NITTYGRITTY AML POLICY

1.1 Nitty Gritty Solutions have a robust AML policy put in place to serve as a guideline and to mitigate possible risk to the business.

We put in place appropriate policies and procedures that reflect the degree of risk associated with the business and its customers. These are:

• customer due diligence measures and ongoing monitoring
• reporting suspicious activity
• record keeping
• internal controls
• risk assessment and management
• monitoring and managing compliance
• Communication of these policies and procedures to customers as appropriate
• staff training

1.2 We are aware of the vulnerability of Nittygritty service to the risk of money laundering, terrorist activities and PEPs. We will take into account situations that, by their nature, can present a higher risk of money laundering or terrorist financing, and take enhanced measures to address them. The specific measures depend on the type of customer, business relationship, product or transaction, especially large or complex transactions or unusual patterns of activity that have no apparent economic or lawful purpose.

We will take the following actions went required and kept them under regular review:

• carry out a formal, regular assessment of money laundering/terrorist financing risks, including market changes, and changes in products, customers and the wider environment
• ensure internal procedures, systems and controls, including staff awareness, adequately reflect the risk assessment
• ensure customer identification and acceptance procedures reflect the risk characteristics of customers
• take further measures for higher risk situations, eg carry out an Enhanced Due diligence on customers where necessary
• ensure arrangements for monitoring systems and controls are robust, and reflect the risk characteristics of customers and the business
• carry out regular assessments of our systems and internal controls to make sure they are working Where we spot any weakness, we will document it and record the action taken to put the problem right.

1.3 The adoption of a risk-based approach will balance the costs to our business and customers with a realistic assessment of the risk that criminals may exploit the business for money laundering and terrorist financing. It allows us to focus our efforts on the most important areas and reduce unnecessary burdens.

1.4 Nitty Gritty Solutions business risk profile
At Nitty Gritty Solutions LTd we understand our responsibilities with regards to money laundering and terrorism financing. That is why we have invested heavily in our system to prevent criminals from using us to launder their proceeds of crime through our business channel. Some of the risks our business face are as follow.

• Customers using fake ID to support their transaction.
• Customers producing fake pay in slips to support their sources of funds to support their transactions.
• Customers using other people documentation to support their transaction
• Customers set up different user accounts in our electronic transfer/App system to avoid the threshold of the system prompting them to upload their support documents.
• Other money service business using us as a front for laundering their collection of small customers transfers in to a single large transaction that may lack the minimum supporting documentation to support those transactions.
• Failure of our system not to capture customers data accurately especially during system down time.

Mitigation of the above risk identify
4.6. These are some of the measures we have taken to mitigate the above risk.

• We have invested heavily in money remittance software for automatic identification of fraudulent activities
• Customers supporting documents can be check automatically by the system when upload into it.
• All transaction done must be approved by the one of the senior managers of Nitty Gritty Solutions LTD whether done manually or through the online software system.
• Supporting documents of the customers will be kept electronically for all online customers.
• Any agent in any Nitty Gritty Solutions Financial Service LTD must have to pass the fit and proper test for operating a money service.
• Ensure that we are up to date with the Financial Action Task Force (FATF) list of countries having deficient system of preventing money laundering and terrorism financing.

Monitor the effectiveness and implementation
4.7. We at Nitty Gritty Solutions Ltd are committed to continuous improvement and best practice therefore will continue to monitor the effectiveness of the controls put in place to minimize our exposure to the money laundering risk. We will continue to implement changes as the business environment changes as well as committed to the philosophy of continuous improvement.

Further on, in the identification and assessment of Nittygritty AML risk at conducting its business mainly over the internet and currently focused on the one-way transfer of funds from the UK to Nigeria. In the process the directors have further identified the following AML risks listed in the table below:

1. Fraud risk includes the following: Use of stolen credit and/or debit cards As transactions are conducted over the internet through card payments, there is the risk that a customer may want to transfer funds to Nigeria through fraudulently obtained credit or debit card.
2. Impersonation which could be the use of false identity documents. Some customers might attempt to use false identity documents e.g. passport to access the Nittygritty service
3. Facilitating the transfer of proceeds of crime from UK to Nigeria and vice versa. These risks arise from the fact that Nittygritty services enables UK customers to transfer funds (GBP) from the UK to Nigeria whilst enabling the transfer of Naira out of Nigeria. There is the risk that criminals could use our services, in the absence of checks and vigilance, to facilitate the transfer of proceeds of crime out of the UK and /or Nigeria.
4. Inadequate due diligence carried out on customers may result in the non-identification of Politically Exposed Persons and/or individuals on sanctions list. Due to the online nature of Nittygritty business, there is the risk that inadequate due diligence will be undertaken on its customers in the UK. Unlike traditional face-to-face business, where customers are physically present and originals of ID documents can be obtained, the online nature of our business does not enable us to undertake customer due diligence in the same way.
5. Dealing with non-authorised counterparties in Nigeria: Nittygritty meets its obligations delivering the local funds to its customers by obtaining Naira from counterparties based in Nigeria.
6. The sale and transfer of Naira and foreign currencies are controlled by the Central Bank of Nigeria. However, Nittygritty may not be conversant with Nigeria’s foreign exchange regulation(s) and as a result, could end up sourcing Naira from an unauthorised source, thus inadvertently facilitating money laundering.