Anti-Money Laundering & Counter-Terrorist Financing Policy

This policy describes OTCICU’s approach to guarding against money laundering (AML) and the financing of terrorism (CFT) in connection with our cooperative activities.

This policy applies to OTCICU’s membership administration, contributions, and non-interest lending activities. OTCICU is a registered cooperative investment and credit union under the Nigerian Cooperative Societies Act, and is not a licensed bank.

OTCICU is committed to conducting its cooperative activities with integrity and to maintaining procedures appropriate to its size and activities to reduce the risk of misuse for illicit purposes.

Prospective members are asked to provide identifying information, including a valid means of identification, as part of the membership application process, before their membership is approved and activated.

OTCICU maintains membership verification procedures appropriate to its activities, including collection of identification details such as NIN and BVN, consistent with standard know-your-customer practice for cooperative financial institutions.

OTCICU aims to apply a proportionate, risk-based approach to member due diligence, reflecting the nature and scale of a member-owned, non-interest cooperative.

OTCICU maintains oversight of member contributions and loan activity through its cooperative administration processes as part of routine financial management.

Where a member of the Executive Committee or cooperative staff identifies activity that appears inconsistent with a member’s known profile or cooperative purpose, this is escalated internally for review in line with the cooperative’s governance structure.

OTCICU maintains records of membership applications, contributions, and loan activity as part of its ordinary cooperative record-keeping obligations.

OTCICU does not knowingly provide cooperative services in furtherance of money laundering, terrorist financing, or other unlawful activity, and reserves the right to decline or terminate a membership relationship where such concerns arise.

OTCICU is committed to promoting awareness among its Executive Committee and staff of the importance of AML/CFT vigilance appropriate to their roles within the cooperative.

Where OTCICU engages third-party payment service providers to facilitate transactions, those providers operate under their own applicable compliance obligations. OTCICU will cooperate with such providers and with lawful requests from competent authorities as required.

Information gathered in connection with this policy is handled in accordance with OTCICU’s Privacy Policy and is not disclosed except as necessary for cooperative administration or as required by law.

This policy is reviewed periodically by OTCICU management to ensure it remains appropriate to the cooperative’s activities and applicable regulatory expectations.