Grow For Me LTD


Author: Anti-Money Laundering Unit

Recommended By: Executive Management Committee

Approved By: Board of Directors

Date: January 2018





It is the policy of the Grow For Me LTDs to comply with both the letter and spirit of all statutes and regulations relating to money laundering specifically and financial crime in general, as well as provide its staff with the correct training to enable them to identify suspicious transactions and act in accordance with the regulations to protect themselves and the Organization.

1.0 Purpose And Overview Of The Policy and Manual

This Policy and Manual has been formulated by the Organization to reinforce the broad legal requirements and more importantly, to provide best-practice guidance to the Organization‟s staff on how to implement the relevant legal provisions.

Money laundering (ML) has been defined as the process whereby criminals attempt to conceal the illegal origin of illegitimate ownership of property and assets that are the fruits or proceeds of their criminal activities. It is, thus, a derivative crime. Financing of Terrorism (FT) is a reverse form of money laundering and may involve both legitimate and illegitimate money. It is characterized by concealment of the origin or intended criminal use of the funds

Money laundering and terrorist financing are global phenomena and there has been growing recognition in recent times, and indeed, well-documented evidence, that both money laundering and terrorist financing pose major threats to international peace and security and could seriously undermine national development and progress.

Consequently, concerted global efforts have been made to check these crimes. Financial Institutions, in particular, have come under unprecedented regulatory pressure to enhance their monitoring and surveillance systems to prevent, detect and respond appropriately to money laundering and terrorist financing.

This Manual covers the following key areas:

Design of AML/CFT policy framework;

Compliance Officer‟s designation and duties;

The need to co-operate with the competent/supervisory authorities;

Customer due diligence;

Monitoring and responding to suspicious transactions;

Reporting requirements;

Record keeping;

AML/CFT employee training programme;

Appendices defining and listing financial and designated non-financial businesses and professions; money laundering "red flags"; and other resource materials.


2.1 General Guidelines

Grow For Me LTDs (Grow For Me ) is committed to complying with AML/CFT obligations in order to actively prevent any transaction that otherwise facilitates criminal activity or terrorism.

The Organization has formulated and implemented internal controls and other procedures to deter criminals from using its facilities for money laundering and terrorist financing, thus ensuring that it meets its obligations under the law.

The internal control measures include:

  • Programmes to assess the risks related to money laundering and terrorist financing;
  • The formulation of control policy concerned with issues of timing, degree of control, areas to be controlled, responsibilities and follow-ups, to combat money laundering and terrorist financing;
  • Monitoring programmes with regards to unusually large transactions; enhanced due diligence with respect to persons and businesses carrying high risks, including politically exposed persons;
  • Enhanced due diligence on persons in jurisdictions that do not have adequate AML/CFT regimes;
  • Providing employees, including the Compliance Officer, with training on customer due diligence and the recognition and handling of suspicious transactions, etc; and
  • Ensuring employees are aware of the provisions of the AML/CFT laws and regulations and the manual of compliance formulated by the Organization, pursuant to those laws.

3.0 Anti-Money Laundering Reporting Officer's Designation And Duties

The Organization has appointed and at all times has an Anti-Money Laundering Reporting Officer (AMLRO) with the relevant competence, authority and independence to implement its AML/CFT compliance programme.

The duties of the Compliance Officer shall include but not limited to:

Developing an AML/CFT Compliance Programme;

Receiving and vetting suspicious transaction reports from staff;

Filing suspicious transaction reports with the competent/supervisory authority;

Filing of a "NIL‟ returns report with the competent/supervisory authority; 

Ensuring that the compliance programme is implemented;

Coordinating the training of staff in AML/CFT awareness, detection methods and reporting requirements; and

Serving both as a liaison with relevant competent/supervisory authorities and a point-of-contact for all employees on issues relating to money laundering and terrorist financing.

4.0 Co-operation With Competent Authorities

The Organization will comply promptly with requests, and pursuant to the law, to provide information to the competent authority or other relevant government agency. The Organization‟s procedures for responding to authorized requests for information on money laundering and terrorist financing shall include:

  1. immediately searching institutional records to determine whether it maintains or has maintained any account for, or has engaged in any transaction with each individual, entity, or organization named in the request;
  2. reporting promptly to the requesting authority the outcome of the search; and
  3. Protecting the security and confidentiality of any such requests.

5.0 Know Your Customer (KYC)/Client Programme (Due Diligence Procedure)

5.1 What is the "Know Your Customer" Requirement?

The ‟Know Your Customer‟ (KYC) requirement entails obtaining full particulars of the identity of a customer and having adequate knowledge of the purpose for which the customer desires to establish a business relationship with a financial institution. Having adequate knowledge of a customer and applying it to all transactions initiated by the customer is an effective way of avoiding being used to launder the proceeds of crime and recognizing suspicious activities.

Thus, the Organization shall establish clear and written procedures for verifying the identity of persons who open new accounts. The procedures should state the types of information the institution will collect from customers and how it will verify each customer‟s identity.

Our current methods include verification of identity documents by taking selfies with official IDs held next to the customers face. Company documents and IDs are verified by partner banks

5.2 Customer Acceptance Policy

The Organization will not establish a business relationship until all relevant counterparties to the relationship have been identified and the nature of the business they intend to conduct has been duly ascertained. Once an ongoing business relationship has been established and the normal operation confirmed, any inconsistent activity would be investigated to determine whether there is a suspicion of money laundering.

5.3 The Requirement To Obtain Identification Evidence

The first requirement of knowing your customer for money laundering purposes is that the Organization should be satisfied that a prospective customer is who he/she claims to be. The Organization shall not carry out or agree to carry out, any financial business or provide advice to a customer or potential customer unless the Organization has accurately confirmed the individual's identity. If the customer is acting on behalf of another, e.g. the funds are being supplied by someone else, or the investment is to be held in the name of someone else, we have an obligation to verify the identity of both the customer and the agent/trustee unless the customer is itself a regulated financial institution within the country.

5.4 The Nature And Level Of The Business To Be Conducted

Adequate information should be obtained on the nature of the business that the customer intends to undertake, including the expected or predictable pattern of transactions. The information collected at the outset for this purpose should include:

  • Purpose and reason for opening the account or establishing the relationship;
  • Nature of the activity that is to be undertaken;
  • Expected origin of the funds to be used during the relationship; and
  • Details of occupation/business activities and sources of wealth or income.

Adequate steps should be taken to keep the information up to date as opportunities arise, e.g. when an existing customer opens a new account. Such information obtained during any contact with the customer should be recorded and kept in the customer‟s file to ensure, as far as practicable, that current customer information is readily available to the Compliance Officer or relevant regulatory bodies.

