AML/CFT/CPF & KYC Policy

Our policy aligns with the Financial Action Task Force (FATF) recommendations, Central Bank of Nigeria regulations, and other relevant laws. Regular updates by our Compliance Group ensure continued adherence.

The Alternative Bank Ltd is committed to the fight against financial crimes and to leading responsible financial services. Financial crimes involve illegal activities related to money, financial services, or markets, including:

  • Insider Trading
  • Money Laundering (handling the proceeds of crime)
  • Bribery & Corruption
  • Financing of Terrorism and Proliferation
  • Environmental Crime
  • Human Trafficking & Smuggling
  • Illegal Wildlife Trade
  • Tax Evasion
  • Fraud & Forgery

Anti-Financial Crimes (AFC) Program

To mitigate financial crime risks, The Alternative Bank has established a comprehensive AFC program covering AML/CFT/CPF, Anti-Bribery & Corruption (ABC), Whistleblowing, and Sanctions Compliance.

Key aspects include:

Governance and Compliance

Regulatory Reporting & Intelligence Collaboration:

Close collaboration with regulatory bodies such as the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU).

  • Regular Examinations and Spot Checks: Adherence to AML, CFT, and CPF regulations through continuous regulatory assessments.
  • Chief Compliance Officer (CCO) Oversight: Led by a designated CCO and an Executive Compliance Officer to ensure compliance with regulatory standards.
  • Internal & Independent Reviews: Periodic testing and independent audits of financial crime controls.
  • Board-Approved Policies: AFC policies, including AML, CFT, CPF, Employee Conduct, and Whistleblowing, are approved and updated by the Board of Directors.

Anti-Financial Crimes Controls

Our financial crime controls operate across three key phases:

Prevention

  • Rigorous Know Your Customer (KYC) processes.
  • Risk-based due diligence during customer onboarding.
  • Ongoing monitoring of financial transactions.

Detection

  • Continuous transaction monitoring to identify suspicious activities.
  • Thorough investigations of flagged transactions.

Reporting

  • Active tracking and filing of reports in compliance with regulatory requirements.

Execution of Financial Crime Risk Management

The Alternative Bank’s risk management framework operates through:

First Line of Defense: Business units own and manage financial crime risks.

Second Line of Defense: Independent compliance and risk management teams oversee regulatory adherence.

Third Line of Defense: Internal audit independently assesses financial crime risk controls.

Due Diligence & Customer Acceptance

The Alternative Bank conducts risk-based due diligence on customers, correspondents, and third parties, ensuring compliance with:

BVN/NIN requirements for account holders.

SCUML registration for DNFBPs.

CAC and TIN registration for corporate entities.

CERPAC for foreign residents.

FATCA compliance for U.S. nationals.


Due Diligence & Customer Acceptance

The Alternative Bank conducts risk-based due diligence on customers, correspondents, and third parties, ensuring compliance with:

BVN/NIN requirements for account holders.

SCUML registration for DNFBPs.

CAC and TIN registration for corporate entities.

CERPAC for foreign residents.

FATCA compliance for U.S. nationals.


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Abubakar Muhammad Musa

Summary

Abubakar Muhammad Musa is currently a Sharia Advisor and Consultant for SHAPE Knowledge Services a consulting firm based in Kuwait. He has been involved in product development, Sharia research and approval of Islamic banking products for different clients. His work covers retail banking, corporate banking and project finance deals.

Formerly, Abubakar worked as a Researcher in different units at International Shariah Research Academy for Islamic Finance (ISRA) in Kuala Lumpur, Malaysia. Besides his primary assignments in ISRA, he taught Shariah Rules in Financial Transactions to Chartered Islamic Finance Professional (CIFP) Masters online Students of International Centre for Education in Islamic Finance (INCEIF), Malaysia. He also taught MBA and BBA Students different Islamic Banking and Finance Subjects at University College of Bahrain.

Abubakar holds two Diplomas with distinction, one in Islamic Law and the other in Arabic Language from Al-Imam University Riyadh. He also holds LLB (Hons) degree in Shariah from the same University. He successfully completed his (CIFP) Professional Masters Degree Programme at (INCEIF), Malaysia. He had his internship program on Islamic Banking & Finance at Fajr Capital in Kuala Lumpur. During the programme, Abubakar conducted research relating to product structuring and market development.

Abdurraheem Ahmad Sayi

Summary

Abdurraheem Ahmad Sayi is a legal practitioner and Consultant of over 16 years of active legal practice. He is currently the principal partner, A.A. Sayi & Co. (Qist Chambers) and Qadi, Independent Shari’ah Panel of Lagos State – a platform, through which he has delivered several judgments of in-depth analysis, widely applauded by leading legal and intellectual icons, including learned Judges, professors of law and Islamic Studies.

He is the Executive Director/C.E.O., ClearPath Islamic Centre (Incorporated), Lekki-Lagos and Chief Imam, SilverPoint Central Mosque, Badore, Ajah-Lagos. Fondly called Imam Sayi, Abdurraheem is the designate Chairman, Shari’ah Advisory Committee, Mutual Benefit Takaaful.

Imam Sayi has also authored a few works, some of which include: The Financial Obligations: a compendium of essays on monetary or material obligations under Islamic Law and Waqf (Charity Endowment): The Governing Principles.

He holds a Certificate on Improving Personal Effectiveness from the Lagos Business School (Pan African University) and he is a recipient of numerous awards and certificates of merits.

Abdulkader Thomas

Education:

Master of Arts Law and Diplomacy, The Fletcher School of Law & Diplomacy.

Bachelor of Arts Arabic & Islamic Studies, The University of Chicago.

Shariah Board Experience:

Bank Muscat Meethaq (2013 – 2017)

Sterling Bank Nigeria (Since 2013)

University Bank, USA (Since 2006)

Summary

Abdulkader Thomas has over 35 years of diversified financial services experience in major markets. With a Master of Arts Law and Diplomacy from The Fletcher School of Law & Diplomacy and a BA in Arabic & Islamic Studies from The University of Chicago. His areas of activity have included trade finance, real estate finance, securities and alternative finance.

As the general manager of a foreign bank branch in New York, he secured the first US regulatory approvals of Islamic mortgage and instalment credit/sale as banking instruments. Later, he secured US regulatory approval for profit sharing deposits. Abdulkader has been involved in the successful implementation of these products in the US market. With more than 17years Shariah Board Experience in Bank Muscat Meethaq, Sterling Bank Nigeria and University Bank USA, Abdulkader has worked on IFTA projects in Europe, Africa, Southeast Asia, and an authority on Islamic deal structures and securities.

He also serves as a director of Alkhabeer Capital in Jeddah and Chairman of Alkhabeer (DIFC). He is a member of the international advisory board of the Securities Commission of Malaysia, a published author, and an active speaker on Islamic finance.