INTRODUCTION

EASS Limited is committed to ensuring that its people, platforms, services, and products are not used as conduits for Money Laundering, Financing of Terrorism, proliferation financing, and other Financial Crimes. The Board of Directors of EASS Limited has mandated the implementation of this Anti-Money Laundering Policy (“AML/CFT Policy”) to guide the day-to-day operations of the business.

EASS is a private company committed to working with education institutions in Africa and across the globe to adopt innovative engagement and funding strategies that support student success and preserve institutions’ long-term viability.

EASS helps its clients build stronger relationships with their alumni and donors, raise funds for campus projects, and foster public support for education.

This policy document sets out the guidelines for EASS Limited to comply with AML/CFT obligations under the law and regulatory directives and actively prevent any transaction that facilitates criminal activities.

POLICY STATEMENT
This Anti-Money Laundering (“AML”) Policy is issued under the authority of EASS Limited’s Board of Directors. This document applies to all the Company’s employees, staff, partners, affiliates, clients, agents, and directors. These policies also apply to all subsidiaries and affiliate companies.
This document establishes the compliance framework by which EASS Limited will comply with all applicable laws and regulations as well as global standards. This Policy will be used by the Board as a guide to ensure that the Company’s business is conducted in a manner that is compliant with all applicable laws and regulations.

Also, the following shall guide the principles and procedures for the AML compliance program at EASS Limited:

• Develop and implement appropriate internal controls and processes that will dissuade criminals from using its systems for money laundering and terrorist financing and to ensure compliance with existing laws and regulations.
• Designate Compliance personnel at Senior Management level of the organization, with requisite skill, experience, authority, and independence to implement the AML compliance program of the organization.
• Adhere to the requirements of extant laws, guidelines, and standards
• Collaborate with relevant regulators and law enforcement agencies by responding to requests made in line with subsisting laws, statutes and regulations relating to AML, global sanctions etc.
• During business activities, monitor transactions as defined in relevant AML/CFT standards/guidelines, review the business relationships and report to the relevant authorities as may be required.
• Ensure the Company’s Confidentiality Agreements or Policy does not work at
  variance with the provisions of relevant AML Regulations.
• Discontinue relationships which pose unacceptable money laundering risks to EASS Limited.
• Conduct Due Diligence on all clients and Sanctions Screening as well as adverse media screening.
• Ensure adequate communication of this Policy to raise the level of staff and customer awareness on AML issues.

DEFINITIONS

• Money Laundering – Money laundering (ML) means the attempt at concealment or the actual concealment of the origin(s) of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses and/or illegitimate ownership of property and assets that are the proceeds of illegal/criminal activities.
• Terrorism Financing – This refers to activities that provide financing or financial support to individual terrorists or terrorist organizations through both legitimate and illegitimate means.
• “Customer Due Diligence” or “CDD”: These are the procedures implemented to verify certain aspects about customers’ identity on an ongoing basis, as well as the identification of a Beneficial Owner of an entity, where applicable.
• Know Your Customer (“KYC”) – This is the process of identifying and verifying customer identity and preservation of records of customers.
• “BO”: Beneficial Owner and “UBO”: Ultimate Beneficial Owner – This is the natural person(s) who ultimately owns or controls a customer and/or the natural person on whose behalf a transaction is being conducted. A natural person who owns significant shares/control (5% above) of a legal entity is a BO of that legal entity.
• Nigeria Financial Intelligence Unit (“NFIU”) – This is the Nigerian arm of the global community of Financial Intelligence Units (FIUs) under the Egmont Group.
• Politically Exposed Persons – Individuals who are or have been entrusted with prominent public functions in any country; generally presenting a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.
• Shell Entities – Shell companies are non-public entities that are formed to protect or hide another company’s assets. Existing only on paper, shell companies typically have no physical premises, employees, revenue, or significant assets, but may hold bank accounts or investments.
• Wolfsberg Questionnaire – this is a globally accepted template for AML questionnaire which aims to provide a standardized overview of a financial institutions AML policies and procedures.
• Money Laundering (Prevention & Prohibition) Act 2022 – Provides for an effective and comprehensive legal and institutional framework for the prevention, prohibition, detection, prosecution and punishment of money laundering and other related offences in Nigeria.
• Proliferation Financing – Proliferation is defined by the Financial Action Task Force (FATF) as the illegal manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical, or biological weapons and their means of delivery and related materials.
• Terrorism Prevention & Prohibition Act TPPA 2022 – Provides an enhanced framework to prevent, prosecute and punish acts of terrorism.
• Sanctions Screening – Checking against an ever-changing watchlist of businesses, organizations, individuals, and government agencies to protect against fraud and illicit activity.
• Adverse Media Screening – The process of identifying and analyzing negative or damaging information about individuals, organizations, or entities that is publicly available through various sources.
•  Crowdfunding – A way for companies and individuals to raise capital from a large group of investors
• Designated Non-Financial Business & Professions (DNFBPs) – These are high Cash Intensive Businesses or professional gatekeepers that are susceptible to ML/TF. According to the Special Control Unit Against Money Laundering in Nigeria, the following entities are classifies as DNFBPs -*Dealers in Luxury Goods*Dealers in Jewelry*Car Dealers*Supermarkets*Hotels & Hospitality Business* Casinos, Pool Betting & Lottery Businesses* Audit Firms* Tax Consultants*Accounting Firms*Estate surveyors & Valuers* Trust & Company Service Providers* Real Estate Dealers*Mechanized Farming*Construction Companies*Clearing & Forwarding Companies*Dealers in Precious Stones and Metals*Non-Profit Organizations (NPOs)*Religious Organizations*Association/Clubs/Societies

