Synopsis
This book explores the following research question: How can telecommunications companies design anti-money laundering and combating the financing of terrorism (AML/CFT) measures that meet the goal of financial inclusion without compromising the measures that exist for combating money laundering, terrorist financing and other illicit transactions through the financial system? This book will critically review the AML/CFT measures in the Guidelines for Licensing, Regulation and Operation of telecommunications companies issued by the Central Bank of Nigeria. The aim is to determine if the said Guidelines adopt a balanced approach to financial inclusion, anti-money laundering measures and fundamental human rights. Although the main focus of this book is on Nigeria, the measures and principles in it can be applied to any country that is faced with the challenge of designing AML/CFT measures for telecommunications companies. Each chapter of this book, from Chapters 2 to 6, has a discussion and conclusion section. The conclusion section provides recommendations for the policies that were analysed in the discussion section. No other book adopts this kind of approach. The research took the form of a desk study, which analyzed various documents and reports such as the Revised Central Bank of Nigeria National Financial Inclusion Strategy 2018, the Guidelines for Licensing and Regulation of Payment Service Banks in Nigeria as issued by the Central Bank of Nigeria in October 2018, the Central Bank of Nigeria’ Revised Assessment Criteria for Approved Persons' Regime for Financial Institutions 2015, the Central Bank of Nigeria Code of Corporate Governance for Banks and Discount Houses in Nigeria 2014, the Nigerian Money Laundering (Prohibition) Act, 2011 (as amended), the Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism in Banks and Other Financial Institutions in Nigeria) Regulations, 2013, the United Kingdom Payment Services Regulations 2017, the United Kingdom Payment Accounts Regulations 2015, the United Kingdom Electronic Money Regulations 2011, the Guidance on the Prevention of Money Laundering/Combating Terrorist Financing for the United Kingdom Financial Sector Part I as issued by the Joint Money Laundering Steering Group in June 2017 [Amended December 2017], the United States Federal Financial Institutions Examination Council’ Bank Secrecy Act/Anti-Money Laundering Examination Manual 2014, the Kenya Information and Communications (Amendment) Act 2013, the Kenya Information and Communications (Registration of SIM-cards) Regulations 2015, the Financial Action Task Force Guidance on the Risk-Based Approach to Combating Money Laundering and Terrorist Financing - High Level Principles and Procedures 2007, the Financial Action Task Force Guidance on Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion 2011, the International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation (The FATF Recommendations) 2012, the Financial Action Task Force Guidance on Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion 2013 and the Financial Action Task Force Guidance for a Risk Based Approach: Prepaid Cards, Mobile Payments and Internet-Based Payment Services 2013.
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