Anti Money Laundering Policy

Loomo Systems Nigeria Limited (Loomo) is committed to fighting money laundering and complying fully with anti-money laundering legislations. We understand that we have responsibilities to help fight the global battle against money laundering and our commitment will supersede all other privacy obligations contained in our policies.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere, and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, ponzi schemes, cybercrime and other investment-related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Accordingly, in order to comply with applicable AML/CTF legislations, Loomo has implemented systems and controls that meet the standards applicable to regulated sectors such as banking. This decision reflects our desire to prevent money laundering and terrorist financing. Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

Loomo AML and CTF framework include establishing and maintaining a risk-based approach to Customer Due Diligence, including customer identification, verification, and KYC procedures. To ensure we meet these standards, our customers are required to provide certain personal details and documents when opening a Loomo Account. In certain circumstances, Loomo may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes and Politically Exposed Persons (PEPs); establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate; maintaining appropriate KYC records for the minimum prescribed periods; providing training on the framework and raising awareness among all relevant employees; designing systems and controls to allow Loomo to comply with all required sanction screening processes imposed by relevant regulatory authorities and to take measures to prevent transacting with individuals, companies, and countries appearing on these sanctions lists.

There is also an independent AML/CTF Compliance function at Loomo which shall be executed and managed by a designated Compliance Officer, who will regularly update management and board of directors on all material issues.

Loomo identifies and assesses the money laundering and terrorism financing risks that may be associated with its unique business, services, and customers. More specifically, Loomo shall carry out a business-wide AML/CTF risk assessment on a regular basis, for the purpose of assessing the risks to which Loomo is exposed as a result of the nature and complexity of its business; and assess the risks to which Loomo is exposed as a result of entering a business relationship or carrying out a particular transaction, on a continuous basis.

Loomo will identify and assess the money laundering and terrorism financing risks that may arise in relation to new products and business practices as well as new service delivery channels; the adoption of new technologies for both new and pre-existing products; and new AML regulations and how they impact new and existing products and services.

Loomo shall ensure timely and accurate rendition of all AML/CFT returns as specified in the relevant Regulations/Act/Guidelines/Circulars that may be issued from time to time by various government authorities. We shall exercise due diligence in identifying and reporting suspicious transactions. Suspicious transactions shall include transactions that are structured to avoid reporting and record-keeping requirements; altered or false identification or inconsistent information or any transaction involving criminal activity; and any entity that belongs to a person or organization considered as a terrorist.