Wasiu Rabiu, MICA, CAMS

Managed client onboarding, periodic reviews, and ongoing due diligence, ensuring end-to-end compliance with AML/KYC standards and accurate maintenance of client and account data. Conducted daily meetings and provided regular updates to management companies and the AIFM, delivering clear insights on onboarding progress, monitoring trends, and remediation actions. Prepared and presented KPI and SLA reports to senior management, highlighting efficiency, quality, and risk metrics across onboarding and monitoring activities. Played a key role in identifying control gaps, optimising workflows, and contributing to continuous improvement initiatives to strengthen overall financial crime prevention and regulatory compliance. • Led full end-to-end onboarding of institutional and corporate clients, managing account opening, maintenance, and off-boarding activities in line with internal governance standards and regulatory frameworks. • Conducted thorough AML/KYC due diligence on complex structures including funds, corporates, trusts, and SPVs, ensuring compliance with FATCA, CRS, QI, and jurisdictional requirements. • Performed ongoing due diligence and periodic reviews of existing client accounts, assessing risk ratings, refreshing documentation, and escalating high-risk findings or material changes. • Acted as first and second-level reviewer for client and account documentation, verifying completeness, data accuracy, and adherence to onboarding policies. • Held daily meetings with management companies and the AIFM to provide operational updates, discuss onboarding progress, and resolve outstanding items to ensure smooth client activation. • Delivered regular reports and KPI dashboards to senior management and key stakeholders, highlighting productivity, SLA adherence, and quality metrics across onboarding and review activities.

Review domestic and international client accounts, including Source of Wealth, Source of Funds, Source of Income, KYC Identification, AML, KYC, KYT, Factiva, Risk Scoring, etc. Identify and escalate all risk issues to relevant specialist desks and ensure relevant approvals have been acquired. Assure that remediation activities are implemented to comply with industry requirements and Bank’s policies. Ensure all reviewed accounts satisfy the required standards in relation to Financial Crime Compliance, CDB matters and other regulatory requirements Act as a case manager, liaising with Front Office, Financial Crime Compliance and Specialist Desks Provide onboarding KYC recommendations to Relationship Managers Provide advisory support for high risk or complex clients to ensure full compliance with procedures, policies, and regulations Perform basic and enhanced KYC due diligence for existing clients Conduct background checks and evaluate negative news related to existing clients Be an active risk manager, recognize the factors that impact client risk rating and due diligence requirements Work cross-functionally with internal teams to discuss changes or updates to KYC/AML requirements, policy, and procedure Appropriately escalate issues to management, compliance, and the business Handle sensitive and confidential information in accordance with the policy

Provide subject-matter advisory on AML/CTF obligations and financial crime controls to first and second-line teams. Utilize Fenergo for client lifecycle management (CLM), onboarding, due diligence (CDD/EDD), and KYC reviews to ensure AML compliance. Conduct transaction monitoring and investigations using tools such as SIRON AML, Actimize, Oracle Mantas, Fircosoft, or equivalent. Review transaction alerts and escalate suspicious activities; prepare and file high-quality Suspicious Activity Reports (SARs) to the FIU in line with legal requirements and internal SLAs. Conduct thematic reviews and support the design and calibration of transaction monitoring rules based on risk typologies and evolving threat landscapes. Work closely with AML Investigations and Intelligence teams to assess patterns, typologies, and indicators of money laundering, terrorist financing, fraud, or sanctions evasion. Advise on complex high-risk clients, jurisdictions, or products, including the provision of guidance to onboarding and relationship teams. Ensure systems and controls meet local and international standards (e.g., FATF, EU AMLD, FCA, CBI, MAS, etc.) Contribute to internal policies, SOPs, training materials, and awareness programs on AML and financial crime risk. Support internal and external audits, regulatory examinations, and remediation programs. Maintain strong knowledge of regulatory changes, typologies, and financial crime trends, and translate these into actionable guidance. Tools/Systems Fenergo SIRON AML Actimize Mantas Fircosoft / World-Check / LexisNexis OneSumX SAS AML Internal case management and workflow tools (e.g., NICE Actimize Case Manager)

Provide second line of defence (2LoD) regulatory compliance advice, guidance, and oversight to the first line of defence (1LoD) and business teams, ensuring they meet regulatory obligations and effectively manage compliance and conduct risks. Success is strongly measured by a reduction in compliance breaches, a 95%+ adherence rate to regulatory requirements, and evidence of improved customer outcomes through quarterly reviews. • Deliver high-quality regulatory compliance and conduct-related advice, guidance, and support to 1LoD/business teams within a 24-hour response time for routine queries and within 5 business days for complex issues. Conduct a quarterly satisfaction survey with 1LoD to achieve at least 90% satisfaction. • Provide expert compliance advice on all current and future products, services, and activities, including areas like consumer duty, conduct risk, outsourcing, product governance, and vulnerable customer handling. Track metrics such as zero significant compliance issues flagged during audits and 100% product governance compliance during product reviews. • Participate in compliance and regulatory initiatives, including authorizations, transaction monitoring, and surveillance. Ensure timely delivery of project milestones with 95% adherence to project deadlines and no major compliance findings in project audits. • Foster a collaborative working environment between Compliance and 1LoD by scheduling monthly feedback sessions and maintaining an engagement score of at least 85% based on 1LoD feedback surveys. • Assist in the development and implementation of conduct risk and compliance frameworks and policies aligned with the EFG code of conduct. Monitor the success rate of policy implementation through compliance testing, aiming for at least a 95% compliance rate in initial reviews.