5.5 Risk-based Approach to KYC:

The Organization shall adopt a risk-based approach in implementing its KYC policy in respect of certain customers who are considered to carry a "higher risk" than others. Generally, the riskiness of customers may depend upon geographical location, customer type, or the product or service being offered to the customers. Such "higher risk" customer who must be subjected to enhance due diligence investigation on risk-based approach include the following:-

  • private banking customers;
  • correspondent banking;
  • Politically Exposed Persons (PEPS)

For such high-risk entities, the KYC approach should involve customer risk profiling and assignment of specific risk rates, and resort to Enhanced Customer Due Diligence techniques (ECDD).

The ECDD techniques should include:-

  1. Identifying the customer and verifying that customer‟s identity using reliable, independent source documents, data or information (otherwise known as identification data);
  2. Identifying the beneficial owner, and taking reasonable measures to verify the identity of the beneficial owner such that the Organization is satisfied that it knows who the beneficial owner is;
  3. Obtaining information on the purpose and intended nature of the business relationship;
  4. Conducting ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout that relationship to ensure that the transactions being conducted are consistent with the Organization‟s knowledge of the customers, their business and risk profile, including where necessary, the source of funds.

6.0 Leading Issues On Identity

6.1 Definition Of Identity

Identity is defined as a set of attributes, including names used, date of birth, physical features, and the residential address at which a customer may be located, all of which can uniquely identify a natural or legal person. For a natural person, the date of birth and pictures should be obtained as an important identifier in support of the name. It is mandatory to verify the image of the person and an ID.

6.2 Timing Of Verification Of Identity

Identity must be verified whenever a business relationship is to be established and an account opened, or a one-off transaction or series of linked transactions is undertaken. For this manual, the definition of transactions includes the giving of advice. However, advice does not include the provision of information about the availability of products or services or to a first interview/discussion prior to establishing a relationship. Once identification procedures have been satisfactorily completed, and the business relationship established, as long as contract or activity is maintained and records concerning that customer are kept, no further evidence of identity is needed when any transaction or activity is subsequently undertaken.

6.3 Persons Whose Identities Should Be Verified

Customers: Sufficient evidence of the identity must be obtained to ascertain that a customer is who he/she claims to be.

A person acting on behalf of others: The obligation is to obtain sufficient evidence of their identities. This requirement is, however, subject to some exceptions, e.g. in consortium lending where the lead Manager/Agent supplies the normal confirmation letter.

Furthermore, there is no obligation to look beyond the client where:

  • It is acting on its account (rather than for a specific client or group of clients);
  • The customer is a Bank, broker, fund manager or other regulated financial institution;
  • All the business is to be undertaken in the name of a regulated financial institution.

In other circumstances, unless the customer is a regulated financial institution, acting as an agent on behalf of one or more underlying customers within the country, and has given a written assurance that it has obtained and recorded evidence of identity to the required standards, identification evidence should be verified for:

  • The named account holder/person in whose name the investment is registered;
  • Any principal beneficial owner of funds being invested who is not the account holder or named investor;
  • The principal controller(s) of an account or business relationship (i.e. those who regularly provide instructions); and
  • Any intermediate parties (e.g. where an account is managed or owned by an intermediary).

Appropriate steps should also be taken to identify directors and all signatories to an account.

Joint applicants/account holders: Identification evidence should be obtained for all the account holders.

Higher risk businesses being undertaken for private companies (i.e. those not listed on the stock exchange): Adequate evidence of identity and address should be verified in respect of:

The principal underlying beneficial owner(s) of the company; and Those with principal control over the company‟s assets (e.g. principal controllers/directors).

Officers of the Organization should be alert to circumstances that might indicate any significant changes in the nature of the business or its ownership and make enquiries accordingly.

Trusts: Grow For Me Officials should obtain and verify the identity of those providing funds for the trust, i.e. the settlor(s) and those who are authorized to invest or transfer funds or make decisions on behalf of the trust, i.e. the principal trustees and controllers who have the power to remove the trustees.

7.0 Regular Savings Schemes And Savings Accounts

7.1 Investments In The Names Of Third Parties

When an investor sets up a savings account or a regular savings scheme whereby the funds are supplied by one person for investment in the name of another (such as a spouse or a child), the persons who fund the subscription or makes deposits into the savings scheme should be regarded as the applicant for business for whom identification evidence must be obtained in addition to the legal owner.

7.2 Timeframe For Obtaining Verification Requirements

The appropriate timeframe for obtaining satisfactory evidence of identity depends on various relevant factors and circumstances, such as the nature of the business, the geographical location of the parties and whether it is possible to verify the identity before any commitments could be made or transactions executed. A Grow For Me staff may start the processing of account opening as soon as a documented request is received, provided that such staff takes diligent steps to verify the customer‟s identity and does not transfer or payout funds to a third party until the verification requirements have been duly met.

8.0 Identification Procedures

8.1 General Requirements

{% trans ' Every official should at all times satisfy himself/herself  that he/she is dealing with a real person or organization (natural, corporate or legal), by obtaining adequate identification evidence. Where reliance is being placed on a third party to identify or confirm the identity of an applicant, the overall legal responsibility for obtaining satisfactory identification evidence rests with the account-holding Grow For Me.' %}

The requirement in all cases is to obtain satisfactory evidence that a person of that name lives at the address given and the applicant is that person, or that the company has identifiable owners and that its representatives can be located at the address given.

Since no single form of identification can be fully guaranteed as genuine or representing correct identity, the identification process should be cumulative.

In verifying the identity of a natural person, officers should state whether the identification was done face to face or remotely. Adequate steps should be taken to avoid single or multiple fictitious applications or substitution (impersonation) fraud.

An introduction from a respected customer, personally known to a Director or Manager, or from a member of staff, will often provide some comfort but should not replace the need for identification evidence set out in this manual. Details of who initiated and authorized the introduction should be kept in the customer‟s mandate file together with other records. Grow For Me Managers and Heads of Department should insist on normal identification procedures for every applicant.

9.0 Certification of Identification Documents

To guard against the dangers of postal interception and fraud, prospective customers should not be requested to send originals of valuable personal identity documents (such as international passport, identity card, driver‟s licence. etc.) by post.

Where there is no face-to-face contact with the customer, and documentary evidence is required, copies certified by a lawyer, notary public/court of competent jurisdiction, banker, accountant, senior public servant or person of appropriate seniority in the private sector, should be obtained. The person doing the certificate must be known and capable of being contacted, if necessary.

With respect to foreign nationals, the copy of international passport, national I identity card or documentary evidence of address, should be certified by:

An Embassy, Consulate or High Commission of the country of issue; or A senior official within the Organization; or a Lawyer, Attorney or Notary Public.

