Policies

(1). (AML/CFT) Risk Assessment and Mitigation Policy

This Anti-Money Laundering & Combating the Financing of Terrorism (AML/CFT) Risk Assessment and Mitigation Policy (AML/CFT RAM Policy) sets out the framework which Asset Matrix Microfinance Bank Limited (Asset Matrix MFB or the Company) shall apply in identifying the degree of potential Money Laundering/Terrorist Financing (ML/TF) risks associated with specific customers and transactions in order to ensure focused monitoring of t hose customers and transactions that potentially pose the greatest risks of ML/TF.

Asset Matrix MFB adopts a risk-based approach that is commensurate with the specific risks of money laundering and terrorism financing. Higher money laundering risks demand stronger controls. However, all risks, whether low, medium or high, must be mitigated by the application of necessary controls such as the implementation of appropriate customer due diligence, verification and monitoring procedures that are proportionate to the identified ML/FT risks that the financial institution is exposed to from its customers, products and countries that it transacts business with.

This AML/CFT RAM Policy applies to all of Asset Matrix MFB’s Personnel. You must read, understand and comply with this AML/CFT RAM Policy when processing transactions with Customers. This AML/CFT RAM Policy sets out what we expect from you for the Company to comply with relevant ML/FT laws.

This AML/CFT RAM Policy is an internal document and cannot be shared with third parties, Customers or regulators without prior authorisation from the Company.

Unless otherwise expressly defined herein, the definitions set out in the AML/CFT Policy of Asset Matrix MFB are incorporated in this AML/CFT Policy.

While our clients sit back and relax, we initiate and complete the instant fund transfer based on clients' requested. and the beneficiary is paid instantly after confirmation of the necessary requirements.

(2).Scope

The Personnel of Asset Matrix MFB, its board of directors, management and every person working for ASSET MATRIX MFB are required to adhere to this AML/CFT RAM Policy to protect Asset Matrix MFB and its reputation from being misused for money laundering and/or terrorism financing by ensuring they discharge their responsibilities in a manner that enables full implementation of this AML/CFT Policy.

Asset Matrix MFB Limited shall apply this AML/CFT Policy to its relationships with its counterparties or partners.

Specifically, the AML/CFT RAM Policy shall be incorporated into the operations of business marketing, business origination, market regulation, financial control, as well as any other relevant departments within Asset Matrix MFB Limited.

Asset Matrix MFB Limited shall review this AML/CFT RAM Policy from time to time, as is required.

Please contact the Company with any questions about the operation of this AML/CFT RAM Policy, or if you have any concerns that this policy is not being or has not been followed.

(3). Purpose

The purpose of this AML/CFT RAM Policy is to:


• Provide guidance for identifying the degree of potential ML/TF risks associated with specific customers and transactions in order to ensure focused monitoring of those customers and transactions that potentially pose the greatest risks of ML/TF.
• Provide an internal risk assessment and mitigation policy for ASSET MATRIX MFB.
• Provide guidance on the standards of conduct and practice that must be followed in the implementation of the KYC and CDD requirements of a financial institution.
• Protect ASSET MATRIX MFB against fraud, reputational and other financial market risks.
• Minimise the risks of ASSET MATRIX MFB inadvertently processing proceeds of crime.
• Protect the integrity of the financial market against all forms of abuse, fraudulent and unfair trade practices.
• Comply with relevant rules and regulations of the CBN.