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AML and CDD Policy

AfriMillions Anti-Money Laundering (AML) and Customer Due Diligence (CDD) Policy

1. Purpose and Scope

This policy establishes the Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT), and Counter-Proliferation Financing (CPF) framework for AfriMillions Ltd in compliance with the Money Laundering (Prevention and Prohibition) Act 2022, the EFCC/SCUML AML-CFT-CPF Regulations 2024, and directives of the National Lottery Regulatory Commission (NLRC), Lagos State Lotteries and Gaming Authority, the Central Bank of Nigeria (CBN), and the Special Control Unit Against Money Laundering (SCUML).

It applies to all directors, employees, agents, distributors, contractors, and any third parties acting for or on behalf of AfriMillions.

2. Risk Assessment

AfriMillions recognises that lottery and gaming activities present specific ML/TF risks, including:

  • Large or sudden cash payouts
  • Anonymous or third-party ticket purchases
  • Structuring of transactions to avoid detection
  • Agent collusion or aggregation of small bets

The company maintains a documented Enterprise-Wide Risk Assessment (EWRA) reviewed annually or upon any material business change. Risks are assessed across customers, products, delivery channels, agents, and geographies. Each customer or transaction is assigned a low / medium / high risk rating that drives due-diligence depth and monitoring frequency.

3. Customer Due Diligence (CDD)

Standard CDD

Required for:

  • Winnings above ₦5 million

Requires the following:

  • Verify full legal name, date of birth, and identity via valid government-issued ID (NIN, BVN, Passport, Driver’s Licence, or Voter’s Card).
  • Obtain proof of address (utility bill, bank statement, tenancy agreement).
  • Complete KYC forms and store documentation securely.

Enhanced Due Diligence (EDD)

Required for:

  • Winnings ≥ ₦20 million or high-risk customers
  • Politically Exposed Persons (PEPs) or close associates
  • Transactions involving high-risk jurisdictions
  • Third-party prize collectors or agents
  • Frequent high-value players

Requires the following:

  • Verifying source of wealth
  • Senior-management approval before payout
  • Continuous monitoring of the relationship.

Simplified Due Diligence (SDD)

For low-risk or low-value winnings (below ₦5 million), simplified checks may apply, subject to documented risk assessment.

Beneficial Ownership and Corporate Entities

For non-individual claimants, identify and verify beneficial owners (≥ 25 % ownership or control).

Ongoing Monitoring

KYC data must be refreshed at least every 3 years (low risk), 2 years (medium risk), and 1 year (high risk). All transactions are subject to continuous screening and pattern analysis.

4. Transaction Monitoring and Reporting

Suspicious Transaction Reports (STRs)

  • All staff must immediately escalate any unusual or suspicious activity to the Money Laundering Reporting Officer (MLRO).
  • The MLRO must submit STRs to the Nigerian Financial Intelligence Unit (NFIU) via the goAML platform within 24 hours of determination.
  • No minimum threshold applies to STRs.
  • Red-flags include: structuring, use of nominees, reluctance to provide KYC, unusual agent activity, or transactions inconsistent with profile.
  • All STR records and supporting documentation must be retained for 5 years.

Cash Transaction Reports (CTRs)

  • All cash transactions above ₦5 million for individuals or ₦10 million for corporates must be reported to SCUML within 7 days.
  • All cash-based transactions above USD 1,000 (or equivalent) must be reported as CBTR within 7 days.
  • Any structuring or splitting to avoid these thresholds is prohibited and must be reported as suspicious.
  • All large prize payments should be made via traceable non-cash methods (e.g. bank transfer).

Record Keeping

  • Maintain all transaction records and CDD files for at least five years after the last transaction or termination of relationship.
  • Records must be readily retrievable for inspection by NLRC, Lagos State Authority, SCUML, NFIU, or law enforcement.
  • Digital records shall be securely stored with audit trails and restricted access.

5. Organizational Structure

Money Laundering Reporting Officer (MLRO)

  • Senior management appointee with authority and independence to report directly to the Board.
  • Responsible for AML/CFT/CPF compliance, oversight of CDD, record-keeping, reporting to regulators, and liaison with law enforcement.

Compliance Unit

  • Conducts transaction monitoring and investigations.
  • Maintains risk registers, STR/CTR logs, and training records.
  • Reports quarterly to the Board and SCUML on compliance status.

6. Training and Awareness

  • All staff must complete AML/CFT training within 30 days of employment and annually thereafter.
  • Training covers laws, typologies, red flags, reporting processes, and tipping-off prohibitions.
  • The training programme shall be reviewed annually and submitted to SCUML by 31 March each year.
  • Attendance and competence shall be recorded and subject to audit.

7. Agent and Distributor Management

  • Conduct full due diligence on all agents and distributors, including identity, ownership, business history, and financial integrity.
  • Agent agreements must include mandatory AML clauses, audit rights, and termination for non-compliance.
  • Monitor agent sales and cash flows for anomalies and report suspicious behaviour to the MLRO.
  • Conduct annual compliance audits of agent operations.

8. Tipping Off Prohibition

  • Employees must not inform any person that an STR or CBTR has been filed or that an investigation is in progress.
  • Disclosure is permitted only to the MLRO, legal counsel, law enforcement, or regulators.
  • Retaliation against whistle-blowers or staff who raise concerns is strictly prohibited.

9. Sanctions and PEP Screening

  • Screen all customers, agents, vendors, and claimants against UN, OFAC, EU, UK, and Nigerian sanctions lists and PEP databases at onboarding and periodically thereafter.
  • Enhanced review and senior management approval required for PEPs and high-risk matches.
  • Screening tools must be updated daily to reflect current lists.

10. Independent Audit

An independent audit of AML/CFT/CPF controls shall be conducted annually, either by internal audit or external qualified auditors. Findings and remediation plans shall be reported to the Board and SCUML.

11. Policy Review

  • The Board of Directors must approve this policy and any subsequent amendments.
  • Review to occur at least annually or whenever laws, business operations, or risk profiles change materially.
  • Updated versions shall be communicated to all staff and agents immediately upon approval.

12. Penalties for Non-Compliance

Non-compliance with this policy may result in disciplinary action up to and including dismissal.

Breaches may also expose the company and individuals to criminal prosecution under Nigerian law, including fines up to ₦10 million for individuals and ₦25 million for corporates, imprisonment, and revocation of the company’s Lagos State lottery licence.

Last updated: 19 November 2025