Certified copies of identification evidence should be duly stamped, dated and signed: ‟original sighted by me‟, by a senior officer of the Organization. Officers should always ensure that a good reproduction of photographic evidence of identity is obtained and failing that a copy of the evidence certified as providing a good likeness of the applicant.

9.1 Establishing Identity

Before opening an account, the account opening officer should request the applicant to provide the following information which should be certified by the applicant by signing the application form and also independently validated by the officer.

Full Name (including all other names used).

Permanent home address, including landmarks and postcode, where available.

Telephone and fax numbers and e-mail address.

Date and place of birth.


Occupation, public position held (if any) and/or name of employer.

Any official personal identification number or other unique identifier contained in an unexpired official document that bears a photograph of the applicant, such as an international passport, driver‟s license, identification card, tax identification number etc.

The information obtained should establish that a person of that name exists at the address given and that the applicant is that person. Where an applicant has recently changed residence, the previous address should be validated.

A risk-based approach should be adopted in verifying the identity of each customer. Thus, the extent and number of checks will vary, depending on the perceived riskiness of the service or business sought and whether the application is made in person or through a remote medium, such as telephone, post or the internet. Furthermore, the actual or anticipated source of funds, i.e. how the payment was made, from where and by whom, should always be recorded to provide an audit trail.

10.0 Establishing Identity For Politically Exposed Persons (PEPs)

10.1 Who are Politically-Exposed Persons?

These are persons who are or have occupied high public office (See Appendix

IV for a comprehensive list of PEPs). There is, thus, a possibility that such persons may abuse their public powers for unjust and illicit personal gain through the receipt of bribes, frauds, etc. Business relationships with such PEPs or entities associated with them may expose the Organization to significant reputational and/or legal risks. Accepting and managing funds from corrupt PEPs will seriously damage the Organization‟s reputation and could erode confidence in the financial system. Furthermore, the legal repercussions could be costly since, in certain circumstances, the Organization and/or its officers and staff may be liable to criminal sanctions against money laundering if they know, or should have known, that the funds in question derived from corruption or other predicate offences. Thus, all the relevant AML laws and regulations, including suspicious transaction reporting, tipping off, etc., apply.

Heavy fines have been imposed on financial institutions for conducting business with PEPs without adequate KYC and enhanced due diligence procedures. Even in the absence of an explicit legal requirement, it is undesirable and unprofessional for a financial institution to accept or maintain a business relationship if the institution knows or must assume that the funds derived from corruption or misuse of public assets. In the circumstances, it is imperative for Officers representing the Organization when entering into a relationship with a person who is suspected of being a PEP to identify that personality fully as well as persons and entities that are related to the PEP.

10.2 Due Diligence Procedures In Respect Of PEPs

To enable the Organization to guard against inadvertently dealing with PEPs, in addition to the standardized KYC procedures, Officers should adopt the following processes:

Gather adequate information from any new customer and check publicly available information or a credible checklist or database in order to establish whether or not the customer is a PEP.

Determine the source of funds and ensure that it does not derive from a corrupt or another criminal source(s) before accepting a PEP as a customer.

Take a heightened scrutiny approach to the account opening process by referring it for approval by the Compliance Officer and Senior Management.

Carry out ongoing monitoring of accounts and transactions of PEPs and additional controls.

Other Higher Risk Accounts

For other higher-risk accounts or customers, similar steps should be taken to ascertain the source of wealth/funds.

10.3 Lower Risk Accounts

Even for lower-risk accounts or simple investment products, e.g. deposit or savings accounts without a cheque book or any of the Organization‟s automated money transmission facilities, there is an overriding requirement for all Officers to satisfy themselves on the identity and address of the customer.

11.0 Establishing Identity of Natural Persons Resident In Ghana

11.1 Trusts, Nominees and Fiduciaries

The confirmation of name and address should be established by reference to a number of sources. The checks should be undertaken by cross-validation that the applicant exists at the stated address either through the sighting of actual documentary evidence, or by 12 undertaking electronic checks of suitable databases, or by a combination of the two. The primary responsibility for ensuring that the identification evidence is satisfactory rests with the Officers/Grow For Me opening the account or providing the product/service.

11.2 Documentary Evidence Of Identity

Care should be taken to ensure that documents submitted are originals in order to avoid the acceptance of forged documents. Copies of documents dated and duly signed, originally seen by a senior public servant or a person of comparable status in a reputable private organization may be accepted, pending the submission of the original documents.

{% trans ' Checklist Of Acceptable Documentary Evidence Of Identity

  • {% trans 'Personal Identity Documents
  • Current international passport.
  • Residence permit issued by the immigration authorities.
  • Current driver‟s licence issued by a competent agency.
  • Official tax identification number or tax clearance certificate.
  • Birth certificate/sworn declaration of age.
  • National identity card.
  • Documentary evidence of address.
  • Recent utility bill.
  • Search report on prospective customer‟s place of employment and residence, duly signed by a senior officer of the Organization.

11.3 Physical Checks On Natural Persons Resident In Ghana

The Organization should have systems that enable it to establish the true identity and address of a customer and effective checks that protect against the substitution of identity by an applicant.

For example, the officer should demand and examine independent source data like water and electricity bills of the prospective customer to confirm proof of residential address.

11.4 Additional checks to verify identity

Additional confirmation of the customer‟s identity and the fact that the application was made by the person identified should be obtained through one or more of the following procedures:

Mailing of account opening documentation directly to a named individual at an independently verified address;

Having satisfactory evidence of an initial deposit cheque drawn on a personal account in the applicant‟s name in another financial institution in the country;

Making telephone contact with the applicant prior to opening the account on an independently verified home or business number, or a call to the customer before transactions are permitted, utilizing a minimum of two types of personal identity information that had been previously provided during the setting up of the account; and using card or account activation procedures.

11.5 Electronic Checks

Where feasible, electronic checks may be used to verify the evidence of identity and address through other different sources as an alternative or supplement to the documentary evidence provided.

11.6 Special Note On Non-Face-To-Face Identification

Non-face-to-face customers, whether resident or non-resident, pose an increased potential risk of false identities and impersonation. Thus, extra care should be exercised in such cases by supplementing documentary or electronic evidence with additional checks to ascertain that each

the customer in the above category is actually who he claims to be.

In cases where financial intermediaries or agents undertake the processing of account opening requests on behalf of prospective customers, Officers should ensure that such intermediaries are subject to AML controls and that the prescribed identification procedures have been complied with. Documentary evidence of such verification should be obtained and kept with other account-opening documents.

