AML, CTF and Sanctions Manual

1 Purpose, status and scope

1.1Titita Empowerment Foundation (the Foundation; CAC IT Number 7283869) raises money and goods from donors and delivers them to communities. Each step is a place where illicit funds could enter, or where legitimate resources could be diverted. This manual sets the rules that keep both out.

1.2It binds the Board, the Chief Executive Officer, every employee, volunteer, consultant and agent who touches money, goods, beneficiary lists or counterparty files. Implementing partners, hosts and suppliers are bound through the contract clause at Annex A.

1.3Standard adopted. The Foundation follows the Money Laundering (Prevention and Prohibition) Act, 2022 (the Act) and the other laws listed below. It applies every duty the Act places on persons and bodies corporate generally. The Foundation is registered with the Special Control Unit against Money Laundering (SCUML) under section 17(2)(a) of the Act. Its Certificate of Registration, number SC 151420010, was issued on 2 July 2024. The Foundation keeps the certificate current, files any return that SCUML requires of it, and meets the duties that follow from that registration.

1.4Open to every lawful gift. The Foundation welcomes gifts of every size and from every lawful source, including anonymous gifts and cash within the legal limit. Its controls exist to protect donors, communities and the Foundation, not to discourage generosity. Where this manual sets a rule, it is because the Act, SCUML’s guidance or good sense requires it.

1.5Why the Foundation is exposed. International standards treat charities as a sector at risk of abuse, in particular through diversion of resources and through donations from sources that cannot be traced. Nigeria was removed from the FATF list of jurisdictions under increased monitoring on 24 October 2025 and its next mutual evaluation is being prepared for 2027, so supervisors are watching how charities apply their rules. A manual that is not applied is worse than none.

The legal framework this manual rests on

2 Definitions

3 Governance and responsibilities

3.1Appointment. The CO is a person of integrity with enough seniority to challenge the CEO. A named deputy acts when the CO is absent or implicated. The CO cannot also be the sole approver of a payment that the CO has screened.

3.2Independence of reporting. A report to the NFIU or another authority is the CO’s decision. No one may block it. If the CO is implicated, the report goes straight to the Chair, who must act on it within 24 hours.

3.3Protection for people who report. A person who reports in good faith is protected from retaliation. Anyone who retaliates faces disciplinary action. A report may be made anonymously through the contact route in Part 9.

3.4Political neutrality. The Foundation is non-partisan. It does not accept money, goods or services from, or give them to, a political party, a candidate, a campaign organisation or anyone acting for them, and no resource of the Foundation may be used for, or timed or branded to suggest support for, any election. Any offer of that kind is refused, recorded, and reported to the CO and the Chair on the day it is made.

4 Risk assessment

4.1The CO keeps a written risk assessment, reviewed at least once a year and whenever the Foundation starts a new type of activity. The table below is the Foundation’s starting assessment.

4.2 How a counterparty or transaction is scored

4.2.1Score each of five factors from 1 (lowest risk) to 3 (highest), then add them. A transaction takes the score of the counterparty or the transaction, whichever is higher.

4.2.2Automatic Extreme rating, whatever the score: a sanctions or proscription match; an offer from a political party, candidate or campaign; credible evidence that the resource is proceeds of crime. A counterparty that chooses to deal with the Foundation without identifying itself is not rated Extreme for that reason alone, but it cannot be a partner, host, supplier or paid consultant.

4.2.3Substance over form. Look at who really controls the money and who really benefits, not at the legal label. A gift can call for enhanced diligence if the circumstances are odd, whatever its size. Look across related gifts and payments over 12 months, because a gift split into pieces can hide a pattern.

5 Know your counterparty

5.1 Identification documents

For an individual: National Identification Number slip or card, international passport, driver’s licence or permanent voter’s card, with a photograph. For a company or association: certificate of incorporation or registration, the Corporate Affairs Commission status report, the constitution or memorandum, and identification of the officers and of the beneficial owner. For a foreign body: its registration document from its home register, its latest accounts and identification of its controllers. Copies are kept in the counterparty file. Documents that cannot be verified from an independent source are treated as not provided.

5.2 Donors

The Foundation sets no monetary limit on what it accepts from a donor. The level of diligence depends on the circumstances, not on the size of the gift.

• Anonymous gifts. The Foundation welcomes anonymous gifts, in money and in kind, with no limit on size. Giving quietly is a long and honourable tradition, and donors have good reasons for it, including privacy, safety and faith. Anonymity is not treated as suspicious. The Foundation records every anonymous gift in full: the date, the amount or items, the channel and the account it came from. Because the donor is not known, the CO keeps anonymous gifts in the Foundation’s general funds and does not tie them to any activity linked to a party or a candidate. A gift of any kind that carries a real red flag from Part 8 is handled under Parts 8 and 9, whether or not the donor is named.
• Cash gifts. The Foundation accepts cash from donors, within the statutory limit in clause 7.2.
• Digital assets. The Foundation does not accept cryptocurrency or other digital assets unless the Board approves in writing after counsel has advised.
• Refusing a gift. A gift may be refused or returned if a red flag cannot be resolved. The CO records the reason. A return is made to the account it came from, never to a different account.

