Financial Crime
Combating Financial Crime
Nexus International is committed to combating financial crime by implementing measures to detect and prevent money laundering, terrorist financing, and other illegal activities. Our policy ensures the company is not used for illicit purposes. Staff are trained to understand and apply these measures effectively, with success relying on collective vigilance in daily operations.
To ensure these policies are effectively implemented, Nexus International and its entire staff must be:
- Educated about the legal and regulatory frameworks, as well as the severe legal and regulatory consequences of inadvertently aiding financial crime, in every jurisdiction where we operate.
- Vigilant regarding the practical methods criminals use to commit financial crimes.
- Prompt in reporting any suspicious activities to Nexus International management.
LEGAL AND REGULATORY FRAMEWORK
The Union of the Comoros is a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), which combats money laundering by applying Financial Action Task Force (FATF) guidelines. ESAAMLG collaborates with international organizations, analyzes regional trends, enhances institutional capacity, and coordinates technical assistance while integrating regional considerations into enforcement. Members conduct self-assessments to measure compliance with FATF’s Forty Recommendations.
Comoros is also an observer member of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), which supports AML/CFT efforts under ECOWAS. GIABA functions as a FATF-Styled Regional Body (FSRB), aiding in AML/CFT adoption and ensuring compliance with global standards across West Africa.
THE IMPORTANCE OF KNOW YOUR CUSTOMER (“KYC”)
Nexus International follows a strict client approval process, providing services like guarantee issuance only to verified legal entities. While clients often engage through intermediaries, Nexus independently verifies their identity and legitimacy.
Given the high money laundering risks in regions like Africa and India, we enforce strict documentation standards per our Compliance Agreement. Clients undergo thorough screening against international sanctions lists before any non-refundable processing fees are accepted.
Before processing guarantees or credit facilities, we require verifiable proof of genuine commercial activity. This ensures compliance and prevents service misuse, reinforcing our commitment to ethical financial practices.
WHAT IS MONEY LAUNDERING?
Money laundering is a complex process where individuals involved in illegal activities attempt to conceal the origins of unlawfully obtained funds, often referred to as “dirty” money. Although the methods used for money laundering can vary, they generally involve three main stages:
- Placement : This initial phase involves placing the illicit funds into the legitimate financial system. This could include depositing the money into bank accounts or making investments to integrate it into legal economic activities.
- Layering : During this stage, the money undergoes a series of intricate financial transactions aimed at separating it from its illegal origins. These transactions create a complicated trail, making it difficult to trace the money back to its criminal source.
- Integration: The final step involves reintroducing the laundered funds into circulation through seemingly legitimate channels. At this point, the money appears “clean” or “laundered,” making it indistinguishable from funds acquired through legal means.
Nexus International remains steadfast in its commitment to combatting money laundering within the finance and technology sectors.
PRACTICAL GUIDANCE TO DETER FINANCIAL CRIME
It’s a well-known truth that individuals engaged in illegal activities, such as money laundering, do not overtly present themselves as such. While broad generalizations may not always be helpful, certain red flags indicating a suspicious transaction or illicit activity include:
- Lack of obvious commercial rationale.
- Use of ‘front men’ or ‘front companies’ not appearing in the corporate structure.
- Insufficient documentary support for a person or transaction.
- Excessive concern about secrecy, especially regarding the source of funds.
REPORTING SUSPICIOUS
At Nexus International, reporting suspicions is a critical part of our anti-money laundering efforts. Our Money Laundering Reporting Office (MLRO), integrated into senior management, meticulously oversees our anti-money laundering policies. They report directly to Nexus International’s Board, ensuring a top-down approach to combating financial crime. It is mandatory for all staff members to promptly report any suspicions of illicit transactions to ESAAMLG through the MLRO.
RECORD KEEPING
At Nexus International, meticulous record keeping is paramount to our operations. We maintain thorough records of our client verification processes, ensuring transparency and compliance. All original documentation, whether in paper or electronic format, is retained throughout a client’s approval period and for an additional six years thereafter.
TRAINING FOR STAFF
At Nexus International, we take responsibility for ensuring our staff are well-equipped to combat money laundering and uphold compliance standards. This includes:
- Providing comprehensive training on understanding money laundering and our role in preventing it.
- Emphasizing the importance of monitoring approved clients and overseeing applicant processes to detect any irregularities.
- Equipping staff with the knowledge and skills to identify and report suspicious transactions promptly.
We conduct periodic refresher training sessions to reinforce these concepts among our team members. Additionally, our Money Laundering Reporting Office (MLRO) and senior management are available to address any questions or concerns related to this topic.