Compliance & Regulatory Standing
Compliance is not a constraint on our business, it is the foundation of trust with every client, counterparty, and partner we serve.
Why institutional compliance matters
In a sector where undercapitalised and poorly governed operators routinely fail to complete transactions due to banking de-risking or regulatory challenge, Trinity IDF's institutional compliance framework directly enables higher-quality relationships and more reliable deal execution.
Current & in good standing
| Licence / Registration | Status | |
|---|---|---|
| Crude Oil Trading Licence | Active | |
| Downstream Petroleum Dealer Licence | Active | |
| CAC Incorporation | Active | |
| Tax Registration | Active | |
| NFIU Compliance Officer Registration | Active |
FATF-aligned, institutionally documented
Our full institutional-grade AML/CFT Compliance Manual is mapped to the Money Laundering (Prevention & Prohibition) Act 2022, the Terrorism (Prevention & Prohibition) Act 2022, CBN AML/CFT/CPF Regulations 2023, NFIU Guidelines, and the FATF 40 Recommendations.
CDD / KYC
- Three-tier CDD (SDD / Standard / EDD)
- PEP screening and Enhanced Due Diligence
- Beneficial ownership to UBO level
- Ongoing monitoring and periodic review
- CDD on all clients, partners, and capital sources
Transaction Controls
- TBML controls, price benchmarking, B/L reconciliation
- Five-regime sanctions screening (UN, OFAC, EU, UK, NG)
- Vessel and flag-state due diligence
- Third-party cargo inspection requirement
- Proliferation financing (CPF) controls
Reporting & Governance
- STR / SAR filing with the NFIU via goAML
- Internal review procedure and DACO oversight
- Annual independent AML/CFT audit
- Five-year minimum record retention
- Whistleblower protection policy
Operating responsibly across E, S, and G
Environmental
- MARPOL-compliant vessel requirements for all engaged operators
- Avoiding transactions involving non-compliant crude origination or flared-gas derivatives
- NMDPRA environmental compliance across downstream distribution
Social
- Energy access for Nigerian industry, logistics, and households
- Job creation across the logistics and distribution value chain
- Compliance with NMDPRA pricing frameworks to avoid market distortion
Governance
- Full AML/CFT compliance programme (FATF-aligned)
- Transparent beneficial ownership disclosure under CAMA 2020
- Dual-authorization controls on material payments
- Zero tolerance for bribery and corruption
Trinity IDF's AML/CFT framework is available to clients, partners, correspondent banks, and regulators in full upon request. This transparency is deliberate, it is the foundation of the trust that institutional counterparties require before engaging in vessel-grade transactions.