11.7 Refugees And Asylum Seekers

In circumstances in which a refugee or asylum seeker applies to open a Grow For Me account without being able to provide the usual evidence of identity, reliance should be placed on certification provided by the relevant or competent government authority confirming the identity of the person in question. As is required for such exceptional circumstances, accounts of this type should be closely monitored to prevent their possible misuse given that such refugees could be PEPs.

12.0 Establishing Identity: Legal Persons Trusts, Nominees and Fiduciaries Cautionary Note

Trusts, nominee companies and fiduciaries conduct a wide variety of commercial activities and often play important and legitimate roles in the global economy. However, the unique features of trusts which attract genuine operators and the anonymity and complexity of structures that they often provide, all tend to make them attractive for criminal activity. Accordingly, there have been general concerns about the misuse of corporate vehicles by criminals to disguise and convert the proceeds of their illegal activities and the use of trusts and other quasi-corporate entities to facilitate such misuse.

Given that trusts and other quasi-corporate entities take different forms and are pervasive, the money laundering risk should be identified and managed on a service-by-service basis. Thus, customer identification procedures should be established to reflect the 12 perceived risks.

Grow For Me officials, when opening accounts for trusts, nominees and fiduciaries, should verify the identity of the trustee(s), the settlor(s), i.e. the provider of the funds, the controllers (who have the power to remove the trustees) beneficiaries, and signatories. The underlying evidence of identity should be kept together with the account opening records on Grow For Me.

12.1 Receipt And Payment Of Funds On Behalf Of Trusts

Officials should check monies received or payments made on behalf of trusts to identify the source of the funds and the nature of the transactions and ensure that adequate due diligence has been observed by the remitting Bank on the underlying client and the origin of the funds.

12.2 Powers Of Attorney And Third-Party Mandates

Grow For Me / officials should obtain and verify identification evidence on holders of powers of attorney and third-party mandates in addition to those of the customers. Furthermore, the reason for granting the power of attorney should be determined and all records of transactions executed pursuant to the power of attorney should be kept.

12.3 Executorships Accounts

Officials should verify the identity of the executor(s)/administrator(s) of the estate when a Grow For Me account is to be opened to wind up the affairs of a deceased person. Payments to the underlying named beneficiaries on the instructions of the executor or administrator of an estate may be made without additional verification requirements. However, if a beneficiary seeks to transact business in his/her name, identification evidence should be obtained. Where there is any suspicion about the nature or origin of assets comprising an estate that is being wound up, a report should be made to the Compliance Officer who would file a suspicious transaction report with the competent authorities.

12.4 Client Accounts opened by Professional Intermediaries

Where a professional intermediary, such as a Solicitor, Fund Manager, Accountant, Stockbroker, or estate agent, holds funds on behalf of its clients in client accounts opened with financial institutions, the professional intermediary is taken as the customer. Where such an intermediary is covered by the anti-money laundering regulations, verification of identity may not be necessary. However, where the intermediary is not subject to anti-money laundering regulations, Grow For Me officials should verify both the identity of the professional intermediary and that of the person on whose behalf he is acting.

The business management should monitor transactions executed on client accounts and report those transactions that give reasonable cause for suspicion to the competent authorities.

12.5 Unincorporated Businesses/Partnerships

Identification evidence should be obtained in respect of the principal beneficial owners /controllers where the applicant is an unincorporated business or a partnership whose principal partners/controllers do not already have a business relationship with the Organization. This procedure entails identifying the main signatories who are vested with a significant measure of control by the principal beneficial owners/controllers.

Evidence of the trading address of the business or partnership should be obtained. Where a current account is being opened, a visit to the place of business may be necessary to ascertain the true nature of the business activities. Also, where appropriate, a copy of the latest report and accounts should be obtained.

The nature of the business or partnership should be ascertained to ensure that it has a legitimate purpose. In cases where a formal partnership arrangement exists, a mandate from the partnership authorizing the opening of an account or undertaking the transaction and conferring authority on those who will undertake transactions should be obtained.

12.6 Limited Liability Partnership

A Limited Liability Partnership should be treated as a corporate customer for verification of identity and ‟KYC‟ purposes.

13.0 Identification Procedures for Corporate Entities

13.1 General Principle

There is particular concern over the ease with which corporate entities could be created and dissolved in some jurisdictions which facilitates the use of these vehicles not only for legitimate purposes but also for criminal activities, such as money laundering. Given the potential risk of misuse of corporate vehicles and the AML protection afforded by factors such as the quality of available information, knowledge of the ultimate beneficial owners as well as the assets and their business objectives, Grow For Me officials should obtain beneficial ownership information and perform customer due diligence at the commencement, and during the course, of a business relationship. This is particularly the case at the account-opening stage.

Furthermore, Grow For Me Management should painstakingly verify the legal existence of the company from official documents or sources and that those persons claiming to act on behalf of the company are duly authorized.

13.2 Identification Requirements

The underlying principles of customer identification for natural persons also apply to corporate entities, especially where the identification and verification of natural persons are involved in the relationship with corporate entities.

For corporate entities, the following information should be obtained:

  • Registered corporate name and any trading names used;
  • Registration or incorporation number;
  • Principal place of business operations;
  • Mailing address;
  • Contact telephone and fax numbers;
  • Names of Directors and secretary as specified in Form 3;
  • Original or certified copy of the certificate of incorporation and the Regulations.
  • The nature of the company‟s business and its legitimacy; and
  • The resolution of the Board of Directors to open an account and identification of the signatories to the account.

Grow For Me Management should verify the information obtained by, at least, one of the following methods:

 Reviewing a copy of the latest report and accounts (audited, if available) for established companies;

Conducting an enquiry through a business information service or an undertaking from a reputable and known firm of lawyers or accountants certifying the documents submitted;

Undertaking a company search and/or other commercial enquiries to see that the institution has not been, or is not in the process of being, dissolved, struck off, wound up or terminated;

Utilising as and when available independent information verification processed, such as accessing public and private databases;

Visiting the corporate entity, where feasible; and Contacting the corporate entity by telephone, mail or e-mail.

13.3 Due Diligence Procedures For High-Risk Business

For private companies and other legal entities undertaking higher risk business, Grow For Me Management should, in addition to the usual requirements for companies, seek to lift the corporate veil and identify those who have ultimate control over the business and the company‟s assets. Identification evidence is required for those shareholders who have significant shareholding (as defined by competent authority) and those who are mandated to manage funds, accounts or investments without further authorization and are thus in a position to override internal procedures and control measures. In keeping with a risk-based approach, identification evidence should be obtained not only for the principal beneficial owners and those who exercise control over the assets of the company but also for the non-executive directors. Grow For Me Management should undertake a visit to the place of business if the volume is large enough not only to confirm the existence of the business and nature and purpose but also its legitimacy. An international business company that is registered in an offshore jurisdiction but operates out of a different jurisdiction requires particular attention. Accordingly, such companies should be subjected to rigorous customer due diligence procedures.

