Fighting Financial Crimes
Sterling is committed to the fight against financial crimes and leading the way in responsible financial services.
Financial crimes involve illegal activities related to money, financial services, or markets, including:
- Fraud & Forgery
- Insider Trading or misuse of financial market information.
- Money laundering (handling the proceeds of crime)
- Bribery and corruption
- Financing of terrorism and proliferation
- Environmental crime
- Human trafficking & Smuggling
- Illegal wildlife trade
- Tax Evasion
As a leading institution with over 4,000 employees, a presence in major cities, and more than 4 million customer accounts, Sterling Bank recognizes that it is a potential target for those seeking to exploit the financial system. We remain vigilant in combating these threats to protect our customers and the integrity of the financial ecosystem.
STERLING’S MISSION AND APPROACH
Sterling’s mission is to be a financial institution of choice and to serve as a trusted partner to our customers by responsibly providing financial services that enable growth and economic progress.
Consistent with this goal, Sterling is committed to the fight against financial crimes and leading the way in responsible finance – conduct that is transparent, prudent, and dependable.
The following key principles govern Sterling’s approach to controlling Financial Crime risks:
- Compliance with extant global standards, regulations, and laws.
- Robust administrative and system controls.
- Cooperation with and support of regulators and law enforcement agencies in their efforts to prevent, detect and control financial crimes.
- Implementation of domestic and international sanctions requirements.
- Serving customers and providing products and services consistent with Sterling’s AML/CFT/CPF risk appetite and commitment to responsible finance and the highest ethical standards, and
- Adherence to the requirements of Sterling’s Anti-Bribery & Corruption (ABC) Policy.
Sterling acknowledges its responsibility to minimize the risks of its financial channels being exploited for illicit activities and implement controls to deter financial crimes against the community it serves.
STERLING’S ANTI-FINANCIAL CRIMES (AFC) PROGRAM
Sterling has established a comprehensive AFC Program to help protect the bank, clients, and our stakeholders from the risks of money laundering, terrorist financing, Proliferation financing and other financial crimes.
The foundation of this AFC program are Sterling’s AML/CFT/CPF Program, Anti-Bribery & Corruption Program, Whistleblowing Program, Sanctions Compliance Program which provide robust policies and consistent system of controls to identify and mitigate Financial Crime risks and comply with regulations and laws.
These include:
Anti-Financial Crime Governance:
At Sterling, our approach to preventing financial crimes is rooted in a comprehensive governance structure that ensures the highest standards of compliance, integrity, and accountability. We have established a robust Anti-Financial Crimes (AFC) program that spans regulatory compliance, employee training, and continuous monitoring. Key elements of our governance framework include:
Regulatory Reporting and Intelligence Collaboration
We ensure timely and precise reporting to regulatory bodies, including the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU). By working closely with these authorities and intelligence agencies, we actively contribute to the detection, prevention, and disruption of financial crimes such as money laundering and terrorism financing.
Regulatory Examinations and Spot Checks
We are subject to regular regulatory examinations and spot checks conducted by the CBN and other regulatory authorities. These evaluations assess our adherence to AML (Anti-Money Laundering), CFT (Combating the Financing of Terrorism), and CPF (Countering Proliferation Financing) regulations, allowing us to continually strengthen our controls against emerging risks.
Designated Chief Compliance Officer and Executive Compliance Officer
The bank’s Anti-Financial Crimes program is led by a designated Chief Compliance Officer (CCO), responsible for overseeing the program’s implementation, monitoring, and effectiveness. The CCO works closely with an Executive Compliance Officer, who provides additional oversight and ensures the alignment of the AFC program with the bank’s broader strategic objectives. Together, they ensure that the bank remains compliant with regulatory expectations and maintains a zero-tolerance approach to financial crimes.
Routine Internal Testing and Independent Reviews
Our AFC program is subject to routine internal testing to assess the effectiveness of our policies, controls, and processes. In addition, we engage independent third-party auditors to conduct external assessments of our AFC framework. This dual-layered testing ensures that our systems remain resilient and compliant with both local and international standards.
Board-Approved AFC Policies
Our AFC program is governed by a set of comprehensive policies that have been approved by the Board of Directors. These policies cover all aspects of financial crime risk management, including AML, CFT, CPF, sanctions screening, ABC, Conflict of Interest, Employee Conduct and Whistleblowing, Customer Acceptance and Risk Management. The Board provides oversight and ensures that our policies are regularly updated to reflect evolving regulatory requirements and industry best practices.
Comprehensive AFC Training
We conduct regular AFC training programs for employees at all levels, including specialized training for Senior and Executive Management and the Board of Directors. These sessions empower our workforce to recognize, report, and respond to financial crime risks, fostering a culture of compliance and vigilance across the organization.
