Introduction
Interswitch Group (“Interswitch”) is a leading e-payment services provider that is committed to providing secure electronic payment solutions and maintaining the integrity and trust associated with its brand.
Interswitch, as part of its efforts in ensuring compliance with relevant regulations has established and implemented policies and procedural guidelines which are frequently reviewed/revised to guarantee that they are in line with the dynamic regulatory environment of the financial sector.
Interswitch’s policies are developed to ensure compliance with legislations, regulatory provisions, and industry standards, while also incorporating extant global best practices
These policies and procedures showcase Interswitch’s contribution to the global fight against financial crimes and it guides the company’s interactions with stakeholders.
This document applies to all Interswitch businesses, subsidiaries, affiliates, joint ventures, intermediaries, agents, and employees, ensuring compliance with AML, CFT, and CPF controls.
Know Your Customer (KYC) Procedures:
Interswitch’s KYC policy ensures that only customers that aligns with its risk appetite are on-boarded, while ensuring that all account opening forms, identification documents and other relevant information and documents are provided.
Customer Due Diligence (CDD) is conducted prior to entering any relationship between Interswitch and a customer. The extent of due diligence applied to each customer category is dependent on the risk level of the third party. Customers that are identified as high risk are subjected to Enhanced Due Diligence (EDD).
Sanction Compliance Management
As a policy, Interswitch does not enter any relationship with sanctioned individuals/entities and shell entities. Interswitch maintains and has access to robust watchlist that contain amongst others, the names of individuals and entities, who have been blacklisted by various supervisory bodies worldwide.
Sanction screening is conducted at the point of onboarding, during routine periodic reviews, and throughout the life cycle of the business relationship.
Politically Exposed Persons (PEPs)
PEPs are individuals who are or have been entrusted with prominent public functions and the classification includes people or entities associated with them. Enhanced due diligence measures are applied to PEPs, as with other high-risk customers to mitigate the risks associated with doing business with them.
This is achieved through the thorough review of information provided by customers and their transaction trends.
Prohibited Relationships
Interswitch does not do business with shell companies, sanctioned individuals or entities, Individuals and organizations previously convicted of ML/TF/PF offences or entities and individuals that exceed the maximum risk tolerance level permitted by Interswitch.
Anti- Bribery & Corruption
Interswitch upholds the highest standards of ethical conduct in all its activities and interactions. With its zero tolerance for any form of bribery, corruption, fraud, and unethical practices among employees, as well as between Interswitch and external parties; Interswitch mandates that the same ethical standards be applied by third parties acting on its behalf.
Record Retention
In accordance with regulations, customer identification documents are retained throughout the life of the account and for five (5) years after the cessation of the banking relationship. Transaction instruments are retained for five (5) years after the transaction date. In litigation and/or regulatory investigations, the records will be kept for as long as they are required.
Whistleblowing
Interswitch has a whistleblowing policy which is approved by the Board. This policy governs the reporting and investigation of improper or illegal activities at Interswitch as well as the protection offered to the Whistle blowers.
All disclosures are treated with strict confidence, and the identity of the Whistle blower will not be revealed except as required for Security, Regulatory or Legal purposes.
Monitoring and Review
Identifying suspicious activity/suspicious transaction redflags is a prerequisite for transaction monitoring and review. This is the responsibility of all stakeholders with protection from victimization and retaliation. However, all employees must avoid tipping off to the effect that a suspicious transaction report has been filed.
Interswitch renders reports to the NFIU and the CBN in accordance with the provisions
of Sections 2, 3 and 7 of the Money Laundering (Prevention and Prohibition), Act 2022
(“the Act”).
Regulatory Intelligence Collaborations
Interswitch remains committed to providing timely and accurate responses to regulatory investigations and information requests, while maintaining confidentiality and preventing tipping off. This is achieved through close collaboration with intelligence agencies, regulators, and law enforcement, supporting national efforts to combat financial crimes, including money laundering and terrorism financing.
Willfull Blindness, Confidentiality, and Tipping Off
Tipping off is prohibited, and strict confidentiality is ensured and maintained during all investigations within the organization. Willfull blindness to AML/CFT/PF issues is to be sanctioned in line with the organization’s sanctions regime.
New Technologies, Products, and Applications
New technologies and products are also assessed for AML, CFT, and CPF risks before implementation. Relevant approval is required for these new technologies, products, and applications.
Termination and Suspension
Interswitch may terminate or suspend the relationship or transaction with a customer, where there is a breach of the terms of agreement that guides the relationship, any applicable law or non-adherence to the content of this document.