13.4 Identification Procedure For Foreign Financial Institutions

Confirmation of existence and regulated status of a foreign financial institution should be carried out by checking with, at least, one of the following sources:

  • The home country Central Bank or relevant supervisory body; or
  • Another office, subsidiary, Grow For Me, or correspondent bank in the same country; or
  • A local correspondent bank of the overseas institution; or
  • Evidence of its licence or authorization to conduct financial and/or banking business. International publications and directories or any of the international business information services may also be used to reinforce any of the above sources.

14.0 Identification Procedures For Other Institutions And Bodies

With respect to applications made on behalf of clubs or societies, Grow For Me Management should be satisfied with the legitimate purpose of each organization by citing its constitution. The identification requirements prescribed for natural persons apply to the key officers of clubs and societies.

When processing an application by a charity to open an account, Grow For Me Management should satisfy itself that the charity is registered and has a legitimate purpose by citing its registration documents. Satisfactory evidence of the identity of the authorized signatories if they are not already known to the institution, in keeping with the due diligence requirements for natural persons, should be obtained.

Grow For Me Management should verify the identity of a religious organization by confirming its status with the company registry. The identity of the signatories to its account should also be duly verified.

 For Governments and their Agencies, Officers should establish the status of the applicant before opening an account. A certified copy of the registration or other document authorizing the opening of the account or undertaking the transaction should be obtained in addition to evidence that the official representing the agency has the relevant authority to act.

14.1 Foreign Consulates

In respect of Foreign Consulates, there is a need to verify the status of applicants requesting to open accounts or undertake transactions in the names of resident Foreign Consulates and any supporting documents by reference to the relevant Government Ministry or competent authority.

14.2 Correspondent Banking

It is incumbent on the Bank to manage its correspondent banking transactions proactively by taking a risk-based approach. Accordingly, it would have to be ensured that correspondent banks are effectively regulated for Anti-Money Laundering control and have effective customer acceptance and KYC policies.

The Organization would not enter into or continue correspondent banking relationships with banks incorporated in jurisdictions that are identified as high risk because they have poor KYC standards or have been designated as being non-cooperative in the fight against money laundering.

The Organization would guard against receiving funds through its accounts without Treasury or Trade Finance officers taking adequate measures to satisfy themselves that sufficient due diligence had been undertaken by the remitting bank on the underlying client and the origin of the funds. The Organization would consider terminating its relationship with correspondent Banks that do not respond adequately to customer due diligence and suspicious transactions queries.

15.0 One-Off Cash Transactions

Cash remittances and wire transfers (whether inward or outward) or other monetary instruments that are undertaken against payment in cash for customers who do not have an account or other established relationship with the Organization (i.e. walk-in customers) represent a high-risk money laundering category. Thus, adequate procedures should be established to record the transactions and take relevant identification evidence where necessary. Limits for requiring identification evidence should be set at a significantly lower level than that for normal transactions.

15.1 Reinvestment Of Income

Where the proceeds of a one-off transaction are to be payable to a customer, but are then to be invested on his behalf and can only be further reinvested or paid directly to him, and for which a record is to be kept, the identification requirement should be carried out in keeping with the procedure set out for natural persons.

16.0 Monitoring, Recognizing & Responding To Suspicious Transactions

16.1 Definition of a Suspicious Transaction

There are numerous types of suspicious transactions, reflecting the various ways in which money launderers operate. For the purpose of this manual, a suspicious transaction may be defined as one which is unusual because of its size, volume, type or pattern or otherwise 21

suggestive of known money laundering methods, such as a transaction that is inconsistent with a customer‟s known, legitimate business or personal activities or normal business for that type of account or that lacks an obvious economic rationale.

16.2 Training in respect of suspicious transactions

The AML Reporting Officer would train staff to a level that would enable them to monitor, recognize and respond appropriately to suspicious transactions. A list of Money Laundering,‟Red Flags‟ is provided in Appendix iii. The AML/CFT Compliance Officer shall supervise the monitoring and reporting of suspicious transactions. The Organization would be alert to the various patterns of conduct that have been known to be suggestive of money laundering and maintain a checklist of such transactions which would be disseminated to the relevant staff.

When any staff of a financial institution detects any ‟red flag‟ or suspicious money laundering activity, it should promptly institute a review under the supervision of the Compliance Officer who will then issue a suspicious transaction report (STR) to the appropriate authorities.

16.3 Filing A Suspicious Transaction Report (STR)

Where the Compliance Officer knows, suspects or has reason to believe that:

  • A transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity;
  • A transaction is designed, whether through structuring or otherwise, to evade the reporting requirements;
  • A transaction has no business or apparent lawful purpose or is not the type in which the customer would normally be expected to engaged in; or
  • A transaction involves the use of the institution to facilitate criminal activity.

The Compliance Officer should file a suspicious transaction report. See Appendix VI. The Compliance Officer should not base the decision to file a suspicious transaction report solely on whether the transaction falls above the prescribed threshold but should file such a report in all circumstances where transactions raise a reasonable suspicion of criminal, corrupt, or terrorist activities.

The Compliance Officer should report suspicious transactions by completing the prescribed STR form and collect and retain the supporting documentation as required by law and regulations.

16.4 Currency Transaction Report (CTR)

The Organization shall comply with key provisions of the Anti-Money Laundering Act, Act 2008 (Act 749) and Anti-Money Laundering Regulations, 2011 (L.I.1987) regarding Currency Transaction Reporting.

16.5 Cash Management

The Organization shall put in place prudent cash management systems and policies to check "aggregation" of cash deposits and withdrawals made at different times, days, or Grow For Me es for linked accounts (belonging to the same customer). This shall be done with the aid of an AML monitoring tool.

16.6 Funds/Wire Transfers

Funds transfer requests from customers shall be strictly subjected to AML and Foreign Exchange Acts to guard against any breach. Domestic funds transfers, using the Automated

Clearing House and the Ghana Interbank Settlement Systems, with the amount exceeding Ghs100,000.00, shall not be effected without recourse to the Treasury Department. Funds transferred outside Ghana shall be supported with the required documentation before they are effected.

17.0 Remittance Services

The Organization‟s AML/CFT Policy is derived from the direction of the Bank of Ghana (BoG) and the Financial Intelligence Centre‟s (FIC) Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Guideline for Banks and Non-Bank Financial Institutions in Ghana, December 2011, as well as the Financial Action Task Force (FATF) Recommendations, February 2012. It shall at all times be the reference point for all AML/CFT issues hence, applicable to remittance services and Grow For Me networks. Where there appears to be grey areas for clarity in a specific product line and for which there is no definite solution in the bank AML/CFT policy, reference may be made to the respective remittance service‟s AML/CFT control regime and International best practice.

