Premium Capital Investment Ghana Limited is committed to preventing money laundering, terrorist financing, sanctions evasion, and other financial crime. We refuse to handle the proceeds of crime, regardless of the size of the relationship or the commercial pressure to do otherwise.
Compliance with anti-financial-crime law is the responsibility of every employee. We support a "speak up" culture in which any staff member can raise concerns to compliance, the MLRO, or the Board, without fear of retaliation.
Our AML programme is designed to comply with:
The Board of Directors has ultimate responsibility for AML/CFT. The Audit & Risk Committee oversees the programme on the Board's behalf and reviews its effectiveness at least annually.
We appoint a Money Laundering Reporting Officer at senior level, with sufficient seniority, experience, and independence to exercise the role. The MLRO reports directly to the Audit & Risk Committee and has unrestricted access to the Board. The MLRO can be contacted at compliance@premiumcapitalgh.com.
The Compliance Officer (who may be the same person as the MLRO depending on firm size) is responsible for the day-to-day operation of the AML programme.
Our programme follows a risk-based approach: we apply more rigorous controls where the risk of financial crime is higher, and proportionate controls where it is lower.
We assess and document risk at three levels:
Before we open an account or enter a business relationship, we identify and verify each customer.
For individual customers, we collect:
For corporate customers, we collect:
We verify the identity of customers using reliable, independent source data: the National Identification Authority for Ghana Card verification, government registries, and reputable third-party verification services.
We assess the purpose for which the account is being opened and the intended nature of the activity, to set a baseline against which we can monitor.
Where the risk of money laundering or terrorist financing is higher, we apply enhanced measures, which may include:
Categories where EDD is typically applied include politically exposed persons, customers from higher-risk jurisdictions, customers in higher-risk industries, complex ownership structures, and unusually large or unusual transaction patterns.
For all corporate, trust, foundation, and partnership clients, we identify the natural persons who ultimately own or control the entity. The beneficial ownership threshold we use is 10% or more of voting rights, ownership, or economic interest, in line with Ghana's Companies Act and Beneficial Ownership Disclosure regime.
We verify beneficial ownership using documentary evidence and, where available, the public Beneficial Ownership Register maintained by the Office of the Registrar of Companies.
We identify customers who are, or are connected to, politically exposed persons (PEPs). PEPs include:
PEP relationships require senior management approval before establishment, enhanced source-of-wealth verification, and increased ongoing monitoring. We apply these measures regardless of the apparent reputation of the individual.
We screen all customers and beneficial owners against sanctions lists at onboarding and on an ongoing basis. Lists screened include:
Where a confirmed match is identified, we will not establish or continue the relationship and will report as required to the FIC and other authorities. We maintain transaction screening to detect attempts to deal with sanctioned parties.
The relationship does not end at onboarding. Throughout the customer relationship we:
Where we have reasonable grounds to suspect that funds or transactions are connected to money laundering, terrorist financing, or other crime, we file a Suspicious Transaction Report (STR) with the Financial Intelligence Centre.
Tipping off — telling a customer or third party that a report has been or may be filed — is a criminal offence under Ghanaian law, and we strictly prohibit it.
We do not require certainty before filing; reasonable suspicion is enough. We err on the side of reporting where in doubt.
We retain the following records for at least six years after the end of the customer relationship or the date of the transaction (whichever is later):
Records are stored securely with controlled access, in formats that allow timely retrieval.
All staff complete AML/CFT training at induction and at least annually thereafter. Training covers our policies, current typologies, sanctions, the duty to report, and the prohibition on tipping off. Training is differentiated by role: staff in client-facing or compliance roles receive deeper training appropriate to their responsibilities.
The AML programme is subject to independent review at least annually, conducted either by internal audit or an independent external reviewer. The findings are reported to the Audit & Risk Committee and the Board, with corrective actions tracked to closure.
We cooperate fully with the Financial Intelligence Centre, the Securities & Exchange Commission of Ghana, Bank of Ghana, the Ghana Revenue Authority, the Police, and other competent authorities, in line with applicable law. We respond promptly to lawful information requests and production orders.