Business and customer risk
Assess products, markets, delivery channels, payment methods, agents, suppliers, customer types and emerging typologies. Translate that assessment into risk appetite, controls and measurable review triggers.
NGA LICENSING STANDARD / FINANCIAL CRIME
Financial crime controls must work in practice.
A policy document is not a control. Applicants must show a risk-based programme with accountable decisions, usable systems, competent staff and a complete evidential trail.
ACCOUNTABILITY
One programme, owned at senior level.
The operator must appoint a suitably experienced and independent MLRO or equivalent accountable officer with direct access to senior management, adequate resources, a competent deputy and authority to restrict activity. The governing body must approve and periodically review the business-wide financial-crime risk assessment.
MANDATORY CONTROL AREAS
CDD, age and identity
Identify and verify customers using reliable evidence, detect duplicates and synthetic identities, establish beneficial ownership for non-natural customers and prevent anonymous or materially fictitious accounts.
Enhanced due diligence
Apply documented EDD to higher-risk customers and events, including PEP exposure, high-risk geography, complex ownership, unusual payment behaviour, rapid movement of value and material affordability or fraud indicators.
Sanctions and PEP screening
Screen customers, beneficial owners, counterparties and relevant suppliers at onboarding and on an ongoing basis. Potential matches require controlled review, disposition and escalation; sanctions prohibitions override commercial interests.
Source of funds and wealth
Set risk- and value-based triggers, obtain evidence proportionate to the concern, compare it with observed activity and record why the evidence is sufficient. Deposit history alone is not proof of legitimate origin.
Transaction monitoring
Monitor deposits, withdrawals, peer or linked-account behaviour, payment-instrument ownership, velocity, structuring, bonus abuse, low-play-through cash-out, reversals and device or network relationships. Alerts must be timely, investigated and quality assured.
Suspicion and legal reporting
Provide confidential internal escalation to the MLRO, prohibit tipping off, document decisions and make reports to the competent authority whenever applicable law requires. NGA does not receive or replace statutory suspicious-activity reports.
Records, training and assurance
Retain auditable KYC, screening, monitoring, investigation, decision and training records for the legally required period. Test the programme independently at a frequency proportionate to risk and close findings to verified completion.
ZERO-TOLERANCE EVENTS
Concealment is more serious than control weakness.
Knowingly serving sanctioned persons, fabricating KYC, disabling monitoring to preserve revenue, concealing material alerts, obstructing review or misrepresenting the programme may cause immediate interim suspension and revocation review.
Legal boundary
NGA is a private assessment and certification scheme. This standard supplements and does not replace any AML, CTF, sanctions, tax, reporting or record-retention duty imposed by a competent governmental authority.