ICEMAN-TECH NIGERIA
ANTI-MONEY LAUNDERING (AML) POLICY
Effective Date: May 15, 2025
Last Reviewed: May 15, 2025
This Anti-Money Laundering (AML) Policy outlines the framework Iceman-Tech adopts to prevent and detect money laundering and terrorist financing in relation to its Partnership Investment Program. We are committed to full compliance with the Money Laundering (Prohibition) Act, 2011 (as amended), relevant regulations issued by the Central Bank of Nigeria (CBN), and global best practices.
Money Laundering: The process of disguising the origins of illegally obtained money to make it appear legitimate.
Terrorist Financing: The act of providing financial support to individuals or groups that engage in terrorism.
1. Prevent the use of Iceman-Tech’s investment program for money laundering or terrorist financing.
2. Establish robust internal procedures for identifying and reporting suspicious activities.
3. Conduct due diligence on all partners and investors.
4. Comply with all legal and regulatory AML requirements.
All prospective investors shall undergo a KYC/AML verification process whenever a transaction above one million naira (1,000,000.00) is performed on there acount which includes:
1. Full name, address, nationality
2. Valid government-issued ID (NIN, passport, or driver’s license)
3. Proof of address (utility bill or bank statement)
4. Source of investment funds
5. Business registration documents (for corporate investors)
Enhanced Due Diligence (EDD) will be required for high-risk individuals or entities.
No investor with transaction above 1million Naira shall be allowed to participate in the Partnership Investment Program without full verification. This includes:
1. Manual or automated ID verification
2. Risk profiling
3. Ongoing monitoring of investment behavior and withdrawals
All investment and withdrawal transactions shall be monitored using AML screening tools. The following triggers will be flagged for review:
1. Unusually large transactions
2. Multiple rapid deposits and withdrawals
3. Mismatched investor identities
4. Unverifiable sources of funds
Suspicious transactions will be escalated to the Compliance Officer and may be reported to the Nigerian Financial Intelligence Unit (NFIU).
Iceman-Tech shall maintain all KYC and transaction records for a minimum of 5 years, in compliance with regulatory requirements. Records shall include:
1. Investor identification data
2. Transaction history
3. Internal AML investigations and actions taken
All staff involved in investment management and customer interaction shall undergo annual AML training. This includes:
1. Identifying suspicious activities
2. Proper documentation and escalation
3. Changes in Nigerian AML regulations
The appointed Compliance Officer shall ensure timely reporting of suspicious activities to the NFIU, and maintain liaison with law enforcement and regulators as necessary.
Failure to comply with this AML policy may result in:
1. Termination of investment relationship
2. Reporting to regulatory and enforcement authorities
3. Legal action in accordance with Nigerian law
This AML Policy will be reviewed annually or as necessary to reflect changes in applicable laws or operational procedures.
Approved by:
Management of Iceman-Tech