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KYC/AML/CTF Policy

KYC (Know-Your-Customer) is the practice of collecting data about your customer to help with identifying and verifying their identity.

Businesses need KYC as it helps to understand and know your customers better. Below are some of the advantages and importance of KYC:

  • To establish the identity of the customer
  • To understand the nature of the customer’s activities
  • To assess money laundering risks associated with that customer for purposes of monitoring the customer’s activities

At Cogent only merchant require to provide adequate KYC information for onboarding. Our system makes it easy for merchants to comply with this requirement, while uploading the documents of the Backoffice.

KYC REQUIREMENTS FOR MERCHANTS.

As part of the business verification, each merchant required to provide adequate information. These documents include means of identity, utility bill, and business incorporation certificate.

Also, KYC ensures that Cogent can meet the anti-money laundering and other global financial best practices. It is important to know that all information shared with Cogent as part of KYC requirements is always kept confidential according to our privacy policy and being used for compliance purposes only and is protected under GDPR guidelines.

ANTI-MONEY LAUNDERING POLICY

As a worldwide financial institution, Cogent is fully committed to conducting due diligence on our clients and ensuring that all applicable laws and regulations necessary to forestall and prevent money laundering. These include confirming the identity of our merchants by means of:

  • Government-issued photo ID
  • Proof of residential or business address
  • Corporate documentation
  • Business registration information
  • Any other applicable documentation

Furthermore, we reserve the right to conduct enhanced due diligence on all clients given world-wide approved risk-based policies and as mandated by Sections 3 (6) and (7) of the Anti Money Laundering Act 2011. Cogent also reserves the right to refuse a transaction or deny operation on a client or account at any time should suspicion arise that it may be connected to money laundering, criminal activity or any other predicate offense to money laundering. Cogent will not enter into any business arrangement with anyone or group suspected of or directly involved in money laundering, or where funds have been sources or ends of an illegal activity.

In the event that Cogent receives, during its request for documentation, deceptive documentation, contact details, business description or other false information, Cogent will terminate the offending account. Cogent is legally bound to report such misdemeanours to the relevant authorities such as the Economic & Financial Crimes Commission (EFCC) and the Special Fraud Unit (SFU), and as such the subject, business and its owners may be the subject of a criminal investigation.

Also, in the event that Cogent observes, in respect to any account, the occurrence of certain triggers or red-flags (Indicators) which are indicative of perpetuation of fraud, fraudulent or money laundering activities, Cogent will place a lien on such an account and the funds therein contained. Cogent is legally bound under Section 6 of the Anti-Money Laundering Act 2011, to report same to the Economic & Financial Crimes Commission (EFCC) and the Financial Intelligence Unit (FIU).

*Indicators are observable events that point to the possibility of specific activities occurring*

Cogent reserves the right to:

  • Withhold suspected fraudulent or money laundering funds in suspected accounts
  • Order for full-scale forensic investigations in respect of said accounts
  • Upon confirmation of the status of the account, deduct the costs of Cogent’s investigations and incidental expenses from the withheld funds in the account.

Cogent COUNTER-TERRORISM FINANCING STATEMENT (CTF)

As part of the information that is collected during our verification and AML procedures, Cogent conducts verification through world-wide databases. At the forefront, they will include compliance with EFCC (Economic & Financial Crimes Commission) requirements, as contained in the Economic and Financial Crimes Commission Act 2004, global sanctions reports and government watch lists and screening processes. At any time, due to a requirement to satisfy any of the above verification methods, a client, business entity or any of the business entity owners or affiliates may be asked a specific document or piece of information to confirm their identity or provide additional information regarding any transaction, operations or even business dealings with certain individuals, institutions and dealings in geographical locations.

Should a situation arise where the nature of the business, geographical specific regulations or account activity fall in the scope of non-compliance in any applicable law or regulation, Cogent will inform the client, business unit or any of the business owners or affiliates of the event and occurrence. For such instances, pre-verification and enhanced due diligence will be required prior to regaining active account status. In cases, where compliance is not achieved pursuing remediation measures, Cogent will see fit to terminate the account and will report the event and surroundings to the applicable law enforcement and regulatory authorities.