Our commitment
Claybarn Fronteira Limited (“Claybarn”, “we”, “us” or “our”) is a Nigerian company licensed to carry on money-lending business in the Federal Capital Territory (“FCT”). We are committed to conducting our lending activities responsibly and to maintaining controls designed to prevent our services from being used for money laundering, terrorism financing, proliferation financing or other financial crime.
This public policy summarises our approach to Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing (“AML/CFT/CPF”). It should be read as a public statement of our compliance approach rather than a description of confidential internal detection, investigation or reporting procedures.
Legal and regulatory framework
Our AML/CFT/CPF framework is designed to reflect the laws and requirements applicable to our business, including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, applicable targeted financial sanctions requirements, and other applicable Nigerian laws, regulations, directives and guidance.
Claybarn also complies with the requirements attached to its FCT money-lender licence and with lawful requirements of competent authorities applicable to its activities.
As a money lender falling within the non-financial institution category, Claybarn maintains AML/CFT/CPF controls applicable to its business and complies with applicable registration, supervision, reporting and cooperation requirements. This includes applicable requirements of the Special Control Unit against Money Laundering (“SCUML”), the Nigerian Financial Intelligence Unit (“NFIU”) and other competent authorities.
Claybarn maintains its applicable SCUML registration and compliance arrangements and supports lawful AML/CFT/CPF supervision, inspections, information requests and statutory reporting. Detailed reporting thresholds, escalation routes and submission procedures are maintained in our internal compliance framework.
Risk-based approach
We apply a risk-based approach. This means that the nature and extent of our checks may differ depending on the financial-crime risk presented by a customer, transaction or business relationship.
Our assessment may take account of factors such as:
- the identity, occupation or business of the customer;
- the purpose and nature of the loan or relationship;
- the amount, frequency and pattern of transactions or repayments;
- the source of funds used for repayments where relevant;
- the countries or geographic areas connected with a customer or transaction;
- whether the customer or a relevant connected person is a Politically Exposed Person (“PEP”);
- the use of third parties, unusual payment arrangements or complex ownership structures; and
- other information or indicators relevant to money laundering, terrorism financing, proliferation financing, fraud or sanctions risk.
Higher-risk situations may result in additional information requests, enhanced due diligence, closer monitoring or a decision not to enter into or continue a relationship where the risk cannot be appropriately managed.
Customer identification and due diligence
We carry out Know Your Customer (“KYC”) and Customer Due Diligence (“CDD”) checks appropriate to our lending activities. We may obtain and verify information before granting a loan and may update our checks during the relationship.
Depending on the circumstances, we may:
- obtain and verify a customer’s full name, address, date of birth, contact details and other identifying information;
- request valid identification and supporting documents;
- verify information using reliable and independent sources;
- understand the purpose of the loan and the nature of the customer relationship;
- identify and verify a person acting on behalf of a customer;
- for corporate or other non-individual customers, identify relevant directors, controllers and beneficial owners;
- request information about source of income, source of funds or source of wealth where appropriate; and
- request updated information where existing information is incomplete, inconsistent, expired or has materially changed.
If we cannot complete required due diligence or obtain information reasonably needed to manage financial-crime risk, we may decline an application, decline or restrict a transaction, or end a relationship, subject to applicable law and contractual rights.
Beneficial ownership
Where a borrower or other customer is a company or another legal entity or arrangement, we may take reasonable steps to identify the individuals who ultimately own or control it. We may request corporate records, ownership information, identification documents and other information needed to understand the ownership and control structure.
Customers are expected to provide complete and accurate information and to notify us of material changes to ownership or control information.
Politically Exposed Persons and enhanced due diligence
A PEP is generally an individual who is or has been entrusted with a prominent public function. Depending on applicable requirements and risk, relevant family members and close associates may also require enhanced consideration.
Being identified as a PEP does not mean that a person has engaged in wrongdoing. It means that additional measures may be appropriate because of the risks associated with certain prominent public functions.
Where enhanced due diligence is required, we may obtain additional information, establish source of funds or wealth, obtain appropriate internal approval and apply enhanced ongoing monitoring.
