Compliance

1. Regulatory Framework

Signature Africa Digital Bank operates under the comprehensive regulatory framework of the Federal Republic of Nigeria. We are committed to maintaining the highest standards of compliance with all applicable laws, regulations, and industry best practices.

1.1 Primary Regulators

• Central Bank of Nigeria (CBN): Our partner banks' primary regulator and licensing authority
• Financial Reporting Council of Nigeria (FRCN): Oversees financial reporting standards
• Nigeria Data Protection Commission (NDPC): Regulates data protection and privacy
• Economic and Financial Crimes Commission (EFCC): Anti-money laundering enforcement

1.2 Banking License and Authorization

2. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

2.1 AML/CTF Framework

We maintain a robust Anti-Money Laundering and Counter-Terrorism Financing program in compliance with:

• Money Laundering (Prohibition) Act 2011 (as amended)
• Terrorism (Prevention) Act 2011 (as amended)
• CBN Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Regulation 2013
• Financial Action Task Force (FATF) recommendations
• Nigerian Financial Intelligence Unit (NFIU) guidelines

2.2 Key AML/CTF Measures

• Customer Due Diligence (CDD): Comprehensive identity verification and risk assessment
• Enhanced Due Diligence (EDD): Additional scrutiny for high-risk customers and transactions
• Ongoing Monitoring: Continuous transaction monitoring and suspicious activity detection
• Sanctions Screening: Real-time screening against local and international sanctions lists
• Record Keeping: Maintenance of detailed transaction and customer records
• Staff Training: Regular AML/CTF training for all employees

2.3 Suspicious Transaction Reporting

We have established procedures for identifying, investigating, and reporting suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) and other relevant authorities as required by law.

3. Know Your Customer (KYC) Requirements

3.1 Customer Identification Program

All customers must complete our comprehensive KYC process before accessing our services:

• Identity Verification: Valid government-issued identification documents
• Address Verification: Proof of residential or business address
• BVN Verification: Bank Verification Number validation
• Biometric Capture: Fingerprint and facial recognition data
• Source of Funds: Documentation of income and wealth sources

3.2 Customer Risk Classification

4. Data Protection and Privacy Compliance

4.1 Regulatory Compliance

We comply with Nigerian data protection laws and international standards:

• Nigeria Data Protection Regulation (NDPR) 2019
• CBN Consumer Protection Framework
• International data protection best practices
• ISO 27001 information security standards

4.2 Data Protection Measures

• Data minimization and purpose limitation
• Consent management and customer rights
• Data retention and deletion policies
• Cross-border data transfer safeguards
• Regular privacy impact assessments

5. Consumer Protection

5.1 CBN Consumer Protection Framework

We adhere to the CBN Consumer Protection Framework to ensure fair treatment of all customers:

• Transparent pricing and fee disclosure
• Clear terms and conditions
• Accessible complaint resolution procedures
• Protection of customer information
• Fair debt collection practices

5.2 Complaint Resolution Process

6. Cybersecurity and Information Security

6.1 Regulatory Requirements

We comply with cybersecurity regulations and guidelines:

• CBN Guidelines on Cybersecurity Framework for Banks and Other Financial Institutions
• Nigeria Computer Security Incident Response Team (NgCERT) guidelines
• International cybersecurity standards (ISO 27001, NIST Framework)
• Payment Card Industry Data Security Standard (PCI DSS)

6.2 Security Measures

• Multi-layered security architecture
• 24/7 security monitoring and incident response
• Regular penetration testing and vulnerability assessments
• Employee security awareness training
• Secure software development lifecycle
• Business continuity and disaster recovery planning

7. Financial Reporting and Disclosure

7.1 Reporting Standards

We maintain accurate financial records and reporting in accordance with:

• International Financial Reporting Standards (IFRS)
• CBN prudential guidelines
• Nigerian accounting standards
• NDIC reporting requirements

7.2 Regular Reporting

• Monthly regulatory returns to CBN
• Quarterly financial statements
• Annual audited financial statements
• Suspicious transaction reports to NFIU
• Cybersecurity incident reports

8. Risk Management

8.1 Risk Management Framework

We maintain a comprehensive risk management framework covering:

• Credit Risk: Loan underwriting and portfolio management
• Operational Risk: Process controls and business continuity
• Market Risk: Interest rate and foreign exchange exposure
• Liquidity Risk: Cash flow and funding management
• Compliance Risk: Regulatory adherence and monitoring
• Reputational Risk: Brand protection and crisis management

8.2 Risk Governance

• Board-level risk oversight and approval
• Independent risk management function
• Regular risk assessments and stress testing
• Risk appetite framework and limits
• Incident reporting and corrective action

9. Corporate Governance

9.1 Governance Structure

Our corporate governance framework ensures accountability, transparency, and ethical conduct:

• Independent board of directors with diverse expertise
• Board committees for audit, risk, and governance oversight
• Clear separation of management and oversight functions
• Regular board evaluations and training
• Stakeholder engagement and communication

9.2 Ethics and Conduct

• Code of conduct for all employees and directors
• Conflict of interest policies and procedures
• Whistleblower protection and reporting mechanisms
• Anti-corruption and bribery policies
• Regular ethics training and awareness programs

10. Regulatory Examinations and Audits

10.1 Regular Examinations

We undergo regular examinations and audits by regulatory authorities:

• CBN on-site and off-site examinations
• NDIC deposit insurance assessments
• External audit by certified public accountants
• Internal audit and compliance reviews
• Third-party security assessments

10.2 Corrective Actions

We promptly address any findings from regulatory examinations and implement corrective actions to ensure continuous compliance and improvement of our operations.

11. Training and Awareness

11.1 Employee Training Programs

• Regular compliance training sessions
• Role-based training for different departments
• Annual refresher courses
• Specialized training for compliance officers