1. Introduction

Transingenium Innovations Ltd (“Transingenium”) is committed to the highest standards of anti-money laundering (AML) compliance and ensuring adherence to all applicable laws and regulations in Nigeria, including the Money Laundering (Prohibition) Act 2022 and guidelines from regulatory bodies.

2. Purpose

This policy outlines Transingenium’s approach to preventing and detecting money laundering, terrorist financing, and other illicit activities. The objective is to protect the organization and its customers from being used for illegal activities.

3. Scope

This policy applies to all employees, contractors, consultants, and any parties engaged in business with Transingenium or any of its subsidiaries, products, or services.

4. Definitions

• Money Laundering: The process of disguising the origins of illegally obtained funds to make them appear legitimate.
• Terrorist Financing: The provision of funds or support for terrorist activities.
• Customer Due Diligence (CDD): The process of identifying and verifying the identity of a customer to assess risks associated with money laundering and other financial crimes.

5. Responsibilities

All Transingenium personnel must understand and comply with this policy. Key responsibilities include:

• Identifying and reporting suspicious activities.
• Completing mandatory training on AML compliance.
• Ensuring proper record-keeping and reporting in accordance with regulatory requirements.

6. Customer Due Diligence (CDD)

Transingenium follows a robust CDD process to verify the identity of customers and assess the risks associated with their transactions. This includes:

• Obtaining valid identification documents such as passports, national ID cards, or driver’s licenses.
• Verifying the customer's identity against third-party databases and watchlists.
• Conducting enhanced due diligence (EDD) for high-risk customers, including politically exposed persons (PEPs).

7. Suspicious Activity Monitoring

Transingenium monitors transactions for patterns or activities that may indicate money laundering or other financial crimes. Indicators include:

• Unusually large or frequent transactions inconsistent with a customer’s profile.
• Transactions involving high-risk jurisdictions.
• Structuring transactions to avoid reporting thresholds.

All suspicious activities must be promptly reported to the designated AML Compliance Officer.

8. Reporting Obligations

Transingenium complies with reporting requirements set by Nigerian regulatory authorities, including the Nigerian Financial Intelligence Unit (NFIU). This includes:

• Submitting Suspicious Transaction Reports (STRs).
• Filing Currency Transaction Reports (CTRs) for transactions above specified thresholds.
• Cooperating fully with law enforcement and regulatory authorities during investigations.

9. Record-Keeping

Transingenium maintains accurate records of customer transactions, CDD documentation, and STRs for a minimum of five (5) years, in compliance with Nigerian AML regulations.

10. Training and Awareness

All employees and contractors are required to complete mandatory AML training upon joining Transingenium and participate in periodic refresher courses. Training covers:

• Recognizing suspicious activities.
• Understanding CDD and EDD requirements.
• Reporting obligations and procedures.

11. Non-Compliance

Failure to comply with this policy may result in disciplinary action, including termination of employment or business relationships, and may also result in legal penalties under Nigerian law.

12. Governance and Review

This AML policy is reviewed annually or as required to ensure it remains compliant with evolving regulations and industry standards. The AML Compliance Officer is responsible for overseeing the implementation and effectiveness of this policy.

13. Contact Information

For questions, concerns, or reports related to this policy, please contact the AML Compliance Officer: