SIAO PARTNERS
KNOW YOUR CUSTOMER POLICY
BACKGROUND
This Policy is intended to serve as a further guide to SIAO Partners/ the Firm on the procedures necessary for the proper knowledge of their customers/ clients.
There is no doubt that having sufficient information about our clients and making use of that information is the most effective weapon against being used to launder the proceeds of crime. In addition to minimizing the risks of being used for illicit activities, it provides protection against fraud, reputational and financial risks and enables individual financial institutions to recognize suspicious activities.
SIAO Partners will not establish a business relationship until all relevant parties to the relationship have been identified, and the nature of the business they intend to conduct has been ascertained. Once an on-going business relationship has been established, any inconsistent activity can then be examined to determine whether there is a suspicion of money laundering.
The first requirement of knowing our clients for money laundering purposes is for SIAO Partners to be satisfied that a prospective client is who he/she claims to be.
SIAO Partners will not carry out, or agree to carry out financial or business activities, or provide advice to a client or potential client, unless they are certain as to who that person actually is. If the client 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 then SIAO Partners has the obligation to verify the identity of both the client and the agent/trustee unless the client is itself a Nigerian regulated financial institution.
Although SIAO Partners as designated non-financial institution has the duty to obtain evidence in respect of their customers, there are certain exceptions to this duty. However, since exceptions are difficult to apply, SIAO Partners are advised to identify all relevant parties to the relationship from the outset. The general principles and means of obtaining satisfactory identification evidence are also set out below.
Sufficient information will be obtained on the nature of the business that the client is undertaking or intends to undertake, including the expected or predictable pattern of transactions.
The information collected at the outset for this purpose will include: purpose and reason for 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/employment/business activities and source(s) of wealth or income.
Reasonable steps shall be taken to keep the information up-to-date as the opportunities arise, e.g. when an existing client gives us a new engagement. Such information obtained during any meeting, discussion or other communication with the client should be recorded and kept in the client