• 1. Introduction

    • Pepper Rest Ltd (the "Company", "us", "we") is a private company limited by shares registered under the laws of England and Wales and providing payment services to merchants and vendors through its e-commerce and payment services technology platform. The business of the Company might be a risk in relation to money laundering, however, in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering, we wish to put in place the following anti-money laundering policy which supplements the anti-money laundering, combating the financing of terrorism, and countering proliferation financing training given to all members of staff.


  • 2. Definitions & Interpretations

    • CTR : means Currency Transaction Reports.


    FATF : means Financial Action Task Force.


    MLRO : means Money Laundering Reporting Officer.


    MLR 2017 : means Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019.


    NCA : means National Crime Agency.


    Political Exposed Persons : Political Exposed Persons means Customers who are high-level public officials and their family members, and well-known personalities wishing to process payments using the Company's platform.


    SOCPA : SOCPA means Serious Organised Crime and Police Act 2005.


    UNSC : means United Nations Security Council.


  • 3. Scope of the Policy

    • The broad definition of money laundering means that potentially anyone could commit a money laundering offence, and this includes all employees of the Company, all temporary staff and contractors. This Policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.

    This Policy applies to everyone involved in the company. i.e. officers, employees, volunteers, suppliers, agency workers, contractors and shareholders. This Policy is made available internally throughout the Company and management is required to ensure that everyone is aware of it and receives appropriate training.

    All employees must be familiar with their legal responsibilities and failure to comply with this Policy may lead to disciplinary action.


  • 4. What is Money Laundering

    • The principal money laundering legislation is the Proceeds of Crime Act 2002 (POCA) as amended by the Serious Organised Crime and Police Act 2005 (SOCPA), supplemented by the Terrorism Act 2000 and the Fraud Act 2006. The secondary legislation is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 and Bribery Act 2010.

    Money laundering can be defined as the process of moving illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the UK; entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person; and acquiring, using or possessing criminal property.

    There are also several secondary offences which include, failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency (NCA); and 'tipping off' whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

    Any member of staff could potentially be in violation of the money laundering provisions if they suspect money laundering and either become involved with it in some way and/or do nothing about it. This Policy sets out how any concerns should be raised.


  • 5. Money Laundering Reporting Officer (MLRO)

    • The Company will appoint an MLRO to receive disclosures about money laundering activity and be responsible for anti-money laundering activities within the Company. The officer nominated to do this is Bridget Yadua-Soremekun.

    The Company will also appoint a deputy MLRO who will be responsible in the absence of the nominated officer. The deputy MLRO is Emmanuel Afolabi

    The MLRO will ensure that appropriate periodic training and awareness are provided to new and existing employees, officers, contractors, shareholders and volunteers of the Company. . The MLRO will ensure that appropriate anti-money laundering systems and processes are incorporated by the Company.


  • 6. Customer Acceptance Policy

    • 6.1 Business risk evaluation and management.

    The Company considers that the potential threat of becoming involved in any money laundering or terrorism activity is directly related to the type of business carried out by the Company and that such threat can be more effectively and efficiently managed if the potential risk linked to the business and products of the Company is known before.

    Classifying its products by risk levels shall enable the Company to design and implement measures and controls to mitigate such risk. Likewise, it shall enable the Company to focus on those business lines and products that present greater risk. Therefore, the Company shall apply a procedure that shall enable them to determine the risk of the business lines in which they participate and the products they distribute, with respect to money laundering or terrorism financing. The criteria and factors to be used for measuring such potential risk should also be identified.

    In the same sense, risks inherent in money laundering or terrorism financing can be managed more effectively and efficiently if the potential risk linked to the different types of customers and their transactions is known beforehand.

    Having customers and their transactions identified by risk level shall enable the Company to design and implement measures and controls to mitigate such risk. Likewise, it shall enable them to focus on those customers and transactions that present the greatest risk. In peculiar cases, such risk may only become apparent over time, such concerns thus make it prudent to monitor and/or report such customer's policies and activities as a fundamental component of our risk-based approach.

    In this sense, the Company shall design a procedure, based on the risk consideration of their own business and the products marketed by them, which shall provide an appropriate framework for segmenting their own customers by levels of money laundering or terrorism financing risk. The criteria and factors to be used for making such segmentation should also be identified.

    6.2 Assessing risks and applying a risk-based approach

    In compliance with the international standards on countering money laundering and the financing of terrorism & proliferation based on FATF Recommendation 1, the Company shall apply a risk-based approach (RBA) to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified.

    Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction.