SCOPE OF THE AML/CFT POLICY
All employees shall comply strictly with provisions of this policy and the Board of Directors of EASS Limited shall be responsible for approving this policy, ensuring compliance with this policy, and driving a good compliance culture within the organization.
The approach to mitigating the Money Laundering and Terrorism Financing (ML/TF) risks identified shall be risk-based to ensure EASS Limited is adequately protected from being used as a conduit or facilitator of ML. The provisions set out in this Policy must always be complied with. The Company reserves the right to take disciplinary action for non-compliant employees or contractors.
There shall be an independent review of the Compliance with this policy on a periodic basis and the outcome of the review shall be communicated to the management and board of directors. The AML/CTF policy encompasses, but is not limited to the following activities:

1. Customer Due Diligence (identification/verification requirements)
2. Customer profiling e.g. PEPs, UBOS
3. Defining the scope of eligible and not eligible activities,
4. Transactional monitoring,
5. Sanctions screening, adverse media screening and regular risk assessments,

Record keeping, training and other pertinent aspects, as required by applicable laws and regulations.
This Policy will be reviewed at least once every two (2) years, to ensure that it incorporates recently enacted rules and regulations, provides guidance on new products, systems/tools introduced by the company, and addresses recent learnings and best practices in the areas of AML and Sanctions.

REFERENCE
EASS Limited will comply with all applicable laws and regulations (hereinafter “AML/CTF Applicable Laws”), and AML, Sanction laws and regulations, FATF Recommendations and additional local AML regulations, as required.
Laws, regulations, and standards applicable to EASS Limited include, but are not limited to:

• Money Laundering (Prevention & Prohibition) Act 2022
• Terrorism Prevention & Prohibition Act TPPA 2022
• Proceeds of Crime (Recovery and Management) Act 2022
• Financial Action Task Force (“FATF”) Forty Recommendations (“FATF 40 Recommendations”);
• All other applicable laws, regulations, rules, directions, orders, and requirements in Nigeria

PURPOSE
The purpose of this Policy is to:

• Provide standards of conduct and practice that must be followed in the implementation of the KYC and Customer Due Diligence requirements as a company providing support services to educational institutions.
• Protect the Company against ML, fraud, reputational and other financial crimes risks.
• Eliminate, and in any event minimize the risks faced by the Company from proceeds of crime.
• Protect the integrity of the transactions undertaken by the Company, against all forms of abuse, fraudulent and unfair practices.

