1. Customer Due Diligence (CDD)

• Verify customer identity (name, address, date of birth, nationality).
• Conduct risk assessments to identify high-risk customers.
• Obtain information on customer’s business or occupation.

2. Transaction Monitoring

• Monitor transactions for suspicious activity (e.g., large or unusual transactions).
• Report suspicious transactions to the Nigerian Financial Intelligence Agency (NFIU).

3. Reporting Suspicious Transactions

• File Suspicious Transaction Reports (STRs) with NFIU within 3 days.
• Provide required information (customer details, transaction details, reason for suspicion).

4. Record Keeping

The money laundering Regulations requires firms to retain records concerning Customer’s identification and transactions for use as evidence in any possible future investigation. Our customer on-boarding documents facilitate the establishment of the identity and verification of the Customer and it is the firm’s policy to retain copies of such documents for six (6) years after the relationship with the Customer has ended. The full scope of records to be maintained should cover:

• Customer information
• Transactions
• Internal and external suspicion reports
• Money Laundering Compliance Officer’s reports
• Evidence of Training and compliance monitoring

5. Training and Awareness

It is the policy of the firm that all new staff are given Anti-Money Laundering training prior to commencing their role or within a reasonable period of commencement.

It is a regulatory requirement that every relevant member of staff receives adequate training on money laundering and terrorist financing prevention. At Mita Technologies Limited, training may take place either through electronic learning, face to face talks, and ad-hoc emails.

The training provided will be developed by the Money Laundering Compliance Officer in collaboration with the Compliance Department. The scope of training will cover, as a minimum, the following key areas:

• The nature of Money laundering;
• AML/CFT Regulations and offences;
• Money laundering ‘red flags’ and suspicious transactions, including trade-based money laundering typologies;
• Reporting requirements;
• Know Your Customers requirements; and
• Record keeping and retention policy

The Firm will obtain an annual declaration from each employee to the effect that they have read and understood the anti-money laundering Manual.

6. Compliance Officer

Mita Technologies Ltd will designate an Anti-Money Laundering Officer. The Anti-Money Laundering officer will be responsible for:

• Considering internal reports of money laundering;
• Reporting suspicions of money laundering to the responsible authorities;
• Acting as key liaison with the money laundering authorities.
• Training the business and its employees on money laundering;
• Submitting weekly reports to the Special Control Unit Against Money Laundering (SCUML)
• Advising on proceed after a report of suspicion on money laundering has been raised; and
• Designing and implementing Anti-Money Laundering processes and procedures.

Receiving Complaints or Investigation Requests