Subsi Stores Limited (Subsi.ng) · Effective 11 April 2026
SUBSI STORES LIMITED
ANTI-MONEY LAUNDERING (AML) & COUNTER-TERRORIST FINANCING (CTF) POLICY
Effective Date: 11th DAY of APRIL, 2026
1. INTRODUCTION
1.1 Purpose
This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines the framework adopted by Subsi Stores Limited (“Subsi.ng”, “we”, “us”) to:
• Prevent, detect, and report money laundering and terrorist financing
• Protect the integrity of our platform
• Ensure compliance with applicable Nigerian laws and regulatory obligations
2. LEGAL AND REGULATORY FRAMEWORK
Subsi Stores Limited complies with all applicable AML/CTF laws and regulations, including:
• Money Laundering (Prohibition) Act 2011 (as amended)
• Terrorism (Prevention) Act
• Regulations and guidelines issued by the Nigerian Financial Intelligence Unit
• Applicable guidance from the Federal Competition and Consumer Protection Commission
3. AML GOVERNANCE STRUCTURE
3.1 Compliance Officer
We shall appoint a designated AML Compliance Officer responsible for:
• Implementing AML controls
• Monitoring compliance
• Reporting suspicious activities
3.2 Responsibilities
Management shall:
• Ensure adequate AML resources
• Approve policies and updates
Employees shall:
• Comply with AML procedures
• Report suspicious activities immediately
4. RISK-BASED APPROACH
4.1 Risk Assessment
We adopt a risk-based approach to identify and assess risks related to:
• Customers
• Transactions
• Geographic locations
• Products and services
4.2 Risk Categories
Customers may be classified as:
• Low Risk
• Medium Risk
• High Risk
5. CUSTOMER DUE DILIGENCE (CDD)
5.1 Customer Identification
We verify:
• Individuals (identity, address, contact details)
• Businesses (CAC registration, ownership, directors)
• Beneficial owners (ultimate control)
5.2 Verification Measures
• Government-issued ID validation
• Address verification
• Phone/email verification
• Biometric/selfie verification (where applicable)
5.3 Ongoing Due Diligence
We continuously monitor:
• Transaction behavior
• Account activity
• Changes in customer risk profile
6. ENHANCED DUE DILIGENCE (EDD)
EDD is applied to high-risk users, including:
• Politically Exposed Persons (PEPs)
• High-value transaction users
• Suspicious activity accounts
• High-risk jurisdictions
EDD measures include:
• Source of funds verification
• Additional identity checks
• Manual review and approval
7. TRANSACTION MONITORING
We implement systems to detect:
• Unusual transaction patterns
• Rapid or large-value transactions
• Structuring (splitting transactions to avoid detection)
• Suspicious vendor or buyer behavior
Transactions may be:
• Flagged
• Delayed
• Blocked pending investigation
8. SANCTIONS AND WATCHLIST SCREENING
We may screen users against:
• Sanctions lists
• Politically exposed persons (PEPs)
• Watchlists issued by regulators or international bodies
Accounts flagged may be restricted or reported.
9. SUSPICIOUS ACTIVITY REPORTING (SAR)
9.1 Internal Reporting
Employees must immediately report suspicious activities to the AML Compliance Officer.
9.2 External Reporting
Where required, reports shall be filed with the Nigerian Financial Intelligence Unit within the legally required timeframe.
10. RECORD KEEPING
We maintain records of:
• Customer identification data
• Transaction records
• Suspicious activity reports
Records shall be retained for at least 5 years or as required by law.
11. DATA PROTECTION
All AML-related data is processed in compliance with the Nigeria Data Protection Regulation.
We ensure:
• Secure storage
• Restricted access
• Lawful processing
12. TRAINING AND AWARENESS
12.1 Employee Training
Employees receive regular training on:
• AML laws and obligations
• Fraud detection
• Reporting procedures
12.2 Ongoing Awareness
We maintain continuous updates on:
• Regulatory changes
• Emerging fraud risks
13. INTERNAL CONTROLS AND AUDIT
We conduct:
• Periodic AML compliance reviews
• Internal audits of AML processes
• System testing for fraud detection effectiveness
14. ENFORCEMENT AND DISCIPLINARY ACTION
Violations of this Policy may result in:
• Disciplinary action
• Termination of employment
• Reporting to regulatory authorities
15. NON-COMPLIANCE AND SANCTIONS
Failure to comply with AML obligations may expose the company and individuals to:
• Regulatory penalties
• Criminal liability
• Reputational damage
16. REVIEW AND UPDATES
This Policy shall be reviewed periodically and updated to reflect:
• Changes in law
• Business operations
• Risk environment
17. CONTACT INFORMATION
For AML-related matters: Company Secretary / Compliance Unit Email: support@subsi.ng Phone: 09064678987