CUSTOMER DUE DILIGENCE
Risk Based Approach
In accordance with various provisions of applicable regulations, EASS Limited customer due-diligence measures and AML controls will involve the use of fact-based decision-making to target the risks of money laundering/Financial Crimes.
EASS Limited shall categorize each customer relationship into either high, medium, and low risk category and will tailor due diligence measures and KYC requirements and approval protocols based on these categories. The risk category of each customer relationship must be based on the assessment of the ML/TF risks posed by the customer, including information about the nature of business relationships, associated countries or geographic areas, products or services offered to such customers, transactional volumes, consistency of behavioral patterns, account tenure, preferred payment or funding methods used, and other pertinent factors.
The assessment of the risk level to be assigned to a customer will take place at the point of onboarding the customer and throughout the relationship with the customer,
to ensure the customer risk profile is dynamic. For Example, all customers identified as PEPs, DNFBPs shall be classified as high risk.
The risk-based approach which shall be adopted by EASS Limited will determine the extent and frequency of the customer due diligence measures/activities and (where applicable) the required approval needed to accept or decline a customer relationship.

CUSTOMER IDENTIFICATION AND ACCEPTANCE
EASS Limited shall identify and verify its customer’s identity (this includes the partner educational institution and their contributors/members/donors) at the commencement of business relationship. The identity of the customer shall be established by consulting official government identification documents e.g. Driver License, National Identity Card, International Passport, Voters Card, and conduct authentication of the said document from source. This includes utilizing a reliable identification database for this purpose, e.g. BVN.
For natural persons, customer information shall be basically validated using the Bank Verification Number (BVN) and government official identification documents.
For legal persons, the incorporation documents of the entity shall be verified, and the identity of all connected natural persons (ultimate beneficial owners) shall be verified accordingly.
All entities shall be screened through a PEP database, Sanctions Screening Database
e.g. OFAC, Nigerian Sanction List etc. and adverse media screening tool e.g. Refinitiv. Also, all legal persons shall be screened through the CAC Person with Significant Control (PSC) register to ascertain Ultimate Beneficial Owners.
The nature of the planned business activities of the customers who are onboarded shall be determined and defined by EASS Limited in the Terms and Conditions that must be accepted by the customer. In the Terms and Conditions, EASS Limited will specifically define which activities are acceptable and not acceptable, and other specifics with respect to the services offered by EASS Limited e.g. Konnect
As a mitigation strategy to address the risk of non-face-to-face relationship (especially for donors), EASS Limited shall deploy the following measures:

• Limit customer to “own transaction.
• Introduce Transaction limits
• Carry out adequate identification via proof of life selfie, facial matching, and confirmation of regulatory identification as well as BVN authentication.

Prohibited Customers
The following customer relationships are prohibited by EASS Limited

• Sanctioned Entities (Natural and Legal).
• Shell Entities – These are entities that cannot be identified in line with the stipulated identification and verification protocols.
• Clients or partners engaged in the following businesses:

1. Any form of illegal activity.
2. Operating a business that requires a license or a special permit without obtaining such license or permit.
3. llegal or unauthorized gambling.
4. Extremism
5. Illegal drugs
6. Illegal firearms and ammunition.
7. Weapons of Mass Destruction (WMD)

Financial services operating anonymous accounts or accounts in fictitious names or numbered accounts

• Clients or partners known or reasonably suspected to be involved in criminal or illegal activities or activities that are incompatible with EASS Limited company values; and
• Clients who refuse to provide all required KYC information, including information about beneficial owners. This also applies to clients who provided incomplete or false information, in which case EASS Limited is unable to establish and verify the identity of the customer and/or the nature of the business relationship.

