AML Policy




  1. The Company


  1. Introduction


  1. Objectives


  1. Definitions


  1. Governance


  1. Minimum Standards


6.1. Enterprise-Wide Risk Assessment


6.2. Know Your Customer (KYC)

6.2.1. Customer Identification and Verification

6.2.2. Individual Risk Assessment

6.2.3. Ongoing Customer Due Diligence


6.3. Monitoring of Transactions (Know Your Transactions (KYT))


6.4. Record Keeping


  1. Organisation of Internal Control

7.1. Suspicious Transactions Reporting (STR)

7.2. Procedures

7.3. Training

7.4. Compliance Monitoring Program

7.5. Reporting

7.6. Corporate Audit




Valborg Selma Insight Limited (Known as VSI Limited) is company incorporated October 13, 2020 under the Companies And Allied Matters Acts of Nigeria 1990 with RC 1721693 to engage in business of online general trading and investment, online / general marketing services customers among others. It concentrates on its home markets : Nigeria



In response to the international community’s growing concern with regard to money laundering and possible financing of terrorism, many countries worldwide enacted or strengthened their laws and regulations regarding this subject. Money laundering in Nigeria has been a punishable offence since 2011. The Law on prevents the use of the financial system for purposes of laundering money and terrorism financing.


As a regulating body, the Central Bank of Nigeria (CBN) has issued a number of recommendations outlining the obligations of financial and non-financial institutions with regard to money laundering and the fight against terrorism financing. These recommendations encompass provisions applicable.



The purpose of this policy is to establish the general framework for the fight against money laundering and terrorism financing throughout the VSI Limited.


VSI Limited is committed to high standards of anti-money laundering / counter terrorism financing (AML/CTF) compliance and requires management and employees to adhere to these standards in preventing the use of its products and services for money laundering or terrorism financing purposes.


Therefore, VSI Limited are expected to develop an AML-program that is based on Compliance Rules and encompasses “Know Your Customer” (KYC) and “Know Your Transactions” (KYT)-rules considered by the company as minimum standards together with procedures transposing these minimum requirements into operational terms and taking into account local regulatory requirements.



Money laundering is the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;

– the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity

or from an act of participation in such an activity;

– the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;

– participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.


Terrorism financing is the provision or collection of funds and other assets, by any means, directly or indirectly, with a view to, or in the knowledge that those means will be used in full or in part by a terrorist organization or by a terrorist acting alone, even without any connection to a particular act of terrorism.




The Chief Financial Officer of the company saddled with Compliance function reports directly to the Chief Risk Officer, who is a member of the VSI Limited Executive Committee and who is responsible for group-wide adherence to applicable AML/CFT regulations and obligations.




Following standards are to be considered as minimum requirements and are elaborated in more detail in VSI Limited wide Compliance Rules with respect to “Know Your Customer” and “Know Your Transactions”.


6.1.Enterprise-wide Risk Assessment (EWRA) In accordance with the current EU AML Directives on the prevention of the use of the financial system for the purposes of money laundering or terrorism financing (Directive 2015/849) and as

part of VSI Limited’s risk-based approach, all entities of VSI Limited are required to assess on a yearly basis the risks of money laundering and terrorism financing, taking into account risk factors relating to their customers, countries or geographic areas, products, services, transactions and

delivery channels. These enterprise-wide risk assessments are documented, kept up-to-date and made available to the local competent authorities.



6.2.Know Your Customer (KYC)


6.2.1. Customer Identification and Verification VSI Limited has established standards regarding Know-Your-Customer. These standards require due diligence on each prospective customer before entering into a business relationship via identification and verification of his identity and, as the case may be, his representatives and beneficial owners on the basis of documents, data or information obtained from a reliable and independent source compliant with the domestic and European anti-money laundering legislation and regulations; via obtaining information on the purpose and intended nature of the business relationship VSI Limited does not allow its entities to open anonymous accounts.


6.2.2. Individual Risk Assessment

The factors taken into account for the individual risk assessment and classification (very high–high-medium-low risk) of our customers on a risk-sensitive basis are the ones that are in scope of the Enterprise-Wide Risk Assessment as mentioned above and relate to the same categories of risk :

  • Delivery channel risk
  • Product, service or transaction risk
  • Customer risk


  • Geographical risk

Examples of such risk factors that VSI Limited is taking into account to assess

customers as an increased risk of ML/TF and for which an enhanced due diligence

is applied, are :

o the home country or country of residence or registration;

o the country of birth or incorporation;

o the nationality;

o the profession;

o the economic activity;

o the appearance on sanction lists;

o the PEP-status ( politically exposed persons) of customers, representatives

and beneficial owners;

o the delivery channel (face-to-face or remotely with or without safeguards);

o the source of wealth;

o the type of customer;

o the type and size of payments that could be expected.


