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Bafut Cooperative

ATI-MONEY LAUNDERING POLICY

2017

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1. Overview

I.1 Introduction and Definition


Money laundering is the process of concealing the existence, illegal source, or
application of income derived from criminal activity, and the subsequent
disguising of the source of that income to make it appear legitimate. It takes two
forms:
a) Engaging, directly or indirectly in a transaction that involves property that is the
proceeds of crime, knowing or having reasonable grounds for believing the same
to be proceeds of crime.
b) Receiving, possessing, managing, investing, concealing, disguising, disposing of
or brining into Bafut Cooperative Credit Union LTD any property that is the
proceeds of crime, knowing or having reasonable grounds for believing the same
to be the proceeds of crime.
Bafut Cooperative Credit Union LTD. will evaluate all financial transactions and
take all necessary steps to comply with anti-money laundering laws and
regulations.
The reality is that microfinance institutions are also being used for money
laundering and terrorism. Movement of large amount of money in the formal
financial institutions for the purpose of laundering can be monitored. But
transfer of money in small amounts and through charitable institutions and
microfinance institutions is possible and will be hard to monitor. It is in this
context that this anti-money laundering policy focuses on the two main parties.
The first is the origin where the money is coming from. This implies that the
owner of the fund must be determined. The ultimate beneficial owner (UBO)
must also be identified. To be able to do this, Bafut Cooperative Credit Union LTD
has established strong know-your-customer (KYC) policy. The second party is the
destination. Who is the final receiver and user of the money? Is the money being
deposited to the institution only for a short time, to be withdrawn immediately?
Or is the money invested to be used only for a certain group without
expectations of being repaid? Answers to these questions will reveal the
intention of the destination. Bafut Cooperative Credit Union LTD staff should be
familiar about money laundering and terrorism financing so that they can
prevent the institution from being used by people with such intentions. The

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policy is not only as compliance to regulatory requirements but also a part of the
Bafut Cooperative Credit Unions risk management scheme.

I.2 Anti- Money Laundering (AML)

Anti-Money Laundering (AML) as used in this circumstance describes the legal


controls that require Bafut Cooperative Credit Union LTD to prevent, detect
and report money laundering activities. Under the International Money
Laundering Abatement and Anti-Terrorist Financing Act of which Cameroon is
a signatory, money laundering is explained as the act of converting money or
other material values gained from illegal activities such as terrorism, drug
dealing, illegal arms trade, corruption, human traffic and etc. into money or
investments that appear to be legitimate. Bafut Cooperative Credit Union
vows to comply with the above regulation with full attention and no
compromise with any of the above illegal activities. For this purpose, Bafut
Cooperative Credit Union LTD hereby sets out its Anti Money Laundering
Policy.

I.3 Scope of Policy

This policy applies to Bafut Cooperative Credit Union members, Board


members and employees, third parties offering products and services to Bafut
Cooperative Credit Union LTD.

Board member, management, committees and branches within Bafut


Cooperative Credit Union will cooperate to create a cohesive effort in the fight
against money laundering. Each business unit and branch offices shall
implement risk-based procedures reasonably expected to prevent, detect and
cause the reporting of transactions required under the laws in force.

All efforts exerted will be documented and retained in accordance with the
provisions of the laws in force. Branch managers and unit heads are responsible
for initiating Suspicious Activity Reports or other required reporting to the
appropriate hierarchy as the case may be and or the Internal Auditor for further

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investigation and onward transmission of report to the Board of Directors and
Supervisory Board. This may then be handed over to the appropriate law
enforcement or regulatory bodies after concerting with the legal counsel.

I.2 Our Commitment


It is the principle of Bafut Cooperative Credit Union LTD to prohibit and actively
pursue the prevention of money laundering and any activity that facilitates
money laundering or the funding of terrorists. The Union is committed to
compliance to the applicable laws. It is expected that our members, Board
members, employees, third parties offering products and services to Bafut
Cooperative Credit Union shall adhere to these standards in preventing the use of
our products and services for money laundering purposes.

II. Identification of money laundering Stages


Generally, money laundering occurs in three stages until the unlawful proceeds
appear to have been derived from legitimate origins or constitute legitimate
assets.
II.1 Placement stage: Cash first enters the financial system at the "placement"
stage, where the cash generated from criminal activities is converted into
monetary instruments, such as Salary, payments, arrears of due benefits from
state coffers, money orders or traveler's checks, or deposited into accounts at
financial institutions from government treasury.
II.2 Layering stage: At the "layering" stage, the funds are transferred or moved
into other accounts or other financial institutions or cashed by unknown or
circumstantial member to be shared or to further separate the money from its
criminal origin.
II.3 Integration stage: At the "integration" stage, the funds are reintroduced into
another existing account in the Union or withdrawn to be used to purchase
legitimate assets or to fund other criminal activities or legitimate businesses.

III Client Identification Procedures


III.1 Procedures: Before opening an account for an individual client, Bafut
Cooperative Credit Union LTD. will require satisfactory documentary evidence of a
clients name, address, date of birth, and either but not limited to the following
forms of identification:
- ID and number

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- Passport

For a corporation or other legal entities Bafut Cooperative Credit Union


LTD. will require satisfactory legal evidence of the entitys name, address and
that the beneficiary and operators have been duly authorized to open the
account. The staff will retain records of all documentation that have been relied
upon for client/corporation identification.