Clients originating, registered or linked to Non cooperating Countries & Territories (NCCT) as specified by FATF.
EASS Limited reserves the right to terminate relationship with any client at its own discretion, when one of the indicators is present and unresolved or where it has been established that maintaining the relationship with such client would cause serious operational and/or reputational risk to the company.
CDD – ONGOING MONITORING
The due diligence measures must also entail ongoing monitoring of the business relationship and review of transactions to ensure that the transactions being conducted are consistent with EASS Limited knowledge of the customer, including their business profile and the terms of engagement.
EASS Limited shall conduct ongoing due diligence on its customers throughout the relationship by monitoring transactions, screening against sanction lists, monitoring consistency of client behavior, transactional patterns, and reviewing customer identification records.
All the information and documents obtained from the customer during onboarding shall be reviewed on an ongoing basis to identify changes to the customers’ activities, status and profile. The customers classified as High Risk, shall undergo this customer information update at least once every two years while other customers shall be once every three years.
ENHANCED DUE DILIGENCE (EDD)
When it is discovered that a customer represents a higher ML risk, additional information shall be required from the customer. For Politically Exposed Persons (PEPs), an approval by the management must be provided to confirm or decline the continuation of the business relationship.
The following are entities who qualify as High-Risk Customers based on their status or nature of business. However, other matrix like transaction dynamics, mode of transaction, associates, transaction jurisdiction shall determine the customers risk profile.

1. Politically Exposed Persons
2. Designated Non-Financial Business & Professions
3. Customers with recorded suspicious transactions
4. Customers from High-Risk jurisdictions etc.

The following are EDD measures that shall be applied for higher-risk business relationships:

• Obtaining additional information on the customer and updating more regularly the identification data of customer
• Obtaining additional information on the intended nature of the business relationship.
• Obtaining information on the purpose of transaction (intended or performed).
• Verifying information collected from source
• Obtaining documentary details for the sources of funds/wealth for customers such as bank statements, financial statements etc.
• Conducting enhanced monitoring of the business relationship, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.
  An enhanced due diligence form via EASS Limited digital touchpoints shall be executed for this purpose.

SANCTIONS/PEP SCREENING
EASS Limited shall use an external service provider for the purpose of screening customers, at onboarding and on on-going basis, in addition to ensuring adverse media checks are conducted on all customers through available public information.
All functional information available to EASS Limited, either obtained directly from customers or collected independently, will be used to determine whether the customer is included on one of the sanctions lists.
Primary concern is given to UN (Consolidated United Nations Security Council Sanctions List), USA (OFAC SDN List), EU consolidated sanctions list as well as domestic sanctions list (Nigerian Sanctions List). Also, other sanction regimes and private lists are also taken into consideration and incorporated by the service provider while reviewing screening results and assessing whether the customer can be accepted.
The screening result shall be based on the screening matching logic that shall consider full name + date of birth + country of birth or nationality at 90% match. Where there is
a true match at onboarding, the onboarding is discontinued. In the case of an existing relationship, the client relationship is terminated.
All clients are equally screened through a PEP database to ascertain if they will be profiled as PEPs and handled accordingly

RISK ASSESSMENT
EASS Limited shall identify and assess the money laundering risks that may be associated with its unique business, services, and customers. More specifically, EASS Limited:

• Carry out a business-wide ML/TF risk assessment, assessing the risks to which EASS Limited is exposed because of the nature and complexity of its business; and
• Assess the risks to which EASS Limited is exposed as a result of entering a business relationship or carrying out a particular transaction, on a continuous basis.

Each of the above risks assessments will consist of two separate, but related steps:
(a) The identification of the ML/TF risk factors, and
(b) The assessment of any such factors.
The Company shall take reasonable steps to manage them and shall focus resources on the areas of its business that management believes pose the greatest risks.
Based on the outcome of such risk assessment, an appropriate compliance plan shall be developed and executed. The outcome of the AML risk assessment shall be presented to and reviewed by the Board of Directors.
EASS Limited shall put the following measures in place to ensure its business-wide and individual risk assessments remain up to date:

• Set a date for each calendar year, on which the next business-wide risk assessment update will take place.
• Reflect the emergence of new, or an increase in existing ML risks in business- wide and individual risk assessments as soon as possible; and
• For each risk assessment period, record issues that could have a bearing on risk assessments, such as suspicious transaction or activity reports, compliance failures Also. EASS Limited shall identify and assess the money laundering and 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.
• New AML regulations and how they impact new and existing products and services.
  Risk Assessment shall be done prior to the launch or use of such products, practices, and technologies, where applicable, paying particular attention to products or practices that favor anonymity.