Customer Acceptance Policy

VSI Limited refuses to establish or to maintain a business relationship if the ML/TF risk related to the business relationship appears too high. Therefore, VSI Limited will not enter into/maintain business relationships if :

  • It concerns PEPs residing in high risk countries as per Transparency

International’s Corruption Perception Index;

  • It concerns offshore patrimonial companies (= passive NFE’s);
  • It concerns correspondent financial institutions located in high risk countries

except with positive advice of the Company Compliance Function;

  • It concerns cash, cheques or physical securities without the customer being

identified face-to-face or identified remotely with safeguards;

  • It concerns long-term products (loans, life insurance policies) as long as the

customer has not been identified, his identity verified and accepted in an

appropriate way;

  • It concerns arms/munitions dealers;
  • It concerns unlicensed gambling entities.
  • It is not satisfied that the purpose and nature of the business relationship are


  • It is not satisfied that the ML/TF risk can be effectively managed, such as no or

insufficient identification and verification of the identity of the customer, his

representative(s) and/or beneficial owner(s);

  • The customer’s or beneficial owner’s source of wealth or source of funds

cannot be explained ( for example through their occupation, inheritance or


  • There is no sound economic or lawful rationale for the customer requesting the

type of financial service sought;

  • The customer, its representative and/or beneficial owner is a person or

institution appearing on an embargo or terrorist list issued by EU, OFAC or

local authorities;

  • The customer or beneficial owner or anyone associated with them have

handled the proceeds from crime;

  • There is in-house negative information about the customer’s or the beneficial

owner’s integrity, obtained, for example, in the course of a long-standing

business relationship;

  • The customer, its representative and/or beneficial owner is a person with

whom a VSI Limited entity discontinued the business relationship in the past

for AML/TF reasons;


6.2.3. Ongoing Customer Due Diligence

Periodic and risk-based reviews are carried out to ensure that customer-related

documents, data or information are kept up-to-date.


6.3. Monitoring of Transactions (Know your Transactions (KYT))

Local Compliance functions ensure that ongoing transaction monitoring is conducted to detect transactions which are unusual or suspicious compared to the customer’s risk profile (expected versus real transactional behaviour). This transaction monitoring is conducted on two levels :

1) each business line (first line of control) monitors all customers and their financial

behaviour and applies an enhanced due diligence on those customers who are

considered as a higher ML/TF risk;

2) the first line of control is supplemented by a risk-based second line of control, including an increased monitoring of transactions of customers regarded as a higher ML/TF risk.

A company wide transaction monitoring founded on a risk based approach has been defined to be followed by all entities using – as much as possible – the same transaction monitoring tool. In a number of circumstances described in the company wide KYC-rule, measures need to be taken to block the accounts or to terminate the business relationship.


6.4. Record keeping

Records of personal data obtained for the purposes of the prevention of money laundering and terrorist financing are processed and kept in accordance with the requirements from the EU General Data Protection Regulation (GDPR) and shall not be further processed in a way

that is incompatible with those purposes.





7.1. Suspicious Transactions Reporting (STR)

An AML Compliance Officer (AMLCO) is appointed to ensure that unusual transactions that have been detected are reported to the appropriate FIU. The reporting of suspicious transactions must comply with the laws and regulations of the respective local jurisdiction.



7.2. Procedures

All company’s entities have implemented AML/CTF rules, including minimum KYC standards, into operational procedures taking into account their type of activities, their volume and their size together with the local legal and regulatory requirements.


7.3. Training

All group entities develop a coherent training program, including follow-up trainings on a regular basis (in-class trainings, E-learnings, webinars,…), in order to create and maintain a

satisfying AML/CTF awareness. The content of this training program has to be worked out in accordance with the kind of business the trainees are working for and the kind of functions they hold.


7.4. Compliance Monitoring Program

In order to assure the effectiveness of instructions, procedures and processes, recurrent quality controls are performed in the AML/CTF-domain pursuant to a Compliance Monitoring Program. Reviews and quality controls can be executed by the company at its own initiative.


7.5. Reporting

AML/CTF issues and activity reports are submitted on a regular basis to the local Audit, Risk and Compliance Committees and to Company Compliance who reports to the company Risk and Compliance Committee (at the consolidated level). On a yearly basis local Executive Committees or equivalent assess the quality of coverage of the internal control in this respect.


7.6. Corporate Audit

Compliance with the policy, the minimum KYC standards and the procedures encompassing local rules as the case may be falls within the scope of Corporate Audit who verifies if they are correctly implemented and obeyed.