Conduct and Compliance
Sterling is committed to the fight against financial crimes and leading the way in responsible financial services.
Financial Crimes are criminal conduct relating to money or to financial services or markets, including any offence involving:
(a) fraud or dishonesty; or
(b) misconduct in, or misuse of information relating to, a financial market; or
(c) handling the proceeds of crime; or
(d) the financing of terrorism/proliferation.
The challenges in the fight against financial crimes are vast, and potential threats exist in every corner of the world. Financial services firms, regulators and law enforcement agencies alike work very hard to stay ahead of increasingly sophisticated criminals that seek to exploit the global financial system.
As an institution that operates in a wide variety of cultures and languages in Nigeria; Sterling employs over 4,000 people; has a presence in major cities across the country; and maintains more than 4 million customer accounts; Sterling will always be a target of would-be money launderers.
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 AML/CFT/CPF laws and regulations.
- 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 requirement
- 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 Policy.
Sterling recognizes its obligation to cooperate with and support regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime, and to comply with AML/CFT/CPF laws and regulation to close off the financial channels that money launderers and terrorist organizations use for illicit purposes. We have also worked to ensure that we have proper policies, processes and controls in place to deter money laundering and other financial crimes against the bank, our clients and stakeholders.
STERLING’S AML/CFT/CPF PROGRAM
Sterling has established a comprehensive AML/CFT/CPF 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 AML/CFT/CPF program is Sterling’s Anti-Money Laundering Policy, which provides a robust and consistent system of controls to identify and mitigate AML/CFT/CPF risks and comply with AML/CFT/CPF laws and regulations.
These include:
Chief Compliance Officer
The Chief Compliance Officer has been designated by Sterling’s Board of Directors as the Senior Management Staff responsible for overseeing Sterling’s AML/CFT/CPF Program, including apprising the Board of Directors (via the Executive Compliance Officer) and senior management of AML/CFT/CPF compliance initiatives, any significant compliance deficiencies, and the reporting of suspicious activity.
Governance and Enterprise-wide controls
This control framework governs the overall program, including the bank’s AML/CFT/CPF policies, processes, training and testing.
FINANCIAL CRIMES CONTROL LIFECYCLE
Built on and guided by this foundation are the 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 AML/CFT/CPF Investigations to provide holistic reviews of both new and existing clients across various businesses and regions.
- Reporting: Active creation, tracking and filing of Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs), 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)– Sterling’s Businesses 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.
ENHACNED DUE DILIGENCE (EDD)
Sterling conducts Enhanced Due Diligence (EDD) on all consultants, proxies, and third parties before being onboarded to become partners of the Bank. The enhanced due diligence conducted is designed to increase transparency and enhance financial institutions’ capacity to maintain business relationships with key correspondents by exchanging KYC information simply and centrally.
The Wolfsberg Group Financial Crimes Compliance Questionnaire (FCCQ) and the Sterling’s AML Due Diligence Questionnaire is to be completed by third parties before being onboarded. Third-party banks and vendors conducting KYC due diligence, including the Sterling’s AML Due Diligence Questionnaire should engage Sterling directly by emailing [email protected]Â
The Sterling’s AML due diligence questionnaire is a shorter version of the Wolfsberg Group Financial Crimes Compliance Questionnaire (FCCQ) and contains a basic set of questions to address industry demand. Download the Sterling AML Due Diligence Questionnaire (this should be updated with a filled Wolfsberg questionnaire by Sterling)
CUSTOMER ACCEPTANCE
Pursuant to the CBN AML/CFT/CPF regulation and the CBN due diligence regulation, Sterling Bank will only onboard and maintain relationships with customers who meet the regulatory KYC requirements.
Some of which include:
- BVN/NIN for Tiers 2 & 3 accounts
- Registration with the Special Control Unit Against Money Laundering (SCUML) for DNFBPs (Designated Non-Financial Businesses and Professions)
- Operational Licenses for Regulated Businesses
- CERPAC (Combined Expatriate Residence Permit and Aliens Card) for resident foreigners
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 terrorist organizations from accessing our financial 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 money laundering and identifying possible terrorist financing activities involves constant due diligence and the ability to keep pace with the sophisticated schemes employed by criminals. We acknowledge that we must constantly work to identify and understand the potential risks of money laundering and terrorist financing, and implement appropriate processes to mitigate, and ultimately alleviate, such risks.