By integrating these components, we maintain a proactive, dynamic approach to combating financial crime, ensuring the safety and security of our operations, customers, and stakeholders.
Anti-Financial Crimes Controls
The Anti-Financial Crime Controls controls are guided by key Program elements that are executed throughout three phases of the Financial Crimes Control Lifecycle: Prevention, Detection and Reporting:
- Prevention: Building and adhering to a robust Know Your Customer (KYC) program that focuses on the creation and administration of globally consistent standards/policies, customer risk scoring, on-boarding and maintenance of customer data housed in an enterprise-wide repository.
- Detection: Daily transaction monitoring to identify unusual or suspicious transactions or patterns of activity, as well as robust Investigations to provide holistic reviews of both new and existing clients.
- Reporting: Active creation, tracking and filing of reports as required by regulations.
ANTI-FINANCIAL CRIMES PROGRAM EXECUTION
Sterling’s risk management framework – including its Anti-Financial Crimes Program – is based on three lines of defense:
- First Line of Defense (Business Management)– Each of Sterling’s Businesses, including in-Business risk personnel, owns and manages the risks, including compliance risks, inherent in or arising from the Business, and is responsible for having controls in place to mitigate key risks, performing manager assessments of internal controls, and promoting a culture of compliance and control.
- Second Line of Defense (Independent Control Functions) -Sterling’s independent control functions (Compliance, Finance, Legal, and Risk) set standards for managing risks across the organization. We provide guidance, training, and oversight to ensure adherence to laws, regulations, and ethical standards. Compliance Monitoring & Advisory Officers support business units by providing AML/CFT/CPF expertise and monitoring compliance.
- Third Line of Defense (Internal Audit) – Sterling’s Internal Audit function independently reviews activities of the first two lines of defense based on a risk-based audit plan and methodology approved by the Sterling’s Board of Directors.
DUE DILIGENCE
Sterling conducts risk based due diligence on its customers, correspondents and third party relationships in line with extant regulations ensuring that we only establish relationship with third parties who meet the requisite Know-Your-Customer/Know-Your-Third-Party (KYC/KYTP) standards and fall within our acceptance criteria.
We are committed to maintaining the highest levels of transparency and regulatory compliance, especially when it comes to high-risk customer relationships. For clients or transactions that are deemed higher risk—whether due to geographic location, industry, or the nature of the transaction—we implement Enhanced Due Diligence (EDD) procedures.
The primary goal of EDD is to gain deeper insights into these relationships to ensure that all activities align with regulatory standards and ethical practices.
Sterling complies with Wolfsbergs guidance on Correspondent banking and ensures it maintains a populated and up-to-date Correspondent Banking Due Diligence Questionnaire (CBDDQ) to address the ongoing requirements of its Partners.
View our CBDDQ HERE
CUSTOMER ACCEPTANCE CRITERIA
Sterling Bank will only onboard and maintain relationships with customers who meet its regulatory KYC and CIP requirements.
Some of which include:
- BVN/NIN for Tier 1 accounts/wallets while BVN and NIN for Tier 2 and 3 accounts.
- Registration with SCUML for Designated Non-Financial Businesses & Professionals (DNFBP).
- Operational Licenses for Regulated Businesses.
- Registration with CAC and TIN for Corporates.
- CERPAC for resident foreigners.
- CRS and for US Nationals – FATCA (W9).
Anti-Bribery & Corruption (ABC) Program Policy Statement – View HERE
Anti-Money Laundering, Countering Financial Terrorism & Countering Proliferation Financing (AML/CFT/CPF) & Targeted Financial Sanctions Policy Statement – View HERE
Anti-Fraud Management (Prevention & Detection) – View HERE
Whistle-Blowing Program – View HERE
OUR CONTINUED VIGILANCE
Sterling is fully committed to remaining vigilant to prevent the use of our products and services by those who seek to abuse them.
We continually seek to combat financial crimes through the prevention, detection and reporting of unusual or suspicious behavior. We actively work to prevent the propagation of unlawful activities via our products and services, readily assist regulators and law enforcement agencies in their efforts, and promptly respond to inquiries.
We also continually evaluate the strength of our existing policies, procedures and technologies, and update them, as necessary, to address the changing environment. We also train our staff to assure that they are well versed in the evolving techniques that criminals use to infiltrate the system and are well-equipped to combat money laundering, terrorism financing, proliferation financing and other financial crimes.
The fight against financial crimes is a constant and evolving process. At Sterling, we recognize that preventing financial crimes involves constant due diligence and the ability to keep pace with the sophisticated schemes employed by illicit actors. We acknowledge that we must constantly work to identify and understand the potential risks of money laundering, terrorist financing, proliferation financing, bribery & corruption, fraud, financial sanctions and implement appropriate processes to mitigate, and ultimately alleviate, such risks.