Sanctions and proliferation financing
Claybarn maintains controls designed to comply with applicable targeted financial sanctions and proliferation-financing requirements. Where appropriate, we may screen customers, beneficial owners and relevant connected persons against applicable sanctions information.
Where required by law, Claybarn may decline or restrict a transaction or relationship, freeze or otherwise deal with assets as legally directed, and make required reports to the competent authority. We will not give notice where doing so is prohibited by law.
Transaction and repayment monitoring
We monitor lending relationships and relevant transactions in a manner proportionate to our business and the risks identified. This may include reviewing unusual repayment patterns, unexplained third-party payments, transactions inconsistent with known customer information, attempts to conceal the origin of funds, or other activity that gives rise to financial-crime concerns.
Our monitoring controls may be manual, technology-assisted or a combination of both.
Suspicious activity and regulatory reporting
Where Claybarn knows, suspects or has reasonable grounds to suspect that activity may involve proceeds of crime, money laundering, terrorism financing, proliferation financing or another reportable matter, we make the reports required by applicable law and regulatory requirements to the NFIU and, where applicable, through or to SCUML or another competent authority.
We do not disclose the existence or contents of a suspicious transaction report, or related information, where disclosure would amount to unlawful tipping-off. This may mean that we are unable to explain fully why a transaction, application or relationship has been delayed, restricted or declined.
Cash and threshold-based reporting
Claybarn applies controls to cash and other transactions that are subject to statutory reporting requirements. As a non-financial institution, we submit applicable statutory AML/CFT/CPF returns and reports through the channels prescribed by SCUML, the NFIU or another competent authority, including threshold-based reports where the relevant legal requirements are met.
Customers must not structure or split transactions for the purpose of avoiding identification, monitoring or reporting requirements.
Record keeping
We keep customer due-diligence, transaction, loan and AML/CFT/CPF records for the period required by applicable law and regulatory requirements. Records may be retained for longer where this is required by a competent authority, necessary for legal proceedings or otherwise permitted by law.
Records are maintained so that relevant transactions and compliance decisions can be reconstructed and lawful requests from competent authorities can be answered.
Technology and non-face-to-face lending
Where Claybarn uses digital onboarding, electronic communications, online payments or other technology in its lending activities, we consider the additional financial-crime risks that may arise from non-face-to-face relationships.
We may use additional verification, authentication, monitoring or fraud-prevention measures where appropriate. New products, delivery channels and technologies are assessed for relevant AML/CFT/CPF risks before or during implementation.
Governance, training and internal controls
Claybarn maintains internal controls appropriate to the nature, size and risk profile of its money-lending business. Responsibility for AML/CFT/CPF compliance is allocated at an appropriate level within the company.
Relevant personnel receive training on customer due diligence, suspicious activity, sanctions, record keeping and reporting obligations appropriate to their roles. Our framework is reviewed periodically and updated when required by changes in law, regulation, risk or our business.
Customer responsibilities
Customers play an important role in helping us meet our legal and regulatory obligations. We therefore expect customers to:
- provide complete, accurate and current information and genuine supporting documents;
- respond to reasonable requests for KYC, source-of-funds or other due-diligence information;
- notify us of material changes to identity, address, contact, ownership or control information;
- ensure that loan repayments and other transactions are made from legitimate sources;
- not use our services on behalf of an undisclosed third party; and
- not use a Claybarn loan or account relationship for unlawful activity.
Failure to provide information reasonably required for compliance purposes may affect our ability to approve a loan, process a transaction or continue a relationship.
Confidentiality and cooperation with authorities
We protect customer information in accordance with applicable confidentiality and data-protection requirements. These obligations do not prevent us from providing information to SCUML, the NFIU, law-enforcement agencies, courts or other competent authorities where disclosure is required or permitted by law.
Review and contact
We review this policy periodically and may update it to reflect changes in law, regulatory guidance, our services or financial-crime risks. The latest version will be published on our website.
Questions about this policy may be directed to:
Compliance Officer
Claybarn Fronteira Limited
Email: compliance@claybarn.ng
Address: 8 Lake Chad Crescent, Maitama, Abuja