    The Company shall adopt a risk-based approach in respect of profiling AML/CFT along the following lines:

    a. Client;

    b. Geographies;

    c. Product & services; and

    d. Distribution channels.

    6.3 Prohibited customers or with reinforced acceptance measures.

    For money-laundering and terrorism financing risk control purposes, the Company shall not accept the following categories of customers:

    a. Persons included in any of the official lists of sanctions ("applicable lists"). e.g. United Nations Security Council (UNSC) Sanctions List.

    b. Persons about whom information is available indicating possible involvement in criminal activities.

    c. Persons with businesses that make it impossible to verify the legitimacy of their activities or the source of funds.

    d. Persons who refuse to provide the required information or documentation.

    e. Legal entities whose shareholder or control structure cannot be determined.

    f. Casinos or gambling/betting establishments that are not officially authorized.

    g. Financial institutions resident in countries or territories without being physically present (also referred to as "shell companies") and which do not belong to a regulated financial group.

    6.4 Politically Exposed Persons.

    Customers classified as Political Exposed Persons (PEPs) shall only be accepted as customers of the Company with prior authorization from any member of senior management in line with section 35 of the MLR 2017.

    PEPs shall be subject to the Company's risk evaluation procedure and will be assigned risk ratings based on factors such as their industry, transaction volume, geographic location, and PEP status. PEPs shall also be subject to the Company's Enhanced Due Diligence (EDD) process.

    6.5 Know-Your-Customer (KYC).

    The most effective means of preventing the use of the financial system for money laundering or terrorism financing is to identify and know your customers, regardless of whether they are established customers or otherwise.

    Along these lines, the Company shall establish regulations, procedures, and internal controls aimed at obtaining effective and complete knowledge of their customers and their activities, in order to:

    a. Confirm and document the true identity of customers who maintain process payments using its platform.

    b. Confirm and document any additional customer information commensurate with the assessment of the money laundering and terrorism financing risk.

    c. Ensure that the Company does not engage in business with any individuals or entities whose identities cannot be confirmed, who do not provide all required information, or who have provided information that is false or that contains significant inconsistencies that cannot be clarified.

    For customer identification, the Company shall consider the following criteria:

    a. In the case of individuals, an official identification document shall be required to confirm the individual's identity.

    b. For corporations and other legal entities, the documents of incorporation must be presented, including information concerning the customer's name, legal form, address, directors, and the corporate bylaws, powers of attorney, entry in the appropriate register or other reliable identifying information.

    c. Neither anonymous accounts nor accounts using fictitious names may be opened or maintained.

    In these cases, all requirements must be fulfilled, including identification of the beneficial owner of the account, in accordance with the provisions of established AML/CFT regulations.

    The Company shall have procedures for determining that person's identity and relationship to the customer. All necessary measures shall be taken to obtain information about the true identity of the person on whose behalf a relationship is established, or a significant transaction conducted (that is, the beneficial owners) whenever the customer is acting on behalf of third parties or in cases where doubts exist as to whether the customer is acting on its own behalf


  • 7. Suspicions of Money Laundering

    • All employees must as soon as practicable report any knowledge of or suspicion of (or where there are reasonable grounds to suspect) suspicious activity to the MLRO in the prescribed form as set out in this Policy.

    Once the matter has been reported to the MLRO, the employee must follow the directions given to him/her and must NOT make any further enquiry into the matter.

    The employee must NOT voice any suspicions to the person(s) whom they suspect of money laundering, as this may result in the commission of the offence of "tipping off". They must NOT discuss the matter with others or note on the file that a report has been made to the MLRO in case this results in the suspect becoming aware of the situation.


  • 8. Consideration of the Disclosure by the MLRO

    • Once the MLRO has received the report, it must be evaluated in a timely manner in order to determine whether:

    • there is actual or suspected money laundering taking place; or

    • there are reasonable grounds to know or suspect that this is the case; and

    • whether the MLRO needs to lodge a Suspicious Activity Report (SAR) with the NCA via the SAR Online System.

    Where the MLRO concludes that there are no reasonable grounds to suspect money laundering then consent will be given for any on-going or imminent transaction(s) to proceed.

    Where consent is required from the NCA for a transaction to proceed, then the transaction(s) in question must not be undertaken or completed until the NCA has given specific consent, or there is deemed consent through the expiration of the relevant time limits without objection from the NCA.

    All disclosure reports referred to the MLRO and reports made to the NCA will be retained by the MLRO in a confidential file kept for that purpose, for a minimum of 5 years.

    The MLRO must also consider whether additional notifications and reports to other relevant enforcement agencies should be made.


  • 9. Customer Identification and Due Diligence

    • Due diligence is performed on all customers who must provide basic information including full name, residential/business address, date of birth for individuals and registration details for corporate bodies.