TRANSACTION MONITORING AND REPORTING
Adequate resources shall be designated for transaction surveillance using appropriate tools to ensure suspicious transaction triggers are reviewed accordingly.
Suspicious Activity Reports (SARs) shall be reported to the relevant government agency (FIU) when EASS Limited knows, suspects or has reasonable grounds to suspect that money laundering or other financial crimes are being committed or has been committed or attempted. The suspicious report will be filed within 24hrs from the date when the suspicious behavior has been detected.
EASS Limited will:

• Document its SAR decisions accordingly.
• Maintain adequate records for all reported activity.
• Implement all directives and guidance from the FIU and other relevant regulatory or law enforcement agencies on SAR filing.
  All employees of EASS Limited are barred from “tipping off” customers whose transaction has been reported as suspicious to the relevant agency.
  EASS Limited shall ensure that all employees receive appropriate training (including the prohibition against “tipping-off”) on how to report suspicious activities as part of the AML training program.
  To reduce the risk of undue disclosure, EASS Limited shall restrict internal access to SAR filings, documentation, and other SAR-related information to the relevant employees, management, and the Board.

RECORD KEEPING AND RETENTION REQUIREMENTS
EASS Limited shall maintain all necessary records of activities and transactions for at least five (5) years after completion of the transactions or such a longer period as may be required by the law or local law enforcement agencies.
The records of suspicious activities shall also be kept for a minimum period of 5 years.

REGULATORY AND LAW ENFORCEMENT AGENCIES
EASS Limited shall cooperate with relevant regulatory or law enforcement agencies with regards to request relating to AML records as supported by Law.

AWARENESS AND TRAINING
EASS Limited shall implement appropriate training and awareness for all its employees on AML and related financial crimes. This shall be through newsletters, flash-news, online and in-person training sessions etc.
This training and awareness shall take cognizance of emerging trends, regulations and standards on ML risk.
The Board, Management & Staff of EASS Limited shall be trained on AML annually.

RESPONSIBILITIES

Board of Directors

As regards AML, the Board of Directors of EASS Limited shall be responsible for the following.
Ensuring that a comprehensive operational AML Compliance Policy is formulated by Management and regularly updated to comply with the existing regulations.

• Approve the AML Policy
• Provide feedback and advice based on quarterly reports received on AML matters. Providing guidelines regarding the management of AML compliance risks.
• Set the appropriate tone at the top on AML issues to ensure a comprehensive buy-in by all employees.
• Designate appropriate resource e.g. Chief Compliance Officer to develop and implement a robust Compliance Program.
• Encourage active cooperation and feedback among all EASS Limited staff by creating open lines of communication with the Management.

Compliance/Risk Management Function

• Develop an AML Compliance framework and refer same to the Board accordingly.
• Ensure Board directives on Compliance Issues are implemented accordingly.
• Ensure effective communication of relevant developments on ML to the Board.
• Ensure that compliance requirements are integrated into the day-to-day activities of EASS Limited and that processes are efficient and in line with applicable laws and policies
• Coordinate the development of staff in AML awareness, detection methods and reporting requirements
• Ensure daily compliance with applicable ML laws, regulations and best practices.
• Monitor transactions to detect unusual suspicious activities
• Communicating AML issues to all stakeholders

Audit Function
EASS Limited will establish an independent process that will have direct line of communication to the senior management/board. There shall be regular audit and independent review of the AML systems, perform sample testing, review controls efficiency, especially in sanctions screening, customer due diligence, transaction monitoring and reporting suspicious transactions.

The frequency and extent of the reviews should be commensurate with the risks of ML and the size of EASS Limited business. Where appropriate, EASS Limited shall employ external resources for this purpose.

PENALTIES
Where an entity (natural or legal) is found culpable of an offence relating to money laundering or seen to be a facilitator/conduit for money, as stipulated by relevant laws and regulations, that entity shall suffer severe penalties and criminal sanctions which could include imprisonment.
Therefore, every employee of EASS Limited is expected to comply strictly with the provisions of this policy and any violations shall be met with appropriate disciplinary actions