III.2 Prohibited Clients


Bafut Cooperative Credit Union LTD. will not open accounts or accept funds or
from, or on behalf of, any person or entity nor accept high-risk clients (with
respect to money laundering or terrorist financing) without conducting enhanced,
well-documented due diligence regarding such prospective client. Concerns
regarding transactions that are unusually large or that appear suspicious,
questions regarding money laundering in general and any violation of this policy
should be reported.
The followings are some operative examples of the sufficient evidence of their
identity and our action plans we shall take:

a) Prior to open of any new account, we shall document the identity,


residential detail, nature of business and investment purpose by collecting
copies of valid passport or National Identity card or other government issued
documents, and utility bill as address proof;

b) We shall not accept cash deposit and pay out cash without proper
identification of the persons involved in the transaction

c) We shall not accept funds if the name of the originating clients does not
match the name of the client in our system;

d) In case of withdrawal, money only can be withdrawn from the same account
and the same method which it was received and where the name of the
recipient is present, the name must strictly match the name of the client in our
system;

e) Third party withdrawal is strictly prohibited; and

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III.3 Suspicious Transaction Report (STR)

Where an employee of Bafut Cooperative Credit Union knows or suspects or


has reasonable grounds for knowing or suspecting that a customer is engaged
in or about to engage in money laundering or criminal activity, we reserve the
right to refuse to process a transfer at any stage, then that employee must
make a Suspicious Transaction Report to the immediate hierarchy and or the
internal Auditor in the prescribed format. Although it is hard to give definitive
examples of suspicious transactions, the following transactions may be
suspicious:

a) Cash transfer that has no clear origin;

b) Funds that are paid to Bafut Cooperative Credit Union from an account and
where settlement instructions are to pay to another account; and

c) The settlement instructions are changed at the last minute.

d) Funds transferred to Bafut Cooperative Credit Union with receivers name


not on the original transfer document.

e) The instant fabrication of identification documents to serve for withdrawal


purposes.

f) Accounts created for the sole aim of withdrawing transferred funds.

IV Failure to Provide Information

Bafut Cooperative Credit Union staff has the right to decline the account opening
application and report to our Money Laundering Reporting Officer in the following
circumstances:

a) If the Client fails to provide the Union with any documents requested either
for client identification purpose or for any other reason;

2) If the Unions staff suspects or has concern that the submitted documents
may be false or fake; and

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3) If Unions staff suspects that the Client is involved in illegal or fraudulent
activities.

V. Monitoring
Bafut Cooperative Credit Union staff shall monitor customer transactions and
identify and report suspicious activities to regulatory agencies through our Money
Laundering Reporting Officer (Internal Auditor and management staff)

VI. PROCEDURES IN CASES OF DOUBT


In cases of doubt, when opening accounts or deposits, Bafut Cooperative Credit
Union staff shall require a written declaration from the customer as to whether
he is acting for his own account or for the account of a third party and in the
latter case, for whose account.
Doubt is justified but not limited to the following cases:
The opening of an account or deposit is requested, and, at the same time, a
power of attorney is going to a person not recognizable as being closely
enough related to the account holder (e.g., to a non-member), or if any
other unusual aspects arise;
The opening of an account or a deposit is requested by a person whose
financial situation is known to Bafut Cooperative Credit Union. The assets
handed over or to be remitted are beyond the limits of the customers
recognized financial ability;
The opening of an account or a deposit is requested by a person domiciled
abroad, who has been introduced to Bafut Cooperative Credit Union. At the
same time, a power of attorney is given to a person who is recognized as
not being in a sufficiently close relationship to the account holder
The opening of an account or a deposit is requested by a person domiciled
abroad, who has been introduced to Bafut Cooperative Credit Union and
whose financial situation is known to the Bank. The assets, handed over to
be remitted are beyond his final situation;
The opening of an account or a deposit is requested by a person domiciled
abroad who has not been recommended to the Bank. The discussion the
Bank must have with the customer at the time of opening the account or
deposit brings to light unusual aspects;

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The opening of an account or a deposit is requested by a person domiciled
abroad by way of correspondence, accompanied by an attestation of the
signature but the potential customer is not personally known to Bafut
Cooperative Credit Union.

Where serious doubt remains as to the accuracy of the customers written


declaration, which cannot be eliminated by further clarification, Bafut
Cooperative Credit Union staff must decline the request for the opening of the
account or deposit.

VI. Training and awareness

All employees of Bafut Cooperative Credit Union LTD shall regularly receive
trainings and updates on the Union's anti-money laundering procedures and
obligations as and when required. The Money Laundering Reporting Officer
(MLRO) will attend external courses from time to time to ensure that his/her
training and awareness are current.

VII. Annual Report by MLRO

Each year, the MLRO (Internal Auditor) reports to the Board of Directors on the
level of compliance with the money laundering requirements. This report is
produced by the MLRO (Internal Auditor) and Compliance Officer and is
considered by the Directors, who are responsible for any necessary action to
remedy deficiencies identified by the report.

VIII. Record Keeping

Under the Anti-Money Laundering Rules, (Internal Auditor) must retain records
concerning client identification and transactions for use as evidence in any
investigation into money laundering and criminal activity. Client identification
records must be kept for at least 5 years after the relationship with the client has
ended. Transaction records must be kept for at least 5 years from the date of the
relevant transaction.

IX. Our Compliance Framework


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Bafut Cooperative Credit Union shall implement a compliance framework in
respect to relevant laws, including appointment of a Compliance Officer, Money
Laundering Reporting Officer, preparations of policies and procedures, periodic
review of their effectiveness, and providing training to all Bafut Cooperative
Credit Union employees on enhancement of anti-money laundering procedures.

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