    Enhanced Due Diligence

    It may be necessary for the Company to carry out enhanced due diligence on certain customers where the customer or a transaction involving the customer appears to be "high risk". This means that there is a higher level of identification and verification of the customer's identity required. The following non-exhaustive list of situations may indicate a "high risk":

    • a new customer;

    • a customer not well known to the Company;

    • customers in known high risk industries and/or jurisdictions;

    • transactions that are unusual or appear to be unusual for that customer;

    • highly complex transaction or payment arrangements;

    • the transaction involves a politically exposed person ("PEP") or an immediate family member or a close associate of a PEP; and

    • no face-to-face meetings take place with the customer where this is usually expected.

    Employees must assess the money laundering risk for each customer and if they suspect enhanced due diligence is required, you should speak to the MLRO before continuing any engagement with the customer. The MLRO will be required to approve the continuance of the business relationship.

    If enhanced due diligence is carried out, the MLRO must:

    • obtain additional information on the customer and on the customer's beneficial owner(s);

    • obtain additional information on the intended nature of the business relationship;

    • obtain information on the source of funds and source of wealth of the customer and customer's beneficial owner(s); and

    • conduct enhanced monitoring of the business relationship.

    This may include but is not limited to the following:

    • checking the organisation website to confirm the identity of personnel, its business address and any other details;

    • attending the customer at their business address;

    • obtaining additional information or evidence to establish the identity of the customer and its beneficial owner(s), including checking publicly available beneficial ownership registers of legal entities such as the registers available at Companies House;

    • in the case of a PEP, seek the approval of senior management and establish the source of wealth and source of funds; and

    • ensure that the first payment is made into a bank account in the customer's name.

    If satisfactory evidence of identity is not obtained at the outset, then the business relationship or one-off transaction(s) cannot proceed any further. A report should be filed with the MLRO who will then consider if a report needs to be submitted to the NCA.


  • 10. Sanction Screening

    • The Company shall perform comprehensive sanctions screenings on all existing and potential customers, partners, beneficiaries, and transactions. This includes but is not limited to individuals, entities, and entities related to such individuals. The MLRO shall oversee and execute sanction screening processes on all existing and prospective customers, partners, beneficiaries, and transactions.

    The screening process shall encompass a thorough check against global sanctions lists, which shall include lists maintained by:

    • The United Nation's Security Council

    • The Office of Foreign Assets Control

    • The European Union External Action Service

    • His Majesty's Treasury

    • The Financial Action Task Force (FATF)

    The primary objective of the screening shall be to identify and mitigate potential financial risks associated with engaging with customers, beneficiaries or partners (whether individuals or entities) or certain transactions that may be subject to sanctions or restrictions, and the screening process shall be ongoing, with regular updates.

    The MLRO shall file a Suspicious Activity Report (SAR) of all matches with individuals, entities, or transactions found on sanctions lists to the NCA.


  • 11. Ongoing Monitoring

    • Employees should review customers at regular intervals to ensure that the risk level of each customer's information and information held on each customer is not only accurate and up to date but is consistent with the knowledge of the customer and its business.

    Further due diligence may be required if new people become customers of the Company. Any suspicious activity must be reported to the MLRO.


  • 12. Data Protection

    • In preventing money laundering and terrorist financing, the personal data of the Company's customers must be collected and processed in accordance with the Data Protection Act 2018.


  • 13. Record Keeping

    • Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 5 (five) years from the end of any business relationship with that customer.


  • 14. Staff

    • In compliance with the provisions of the MLR 2017, the Training unit shall facilitate training programs that shall make employees and agents to be fully aware of their obligations e.g. identifying suspicious transactions and equip them with the relevant skill required for the effective discharge of their AML/CFT tasks.

    The Company shall adopt any of the following staff training methods;

    a. Classroom training;

    b. Electronic learning management systems (ELMS);

    c. Email Communication broadcast to all Staff on AML/CFT subject matter; or

    d. Mandatory company-wide Knowledge sharing sessions

    The training programs shall consider international standards and local legislation to prevent money laundering and terrorism financing, the latest trends in criminal activity, and the Company's policies and procedures designed to counter money laundering and terrorism financing, including how to recognize and report suspicious activities.

    A specific record shall be kept of all training activity given, stating the date, place and duration of each course, the number of attendees and the Unit to which they belong

  • 15. Implementation of Policy

    • This Policy shall be deemed effective as of August 1, 2023. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

    This Policy has been approved and authorised by:

    Name Bankole Alao

    Position CEO

    Date August 1, 2023