+234(0)809 087 6670
4 Taiwo Ishola Street, Lekki Phase 1, Lagos, Nigeria.

Money Laundering

Money laundering policy - Rosemond Hills Policy Statement

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

How we manage the risk

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.

Identification procedures

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 other than private individuals

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:

  • Copy of the Certificate of Incorporation
  • Copy of the most recent filed Audited Accounts
  • Details of the current company officers (Directors, Company Secretary and Shareholders)


Where our client is a representative of an Estate we will obtain the following:

  • Grant of Probate (where a will was left)
  • Letter of Administration (where no will has been left)

Individual identity verification will be required for the executor or administrator.

Suspicious Activity Reporting

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:

  • Reluctance to provide details of their identity
  • Customer is trying to use intermediaries to hide their identity or involvement
  • There appears to be no genuine reason for the customer using the business’s services Regular/Existing Customers:
  • Money is paid by a third party who does not appear to be connected with the customer
  • The customer requests payment to a third party who has no apparent connection with the customer
  • A cash transaction is unusually large and the customer will not disclose the source of funds.
  • A transaction is carried out for less than market value with an unconnected person.

Should a report be made any information about the transaction will be kept confidential

Record Keeping

In accordance with current legislation the following records will kept:

  • Copies of, or references to, the evidence obtained of a customer’s identity.
  • Supporting records relating to a customer relationship or occasional transaction.

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.