17.1 Detection of Suspicious Transaction

Where a transaction is detected to be suspicious – whether by an internal alert from any of our pay points or escalated to us by our partners, Grow For Me shall take immediate steps to investigate and where need be, file a suspicious transaction report to the Financial Intelligence Centre and inform our respective partner.

18.0 An Audit Function To Test the System 23

There shall be an Independent audit function to test the AML system. This periodic audit test will help review the AML/CFT framework to determine its adequacy, effectiveness and completeness.

19.0 Additional Areas of AML/CFT Risk

The Organization shall review, identify and record other areas of potential Money Laundering risk not covered by the AML & CFT Guideline and report the same half-year to Bank of Ghana (BoG) and the Financial Intelligence Centre (FIC).

20.0 AML/CFT Record Keeping

Record keeping is critical to AML/CFT effectiveness. For instance, investigating authorities need to have an adequate audit trail for suspected money laundering transactions and to be able to establish a financial profile of the suspect account. Thus, it is necessary for the Organization to easily access relevant information or documentation at various stages of a transaction.

To accomplish this, document retention policies have been set and procedures would be established for maintaining AML/CFT records. In establishing a document retention policy, the Organization would be guided by both statutory requirements and the needs of the investigating authorities on the one hand and commercial considerations, on the other.

The broad categories of AML/CFT-related records are:

  • Customer identification and verification documents.
  • Transaction records, including currency transaction reports.
  • Suspicious transaction reports, together with supporting documentation.

AML/CFT-related records may be maintained by way of original documents, stored in microfiche, and computerized or electronic form, subject to the provisions of the law on what is acceptable as evidence.

The Compliance Officer or other designated officer shall be responsible for ensuring that all AML/CFT records are maintained properly and kept for not less than six (6) years before they are sent to the archives.

21.0 Employee Education and Training Programme

21.1 Institutional Policy

Anti-Money Laundering laws in various jurisdictions impose certain obligations on financial institutions and their staff and prescribe criminal sanctions for non-compliance. It is, therefore, imperative that the Head/HRD in consultation with the Compliance Officer design comprehensive employee education and training programmes not only to make

staff fully aware of their obligations but also to equip them with relevant skills required for the effective discharge of their AML/CFT tasks.

21.2 Trainees

The employee training programme would be tailored to meet the perceived needs of the

Organization‟s staff. Nevertheless, a comprehensive training programme would encompass the following staff/areas:

Compliance Officers

New Staff – as part of the orientation programme for those posted to the front office as well as National Service Persons.

Banking Operations/Grow For Me Office staff, particularly cashiers, account opening, mandate, and marketing staff. Internal Control/Audit staff and Managers.

21.3 Content of the Training Programme

The employee training programme shall be developed under the guidance of the AML/CFT Compliance Officer in collaboration with the Human Resources Department. The basic elements of the employee training programme shall include but not limited to:

  • AML regulations and offences
  • Know Your Customer/ Customer Due Diligence(KYC/CDD)
  • The nature of money laundering
  • Money laundering "red flags" and suspicious transactions, including trade-based money laundering typologies.
  • Reporting requirements.
  • The need to combat Money Laundering The effects of Money Laundering
  • Risk-based approach to AML/CFT.
  • Record keeping and retention policy.

22.0 Monitoring of Employee Conduct

The AML Reporting Officer shall have unfettered access to and monitor all employee accounts for potential signs of money laundering. The latter‟s own account is to be reviewed by the Chief Internal Auditor or a person of adequate/similar seniority. Employee accounts would be subjected to the same AML/CFT procedures as applicable to other customers’ accounts. Compliance reports including findings are to be rendered to the BOG and FIC at the end of June and December every year.

The AML/CFT performance review of staff is required to be part of employees‟ annual performance appraisals. 25

23.0 Tipping Off

The Organization, its directors, officers, and employees are prohibited from disclosing the fact that an STR or related information is being reported to the FIC. The identity of the Reporting Officer or any designated officer investigating such a transaction shall not be revealed. A risk exists that customers could be unintentionally tipped off when the financial institution is seeking to perform its customer due diligence (CDD) obligations in these circumstances. The customer‟s awareness of a possible STR or investigations could compromise future efforts to investigate. If the Organization reasonably believes that performing the CDD process will tip off the customer or potential customer, it may choose not to pursue that process and should file an STR.

24.0 Protection for Staff who report violations

The Organization shall direct its staff in the employees AML Handbook to always cooperate fully with the Regulators and law enforcement agencies. They are also required to make it possible for employees to report any violations of the Institution‟s AML/CFT compliance programme to the AML/CFT Reporting Officer. Where the infractions involve the Reporting Officer, employees are required to report to a designated higher authority such as the Chief Internal Auditor.

The Organization shall inform its staff in the employees AML Handbook to make such reports confidential and in good faith and that they will be protected from victimization, civil and criminal liabilities for breach of any restriction on disclosure of information imposed by contract or by any legislative, regulatory or administrative provision, and regardless of whether illegal activity happened.

24.1 Administrative sanctions against staff that violate AML regulations

Any member of Staff that is suspected or found to have contravened any of the AML regulations like tipping-off, aiding and abetting Money Laundering activities, etc, shall be made to appear before the disciplinary committee of the Organization. Such a person when found guilty shall be sanctioned according to the rules of the Organization, and may not be insulated from further civil and criminal liabilities under the AML Law.

24.2 Penalty for Money Laundering infractions under the AML Act

A person who contravenes Section 1 (Money Laundering) or Section 2 (Aiding and abetting money laundering activities) of the AML Act 2008 (Act 749), commits an offence and is liable on summary conviction to a fine of not more than five thousand penalty units or a term of imprisonment of not less than twelve months and not more than ten years or both.

25.0 Concluding note

In the preparation of this Policy and Manual, deliberate efforts have been made to capture and adopt industry best practice. This document shall be reviewed biennially. Nevertheless, should there be a major change in the AML regime whether globally, in the sub-region or nationally that calls for adoption, the Organization shall co-opt that relevant information into this document.


