/ Compliance Policy

In accordance with AML/CFT/CPF global best practice, the “tone is set from the top”. The Board of Directors of the Bank has oversight responsibilities for the AML/CFT/CPF framework. The Board ensures that the Bank’s Management and all employees adhere strictly to all regulatory and internal procedures relating to AML/CFT/CPF and that the Bank maintains a zero-tolerance threshold to regulatory infraction. The Bank’s Chief Compliance Officer is appointed by the Board of Directors and approved by the Central Bank of Nigeria (CBN).

On a monthly and quarterly basis, AML/CFT/CPF reports are submitted to the Bank’s Senior Management and Board members respectively. These reports provide the Board and Senior Management with information to enable them to assess the Bank’s compliance with its regulatory obligations. The reports also ensure that Directors and Senior Management are kept abreast on current trends and developments in the financial industry, particularly in the area of AML/CFT/CPF risk management.

To ensure that only customers that align with the Bank’s risk appetite are on-boarded, duly completed account opening forms, identification documents and other relevant information and documents are provided. This is the foundation/ bedrock for on-boarding a customer in the Bank.

Customer Due Diligence (CDD) is conducted prior to entering any banking relationship with a customer. This includes at a minimum, identity and address verification as well as ascertaining the source of income and wealth of the customer.

Customers that are identified as high risk are subjected to Enhanced Due Diligence (EDD). EDD is conducted on such customers including Politically Exposed Persons (PEPs) to assess and manage the risks that the customers may pose. The approval of Senior Management and the Compliance team is required prior to the commencement of banking relationship with such high-risk customers

In compliance with regulatory requirements and perceived AML/CFT/CPF risk threats, Designated Non-Financial Businesses and Professionals (DNFBPs) and other similar businesses are required to undertake requisite and regulatory measures prior to account opening.

As part of the Bank’s KYC and CDD procedures, identification documents are requested and obtained to confirm the Ultimate Beneficial Owners of a business and the organization’s control and structure.

Sanction screening is also conducted prior to entering a relationship as well as prior to effecting a transaction to ensure that the Bank does not enter a relationship with a sanctioned person/entity.

The Bank is also in compliance with the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards criteria, and thus, have put measures in place to identify the defined persons in the Bank’s database. All identified US persons are required to complete the requisite tax forms i.e., W8 BEN, W8 BEN-E and W9.

Transaction monitoring is done using manual and automated methods. The former is performed by employees, who regularly identify red flags in transactions/activities and the latter resides within the Compliance team with the aid of transaction monitoring solutions.

Employees are aware that suspicious activities/ transactions should immediately be referred to the Compliance team.

Suspicious Transactions are brought to the attention of the Compliance team on a manual or automated basis; the former by way of employees filing internal suspicious transaction reports to the Compliance team and the latter by way of transaction monitoring tools reviewed by Compliance Officers. If deemed appropriate, suspicious transaction reports (STRs) are filed with the Nigerian Financial Intelligence Unit (NFIU).

To properly monitor transactions passing through the Bank’s systems, the SAS AML tool, has been fully deployed in the Bank, providing an advancement in how transactions are monitored and investigated.

Regulatory and statutory requirements stipulate that certain reports and returns are made to regulatory bodies. In Nigeria, the NFIU is the agency charged with the responsibility of receiving the following core transaction-based reports:

• Currency Transaction Report (CTR)
• Foreign Currency Transaction Report (FTR)
• Suspicious Transaction Report (STR)

The Bank renders reports to the NFIU and the CBN in accordance with the provisions of Sections 3, 7 and 11 of the Money Laundering (Prevention and Prohibition), Act 2022 (“the Act”).

Section 3 of the Act provides that financial institutions must submit a report on all international transfer of funds and securities of a sum exceeding ten thousand dollars ($10,000) or its equivalent in other foreign currencies.

Section 7 of the Act provides that a Financial Institution must submit a report on all unusual and suspicious transactions.

Section 11 of the Act provides that any lodgment or transfer of funds in excess of N5 million and above for individuals and N10 million and above for corporate customers must be reported.

The Bank also, where applicable, in accordance with the Act, provides transaction-based reports to competent authorities as required

The Bank maintains a cordial and supportive relationship with all regulatory and law enforcement agencies. The Bank promptly complies with and responds to all requests made, pursuant to the law, and provides information to regulators including the NFIU, the CBN and other relevant agencies.

The Bank is also at the forefront of cooperating with regulators to give feedback on new regulations and means to mitigate the risks that are being encountered in the financial industry brought on by new innovations and developing trends.

As a policy, the Bank does not enter any relationship with sanctioned individuals/entities. All employees, as applicable to their functions, are required to screen names of individuals and organizations who have or plan to enter a business relationship or carry out a transaction with/through the Bank against the Bank’s internal watch list.

The internal watch list contains amongst others, the names of individuals and entities, who have been blacklisted by various regulatory bodies worldwide: Office of Foreign Asset Control (OFAC); European Union (EU); Her Majesty’s Treasury (HMT); The Ministry of Economy, Finance, and Industry in France (MINEFI); The United Nations (UN) and The Local List as provided by local regulatory and enforcement bodies.

Employees are required, as part of the Bank's policy, to refrain from any relationship and/or transaction which yield a true or positive match and follow the escalation procedure. Sanctions screening is done at account opening and on a real time basis for all SWIFT transactions.