5.3 Funders and grant-makers

An institutional funder receives Enhanced diligence on first dealing. The Foundation asks for the funder’s registration, its anti-money laundering and anti-diversion requirements, and any restrictions on use. Funder conditions are accepted only if the Foundation can meet them. The CO checks that no funder condition would require the Foundation to act for a party, candidate or campaign.

5.4 When diligence is done

Before the first dealing; again whenever the counterparty changes owner, address, bank account, activity, location or the way it is paid; and on a fixed cycle: every year for Enhanced and High-rated counterparties, and every two years for the rest. Files are kept for each counterparty and arranged by date.

5.5 Suppliers and consultants

Registered or identifiable provider; tax identification number; bank account in the provider’s own name; a conflict-of-interest declaration; a written order or contract; and payment by bank, or in cash within the statutory limit against a signed receipt. Competing quotations are sought where the purchase is not routine. A new supplier is screened against sanctions lists before it is first paid.

5.6 Implementing partners and host institutions

Payments go only to the partner’s own bank account, never to a person’s account. A partner that cannot show how it will record delivery is not engaged.

5.7 Staff and volunteers

Before anyone handles money, goods or beneficiary data: identification, two references, a declaration of interests and a signed commitment to this manual and to the Privacy Policy. No one works alone with cash or goods at a distribution. Volunteers who carry a register or count goods are briefed before each outreach.

5.8 Beneficiaries

Beneficiaries are not screened as counterparties, but the list that names them is controlled. Lists are drawn up with the community leader and a second independent person, checked for duplicates and for people who should not appear, and collect only what is needed (see TF-PRV-001). Where a beneficiary receives money, it goes to that person’s own account.

6 Sanctions and proscription screening

6.1Screen every donor who identifies themselves, every partner, host and new supplier, every director, officer and beneficial owner named in their documents, and every staff member and long-term volunteer, at onboarding and again every year.

6.2Screen against the lists in Part 2. Keep a dated record of the lists searched, the names searched and the result, even where there is no match.

6.3A possible match is held. The CO checks it against date of birth, address and other identifiers within one working day. A false positive is cleared and recorded.

6.4A true match: stop, do not complete any transaction, do not tell the counterparty, and inform the CO the same day. The CO reports to the NFIU without delay, follows the instructions of the competent authority, and informs the Chair.

6.5Politically exposed persons are identified by a written declaration and by screening. A PEP who is a party official, candidate or campaign officer is handled under clause 3.4. Any other PEP receives enhanced diligence, with the CO’s approval, and the Foundation checks that the money is the person’s own and not public money.

7 Controls on money and goods

7.1 Banking and payments

• Foundation accounts only. All money is received into and paid from accounts in the Foundation’s own name. Personal accounts are never used.
• Two signatures. Every payment needs two authorised signatories. The person who requests a payment cannot approve it.
• Payment voucher. Every payment has a voucher with the invoice or approval, the diligence record and the approvers’ names.
• Monthly reconciliation. The finance lead reconciles each bank account monthly. The CO reviews the reconciliation and any unexplained item every quarter.

7.2 Cash

The Foundation sets no limit of its own on the cash it accepts or pays. The limit in the Act applies, and no one in the Foundation can waive it.

7.3 Digital and mobile payments

Payments to individuals go only to an account in that individual’s own name, held with a bank or a licensed provider. No wallet, number or account that belongs to someone else is used, and payments are not routed through an intermediary without the CO’s approval.

7.4 Gifts in kind

7.5 Distribution day

• Beneficiaries come from a list approved in advance under clause 5.8. No one is added on the day without a recorded reason and a second person’s approval.
• At least two Foundation members and one community witness are present. No one works alone.
• Each recipient is recorded at the point of handover, by name or code, with the item and the quantity, and signs, thumbprints or is otherwise confirmed.
• Leftover goods are counted, recorded and returned to store the same day.
• At the close, the stock issued, the number of recipients and the quantity given are reconciled. A difference above 2 per cent is reported to the CO.
• The CO samples at least 10 per cent of outreaches each year, by contacting a selection of recipients to confirm they received what is recorded.

7.6 Election-period clearance

Any distribution of goods, food, clothing or money, and any gift received, during an election campaign period or in the weeks before polling day requires the CO’s written clearance and counsel’s advice beforehand. Items are given only on the basis of need, never branded, timed or described in a way that links them to a candidate or party, and are valued at their commercial value for the record.

8 Monitoring and red flags

8.1Ongoing monitoring. The CO reviews each month’s receipts and payments for unusual patterns, refreshes Enhanced files yearly, searches for adverse media on any High-rated counterparty every quarter, and re-rates a counterparty when anything changes.

9 Escalation and reporting

9.1Confidentiality does not prevent disclosure. Information about a counterparty must be given to a competent authority when the law requires it, even where an agreement says otherwise. Disclosures are limited to what the law requires and are recorded.

9.2Guidance followed. The Foundation’s reporting is guided by the Act, by the guidance and conditions that SCUML issues to the bodies it registers, and by the form and timetable SCUML prescribes. The CO obtains SCUML’s current guidance every year and whenever SCUML issues new guidance, keeps it on the compliance file, and updates this manual within 30 days. If SCUML’s guidance is stricter than this manual, the guidance prevails.