Appendix 1:

Categories of Financial Institutions

(i) FATF 40 Recommendations – lists 13 types of activities/operations/transactions. This is useful for regulatory/supervisory purposes because it provides a comprehensive list of financial activities and leaves little room for regulatory arbitrage. The FATF guidelines state that ‟Financial Institutions‟ means any person or entity who conducts as a business one or more of the following activities or operations for or on behalf of a customer:

  • Acceptance of deposits and other repayable funds from the public.
  • Lending.
  • Financial leasing.
  • The transfer of money or value.
  • Issuing and managing means of payment (e.g. credit and debit cards, cheques, traveller‟s cheques, money orders and bankers‟ drafts, electronic money). Financial guarantees and commitments.
  • {% trans 'Trading in:
    1. money market instruments (cheques, bills, CDs, derivatives etc.);
    2. foreign exchange;
    3. exchange, interest rate and index instruments;
    4. transferable securities;
    5. commodity futures. 
  • Participation in securities issues and the provision of financial services related to such issues.
  • Individual and collective portfolio management.
  • Safe-keeping and administration of cash or liquid securities on behalf of other persons.
  • Otherwise investing, administering or managing funds or money on behalf of other persons.
  • Underwriting and placement of life insurance and other investment relating insurance.
  • Money and currency changing.

The FATF guidelines further provide that:

When a financial activity is carried out by a person or entity on an occasional or very limited basis (having regard to quantitative and absolute criteria) such that there is little risk of money laundering activity occurring, a country may decide that the application of anti-money laundering measures is not necessary, either fully or partially.

„In strictly limited and justified circumstances, and based on a proven low risk of money laundering, a country may decide not to apply some or all of the Forty Recommendations to some of the financial activities stated above‟.

(ii) From an institutional perspective, 5 broad categories have been identified; by the FATF:

23 Banks and other credit institutions;

  • Securities;
  • Insurance; Bureau de Change
  • Money Remittance.

This broad categorization is particularly useful for conducting surveys, typology studies and analytical purposes.

(iii) Subject to the provisions of the relevant national anti-money laundering laws and regulations, financial institutions are encouraged to adopt the FATF definition and 13type categories of financial institutions.


Categories Of Non-Financial Businesses And Professions (DNFBPs) (i) FATF Categories
  • Casinos (which also includes internet casinos).
  • Real Estate Agents.
  • Dealers in precious metals and dealers in precious stones.
  • Lawyers, notaries, other independent legal professionals and accountants.
  • Trust and company service providers – all persons or businesses that are not covered elsewhere.


Money Laundering And Terrorist Financing "Red Flag"
  1. {% trans 'Introduction

Monitoring and reporting of suspicious transactions is key to AML/CFT effectiveness and compliance. Financial institutions should, therefore, endeavour to put in place effective and efficient transaction monitoring programmes to facilitate the process. Although the types of transactions that could be used for money laundering are numerous, it is possible to identify certain basic features which tend to give reasonable cause for suspicion of money laundering.

This Appendix, which lists various transactions and activities that indicate potential money laundering, may not be exhaustive but it does reflect the ways in which money launderers have been known to operate.

Since transaction or activities highlighted in this list may not necessarily be indicative of actual money laundering if they are consistent with a customer‟s legitimate business,

identification of any of the types of transactions listed here should put financial institutions on enquiry and provoke further investigation to determine their true legal status.

  1. Suspicious Money Laundering Transactions And "Red Flags" (i) Transactions Generally Perceived Or Identified As Potentially

(i) Suspicious Of Money Laundering

  • Transactions involving high-risk countries vulnerable to money laundering, subject to this being confirmed.
  • Transactions involving shell companies.
  • Transactions with correspondents that have been identified as higher risk.
  • Large transaction activity involving monetary instruments such as traveller‟s cheques, Bank drafts, money order, particularly those that are serially numbered.
  • Transaction activity involving amounts that are just below the stipulated reporting threshold or enquiries that appear to test an institution‟s own internal monitoring threshold or controls.

(ii) Typologies Of Money Laundering Using Cash Transactions

  • Significant increases in cash deposits of an individual or corporate entity without apparent cause, particularly if such deposits are subsequently transferred within a short period out of the account and/or to a destination not normally associated with the customer.
  • Unusually large cash deposits made by an individual or a corporate entity whose normal business is transacted by cheques and other non-cash instruments.
  • Frequent exchange of cash into other currencies.
  • Customers who deposit cash through many deposit slips such that although the amount of each deposit is relatively small, the overall total is quite significant.
  • Customers whose deposits contain forged currency notes or instruments.
  • Customers who regularly deposit cash to cover applications for Bank drafts.
  • Customers making large and frequent cash deposits but with cheques always drawn in favour of persons not usually associated with their type of business.
  • Customers who request to exchange large quantities of low denomination banknotes for those of higher denominations.
  • Grow For Me es of banks that tend to have far more cash transactions than usual, even after allowing for seasonal factors.
  • Customers transferring large sums of money to or from overseas locations with instructions for payment in cash.

(iii) Money Laundering Using Deposit Accounts

The following transactions may indicate possible money laundering, especially if they are inconsistent with a customer‟s legitimate business.

  • Minimal, vague or fictitious information is provided by a customer which a deposit money bank is not in a position to verify.
  • Lack of reference or identification in support of an account opening application by a person who is unable or unwilling to provide the required documentation.
  • A prospective customer does not have a local residential or business address and there is no apparent legitimate reason for opening a bank account.
  • Customers maintaining multiple accounts at a bank or different banks for no apparent legitimate reason or business rationale. The accounts may be in the same names or have different signatories.
  • Customers depositing or withdrawing large amounts of cash with no apparent business source or in a manner inconsistent with the nature and volume of the business.
  • Accounts with large volumes of activity but low balances or frequently overdrawn positions.
  • Customers making large deposits and maintaining large balances with no apparent rationale.
  • Customers who make numerous deposits into accounts and soon thereafter request for electronic transfers or cash movement from those accounts to other accounts, perhaps in other countries, leaving only small balances. Typically, these transactions are not consistent with the customers‟ legitimate business needs.
  • Sudden and unexpected increase in account activity or balance arising from the deposit of cash and non-cash items. Typically, such an account is opened with a small amount which subsequently increases rapidly and significantly.
  • Accounts that are used as temporary repositories for funds that are subsequently transferred outside the Bank to foreign accounts. Such accounts often have low activity.
  • Customer requests for early redemption of certificates of deposit or other investment soon after the purchase, with the customer being willing to suffer the loss of interest or incur penalties for the premature realization of investment.
  • Customer requests for disbursement of the proceeds of certificates of deposit or other investments by multiple cheques, each below the stipulated reporting threshold.
  • Retail businesses which deposit many cheques into their accounts but with little or no withdrawals to meet daily business needs.
  • Frequent deposits of large amounts of currency, wrapped in currency straps that have been stamped by other banks.
  • Substantial cash deposits by professional customers into client, trust or escrow accounts.
  • Customers who appear to have accounts with several institutions within the same locality, especially when the institution is aware of a regular consolidation process from such accounts prior to a request for onward transmission of the funds.
  • Large cash withdrawals from a previously dormant/inactive account, or from an account that has just received an unexpected large credit from abroad.
  • Greater use of safe deposit facilities by individuals, particularly the use of sealed packets that are deposited and soon withdrawn.
  • Substantial increase in deposits of cash or negotiable instruments by a professional firm or company, using client accounts or in-house company or trust accounts, especially if the deposits are promptly transferred between other client companies and trust accounts.
  • Large numbers of individuals making payments into the same account without an adequate explanation.
  • High velocity of funds that reflects the large volume of money flowing through an account.
  • An account opened in the name of a money changer that receives deposits.
  • An account operated in the name of an off-shore company with the structured movement of funds.