PEPs are individuals who are or have been entrusted with prominent public functions and the classification includes people or entities associated with them. Enhanced due diligence measures are applied to PEPs, as with other high-risk customers to mitigate the AML/CFT/CPF risk they pose. This is to ensure that the Bank is not unknowingly supporting activities such as money laundering and/or the financing of terrorism.

In line with FATF's recommendation, the Bank employs the use of an automated monitoring tool in identifying and monitoring PEP transactions. This is achieved through the thorough review of information provided by customers and their transaction trends. Continuous monitoring is also carried out on these accounts.

On-boarding of new PEP accounts, as well as continuity of such accounts (for those already existing in the Bank) is subject to the approval of an Executive Director and the Compliance Team.

The Bank only on-boards and maintains correspondent banking relationships with financial institutions that have implemented adequate AML/CFT/CPF policies and procedures. The Bank does not enter any form of relationships with shell banks nor maintain any payable through accounts. The Bank ensures that due diligence, including adverse media searches, are performed annually on our correspondent relationships to mitigate potential AML/CFT/CPF risks.

In line with international best practice, the Bank does not open accounts or conduct transactions for customers using pseudonyms or numbers instead of actual names.

The Bank also does not maintain relationships with individuals or entities that have been sanctioned.

The Bank conducts Risk Assessment on its customers, branches products and services. This is to ensure that AML/CFT/CPF risks are identified, assessed, and mitigated.

The Bank upholds the highest standards of ethical conducts in all its activities and interactions. The Bank has zero tolerance for any form of bribery, corruption, fraud, and unethical practices among employees, between the Bank and its employees, as well as between the Bank and external parties. The Bank also expects the same standards to be applied by third parties acting on behalf of the Bank. The Bank’s Board approved Ethics policy provides the requisite standards and principles on ethical conducts and practices expected and required of all staff and our related stakeholders.

The Bank places a significant importance on the training of its employees. Training is conducted to ensure employees are well informed and up to date on the AML/CFT/CPF laws, KYC principles and the red flags of money laundering or terrorism financing which may occur in their job functions.

Annual Compliance training is mandatory for the Board members and all levels of staff, including Senior Management. Trainings are conducted via e-learning, face to face or on an ad-hoc basis by email or via intranet slides to the appropriate personnel in relation to topical national and international findings. Tests are also conducted annually after the trainings to ensure that all employees have understood the training contents.

To ensure compliance with laws and regulations and to ensure an ever-evolving fit for use of the Compliance function, internal audit of the AML/CFT/CPF function is conducted on a quarterly basis. The purpose of the audit is to test the adequacy of the AML/CFT/CPF functions and ensure that the AML/CFT/CPF measures put in place by the Bank are up to date and effective.

The reports and findings of the audit are circulated to Senior Management. A follow-up to the audits takes place to ensure that the relevant issues are closed out and that the highlighted recommendations have been implemented.

The Compliance function also undergoes a periodic independent review by an external consultant in accordance with regulatory requirements.

In accordance with regulations, customer identification documents are retained throughout the life of the account and for five (5) years after the cessation of the banking relationship. Transaction instruments are retained for five (5) years after the transaction date. In litigation and/or regulatory investigations, the records will be kept for as long as they are required.

The Bank has a duly approved Data Protection Policy which is continuously revised to reflect changes in the Bank’s legal, regulatory, and operating environment, as well as global best practices. The Bank strives to ensure that its operations and practices are in compliance with local and international data protection and privacy laws and regulations such as the National Data Protection Regulations in countries where we operate and the European Union General Data Protection Regulation (EU-GDPR).

The Bank has a Whistle Blowing Policy which is approved by the Board. This Policy governs the reporting and investigation of improper or illegal activities at the Bank, as well as the protection offered to the “Whistle blowers”.

All disclosures will be treated with strict confidence and the identity of the Whistle blower will not be revealed except as required for Security, Regulatory or Legal purposes.

The following guidelines should be noted:

• Information provided should be disclosed in good faith backed by true and reasonable facts and /or evidence where possible.
• The Whistle blower/reporter should ensure that the disclosure is substantially true.
• Whistle blowing is not to be used for malicious acts or making false allegations.
• Whistle blowing is not to be used for personal vendetta or smear campaign.
• The Whistle blower shall be contacted by any of the recipients of the report where additional information is required.

The Bank’s Whistle blowing method consist of a secure portal (hoisted on the intranet and internet) where the disclosure or whistleblowing information is logged.

The Bank places a significant importance on tackling any form of Modern Slavery or Human Trafficking.

The Bank will not allow, facilitate, or condone any form of Modern Slavery or Human Trafficking across our business. The Bank also expects the same standards to be applied by suppliers and third parties acting on behalf of the Bank.

This is supported through the communication, established controls and, proactive steps to ensure compliance with all Anti-slavery and Human trafficking laws and regulations as well as ensuring alignment to the organisation’s ethical standards and Code of Conduct.

GTBank is committed to providing high-quality IT services to both internal and external customers, while also ensuring the confidentiality, integrity, availability of all data, and timely resumption of operations and personnel safety in the event of an incident in line with management systems of the International Standard Organisation (ISO).