9.3Reports rest on suspicion, not on the kind of gift. Anonymity, payment in cash within the legal limit and the size of a gift are not, by themselves, grounds for a report. A report is considered where there are reasonable grounds to suspect, in the terms the Act uses: unjustifiable or unreasonable frequency; unusual or unjustified complexity; no apparent economic justification or lawful objective; or a link to the proceeds of crime, money laundering or terrorist financing. The CO records every decision to report and every decision not to report, with reasons, so that the Foundation can show SCUML a reasoned and consistent practice.

9.4How to reach the CO. By telephone on +234 707 633 0522 or +234 805 146 6501, or by email to partnerships@tititafoundation.org marked “Compliance, confidential”. Anyone who wants to report without giving a name may write to the same address without a signature.

10 Record keeping

10.1Records are kept for at least five years after the last transaction or the end of the relationship, and for seven years for financial records. They are kept longer where an investigation, claim or audit is open.

10.2Records kept: counterparty files and identification; diligence and approval records; sanctions screening logs; risk scores; payment vouchers and bank statements; receipt and cash registers; gift-in-kind records and stock registers; distribution registers; Internal Suspicion Reports and the CO’s decisions; statutory reports; training registers; the Board’s decisions on this manual.

10.3Records are stored securely, with access limited to those who need them, and are produced to an authority promptly and within any period it sets. Personal data in them is handled under TF-PRV-001.

11 Training and awareness

12 Review and assurance

12.1The CO reports to the Board each quarter on: counterparties approved, refused and exited; reports made and not made, with reasons; cash and stock exceptions; training done; changes in the law.

12.2An independent party, such as the external auditor or counsel, reviews how the manual is applied within 12 months of adoption and at least every two years after that. The review is given to the Board.

12.3The Board reviews this manual every year. Changes take effect when the Board adopts them and are recorded in the document control table.

13 Breaches

A breach of this manual is a disciplinary matter and, for a volunteer or consultant, can end the engagement. A counterparty that breaches its commitments has the relationship suspended, resources recovered where possible, and the matter reported where the law requires it. The Foundation may discontinue any programme or grant that has been used for money laundering, terrorist financing or diversion.

Adoption

This manual takes effect when the Board of Titita Empowerment Foundation adopts it by resolution, in the form at Annex F.

Annex A Contract clause for partners, hosts and suppliers

The following clause, or one with the same effect, is included in every agreement with an implementing partner, host institution or supplier.

“The Partner confirms and agrees that: (a) it is lawfully constituted and has given the Foundation true and complete information about itself, its officers and its beneficial owners; (b) it, its officers and its beneficial owners are not on, and are not owned or controlled by anyone on, any sanctions or proscription list, and it will tell the Foundation at once if that changes; (c) it will use every resource it receives only for the purpose agreed, will not divert any of it, and will not use any of it, directly or indirectly, for money laundering, terrorist financing or any unlawful purpose; (d) it will keep a record of every resource received and every person assisted, give the Foundation access to those records and to its premises on reasonable notice, and keep them for at least seven years; (e) it will not use any resource of the Foundation for, or in connection with, any political party, candidate or campaign; (f) it will report to the Foundation within 24 hours any loss, theft or suspected diversion; (g) the Foundation may suspend or end this agreement at once, and recover any resource, if the Partner breaches this clause; and (h) the Foundation may disclose information about the Partner to a competent authority where the law requires or permits.”

Annex B Internal Suspicion Report

Annex C Counterparty due diligence checklist

Annex D Donor declaration

For Enhanced donors, the donor completes and signs the following. The Foundation keeps it in the donor’s file.

• The money or goods I am giving belong to me (or to the organisation I represent) and come from lawful activity. The source is: ______________________________.
• I am not, and no one who owns or controls my organisation is, on any sanctions or proscription list.
• I am / am not a politically exposed person, or a family member or close associate of one. If I am, the position held is: ______________________.
• I am not giving on behalf of, or for the benefit of, any political party, candidate or campaign, and I expect nothing in return from the Foundation.
• The Foundation may check the information above and may disclose it to a competent authority where the law requires.

Name: __________________ Signature: __________________ Date: ______________

Annex E Compliance calendar

Annex F Form of Board resolution

“RESOLVED THAT the Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Manual, reference TF-AML-001 version 1.1, is adopted as the policy of Titita Empowerment Foundation with effect from the date of this resolution; THAT a Compliance Officer and a deputy Compliance Officer are appointed by name in the minutes of the meeting, reporting to the Chair as set out in the Manual; THAT the Chief Executive Officer shall ensure that every employee and every volunteer who handles resources receives and applies the Manual; THAT the Foundation, which is registered with the Special Control Unit against Money Laundering (certificate number SC 151420010, issued on 2 July 2024), shall keep its certification current and file any return that SCUML requires; and THAT the Compliance Officer shall report to the Board each quarter.”

The Board records the two names in its minutes when it passes the resolution. The manual itself names no individual.