Rosemond Hills is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering Regulations of the Federal Republic of Nigeria
Rosemond Hills is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering Regulations of the Federal Republic of Nigeria
Rosemond Hills is committed to staff training in anti-money laundering legislation to ensure our staff are equipped to recognise money laundering and terrorist financing risks and that they understand what they should do to manage these. This training is delivered via group training sessions.
Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism.
Our standard practice in this regard is to obtain, wherever possible, Proof of Identity and Proof of Address, which is compliant with the list of approved documents.
In addition to the above, Rosemond Hills may contract with third-party electronic verification services to identify any Politically Exposed Persons (PEPS).
In the event that the electronic check identify the individual as a PEP then the appropriate level of enhanced due diligence will be applied, as determined by a risk assessment on a case by case basis.
For customers who are not private individuals, such as corporate customers and private companies, Rosemond Hills may contract with a third party electronic verification service for the purposes of verifying that the customer. Due diligence will be carried out, as detailed above, on all beneficial owners, wherever possible. In addition to which Rosemond Hills will also obtain and hold on file company documents as detailed below.
We will seek to obtain for Limited Liability Companies any or all of the below:
Where our client is a representative of an Estate we will obtain the following:
Individual identity verification will be required for the executor or administrator.
A report will be made to the relevant authorities if a member of staff/ the nominated officer thinks that there is a possibility that a person is or has been engaged in money laundering or terrorist financing.
Examples of Suspicious Activity include:
New Customers:
Should a report be made any information about the transaction will be kept confidential
In accordance with current legislation the following records will kept:
The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.
In consideration of our carbon footprint copies of all documents procured for the purposes of identity verification will be stored electronically and only printed where absolutely necessary.
Rosemond Hills has an appointed Nominated Money Laundering officer whose responsibility is to receive internal reports from employees on suspected suspicious activity and forward these reports to the relevant agency.