(iv) Trade-Based Money Laundering Typologies

  • Over and under-invoicing of goods.
  • Multiple invoicing of goods and services.
  • False described goods and services and ‟phantom‟ shipments whereby the exporter does not ship any goods at all after payments had been made, particularly under confirmed Letters of Credit.
  • Transfer pricing.
  • Transaction structure appears unnecessarily complex and designed to obscure the true nature of the transaction.
  • Items shipped are inconsistent with the nature of the customer‟s normal business and the transaction lacks an obvious economic rationale.
  • Customer requests payment of proceeds to an unrelated third party.
  • Significantly amended Letters Of Credit without reasonable justification or changes
  • to the beneficiary or location of payment.

(v) Lending Activity

  • Customers who repay problem loans unexpectedly
  • A customer who is reluctant or refuses to state the purpose of a loan or the sources of repayment or provides a questionable purpose and/or source of repayment
  • Loans secured by deposits or other readily marketable assets, such as securities, particularly when owned by apparently unrelated third parties
  • Loans are made for or are paid on behalf of, a third party with no reasonable explanation
  • Loans lack a legitimate business purpose, provide the bank with significant fees for assuming minimal risk, or tend to obscure the movement of funds (e.g. loans made to a borrower and immediately sold to an entity related to the borrower)

(v) Terrorist Financing "Red Flags"

  • Persons involved in currency transactions share an address or phone number, particularly when the address is also a business location or does not seem to correspond to the stated occupation (e.g. student, unemployed, or self-employed)
  • Financial transaction by a non-profit or charitable organization, for which there appears to be no logical economic purpose or for which there appears to be no link between the stated activity of the organization and other parties in the transaction
  • A safe deposit box opened on behalf of a commercial entity when the business activity of the customer is unknown or such activity does not appear to justify the use of a safe deposit box
  • Large number of incoming or outgoing funds transfers takes place through a business account and there appears to be no logical business or other economic purposes for the transfers, particularly when this activity involves designated high-risk locations
  • The stated occupation of the customer is inconsistent with the type and level of account activity.
  • Funds transfer does not include information on the originator, or the person on whose behalf the transaction is conducted, the inclusion of which should ordinarily be expected.
  • Multiple personal and business accounts or the accounts of non-profit organizations or charities are used to collect and funnel funds to a small number of foreign beneficiaries.
  • Foreign exchange transactions are performed on behalf of a customer by a third party, followed by funds transfers to locations having no apparent business connection with the customer or to high-risk countries.
  • Funds generated by a business owned by persons of the same origin or by a business that involves persons of the same origin from designated high-risk countries.

(vi) Other Unusual Or Suspicious Activities

  • Employee exhibits a lavish lifestyle that cannot be justified by his/her salary.
  • Employee fails to comply with approved operating guidelines, particularly in operations.
  • Employee is reluctant to take a vacation.
  • Safe deposit boxes or safe custody accounts opened by individuals who do not reside or work in the institution‟s service area despite the availability of such services at an institution closer to them.
  • Customer rents multiple safe deposit boxes to store large amounts of currency, monetary instruments, or high-value assets awaiting conversion to currency, for placement in the banking system.
  • Customer uses a personal account for business purposes.
  • Official Embassy business is conducted through personal accounts.
  • Embassy accounts are funded through substantial currency transactions. Embassy accounts directly fund personal expenses of foreign nationals.


Checklist of Politically Exposed Persons (PEPs)

The definition of PEPs by national regulatory authorities and best guidance international bodies such as the FATF is generally broad and gives room for differing interpretations. For instance, the FATF in the forty recommendations defines PEPs as ‟individuals who are or have been entrusted with prominent public functions – for example, Heads of State or government, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, important political party officials.‟ The Basel Committee on Banking Supervision, in its Customer Due Diligence for Banks paper, defines PEPs in similar terms.

In the light of the varying interpretations, there is a need to avoid being too restrictive, thereby undermining AML effectiveness or unduly broad resulting in overburdening designated institutions and targeting the wrong persons. However, given the widespread nature of corruption in the regional socio-political environment and the possibility that even some middle-ranking officials would abuse their public powers for their illicit enrichment through bribes, embezzlement, etc. it makes sense to adopt a sufficient definition.

Consequently, the following checklist is provided for the guidance of financial institutions and designated non-financial businesses and professions to enable them to conduct effective PEP screening processes:

  • Heads of state, government and cabinet ministers.
  • Heads of government ministries, departments and agencies.
  • Senior Judges/Judicial Officers.
  • Senior political party functionaries. Members of ruling royal families Senior military officers.
  • Family members and close associates of PEPs.
  • Middlemen, consultants and advisers to PEPs.
  • private companies, trusts and foundations linked to PEPs.
  • Members of Parliament.
  • Managing Directors and all Board Members on State-owned Enterprises and 29 Departments.

The above checklist is informed by the need not only to target PEPs but also to scrutinize all those who, whether as family members, close associates or advisers and consultants – the people behind the PEPs benefit from being close to such persons and are often used by them as fronts for laundering the proceeds of crime.

APPENDIX V List of 21 Common Predicate Offences

FATF Designated Categories of Predicate Offences Is As Follows:

  • Participation in an organized criminal group and racketeering.
  • Terrorism, including terrorist financing.
  • Trafficking in human beings and migrant smuggling.
  • Sexual exploitation, including sexual exploitation of children Illicit trafficking in narcotic drugs and psychotropic substances.
  • Illicit arms trafficking.
  • Illicit trafficking in stolen and other goods Corruption and bribery.
  • Fraud.
  • Counterfeiting currency.
  • Counterfeiting and piracy of products Environmental crime.
  • Murder, grievous bodily injury.
  • Kidnapping, illegal restraint and hostage-taking.
  • Robbery or theft.
  • Smuggling
  • Extortion
  • Forgery
  • Piracy
  • Insider trading and market manipulation
  • Tax Evasion


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