The Investor AML Services tasks include Fund and investor onboarding and identification/verification of Investors, registration of Investors, AML/FATCA level file reviews for investors entering our contracted funds. Sanctions and PEP screening of all Investor names/connected parties, retention, labelling and loading of all AML documents for these investors, Preparing weekly reporting and KPI’s for our clients, boards and MLROs or Investor AML statistics. Participate in the AML Audits (Internal and External), remediation projects of AML files, operational management of AML function and team members, building client and team member relationships. • Supervise and manage onboarding and continuous review of investors, including KYC (Know Your Customer) requests. • Follow up on missing KYC information with client relationship management teams, clients, and investors. • Assist in reviewing formal documents like subscription and service agreements, AML/Comfort Letters, etc. • Share knowledge and experience with colleagues, coach, and review team members' work for validation and approval for account opening. • Act as a role model for new team members, providing training and guidance. • Serve as the main point of contact for Transfer Agent clients' portfolios, identifying and anticipating potential issues, and providing suitable solutions to clients. • Ensure all operational aspects of accounts and financial monitoring of client portfolios. • Manage relationships with service providers, including auditors, law firms, and banks, from a Transfer Agent perspective. • Assessment of KYC files (completeness of documentation on file, analysis of powers of authorised persons, shareholding structures, beneficial ownerships, incorporation documents, etc.), and carrying out of AML Due Diligence and distributor due diligence (where applicable) on new and existing contractual counterparties and provision of risk-based recommendations for approval to relevant committees

Provide support to the Luxembourg Centre of Excellence (COE) and the global Hub by bringing analytical thinking, skills, and experience to assigned projects to support first line of defence (LOD) AML/KYC activities. The Quality Assurance Team is responsible for the Quality Assurance of the AML/KYC activities performed by Global Due Diligence I&TS, TA Registers (Shareholders Services, Private Capital Services) I&TS and its Branch/Subsidiaries performed in Luxembourg or Canada. • Conducting thorough research and examination of new Customers, transactions, suppliers, intermediaries, brokers, and banks in accordance with the prescribed standards and established procedures, particularly with Luxembourg laws • Requesting the necessary Know Your Customer (KYC) information, documentation, and conducting a meticulous review and verification of the received paperwork, followed by performing a comprehensive risk assessment. • Methodically and concisely documenting the findings and analysis pertaining to the financial activities and associated entities of Customers. This information caters to a diverse audience, including Management, Regulatory bodies, Internal Audit, Senior Management, and Internal Compliance teams. • Executing screenings for customers, connected entities, beneficial owners, and transactions against sanctions lists, politically exposed persons (PEP) databases, and adverse media coverage. • Analysing and resolving alerts generated during the screening process, ensuring that risks are assessed and well documented, and escalating higher-risk situations to senior management and the compliance department. • Conducting periodic assessments of existing Customers in accordance with established policies and procedures. • Performing routine reviews of KYC records to ensure completeness, including validation of the due diligence process and verifying that files and risk assessments remain current and up to date.

● In conjunction with operational delivery managers, assume responsibility for quality, risk, and governance, and seek ways to continually improve processes, drive efficiencies, and automate processes through the use of technology where possible. ● Deliver relevant, cost effective and process efficient solutions that meet client’s needs and objectives. ● This responsibility runs in parallel of the continuous demonstration of successful leadership, through building, managing, and developing high performing teams. ● The build and maintain relationships across the client network, to position our services and capability and maintaining relationships with Partners and central teams. ● Maintain strong professional relationships with key client stakeholders, understanding their needs and having the vision to identify their potential needs in the future. s ● Strategy – identifying key issues faced by the business within the context of the wider firm. ● Governance of delivery programmes to meet contractual obligations, budgetary, timescales and regulatory standards. ● Operating as a Subject matter expert, provide training and QA to Financial Crime Unit staff and act as referral point for queries. ● Provision of input (e.g. drafting content, recommending changes) to design and review of Financial Crime related policies, training and guides and development of the anti-financial crime culture within client’s demand ● Ensuring that financial crime related procedures are in place and followed. ● Ensuring that appropriate transaction monitoring is conducted. ● Supporting Internal Audit, Risk & Compliance on Financial Crime matters.

● Accurately investigating all EDD queries, raising with relevant parties, and escalating where needed ● Providing ongoing guidance and support to the MLRO, Risk and other internal partners in the application of Sanctions and PEP Policy standards ● Undertaking Regulatory, Legislative and Policy reviews against current process to identify risks and non-conformance. ● Managing any adverse findings through to resolution and acting as a subject matter expert ● Undertaking business analysis to identify weaknesses in KPI’s and Control Assessments ● Managing ad-hoc financial crime investigations ● Seen as a subject matter expert and consultant, enabling colleagues to deliver correct outcomes ensuring customers are compliant with our policies and regulations ● Making sure processing is performed accurately and within an agreed turn-around time ● Monitoring and participating in initiatives that help improve our customer service, processes and procedures ● Reviewing processing errors and customer complaints to help identify trends and training needs ● Partnering with the three lines of defence to ensure that Financial Crime guidance and policies are interpreted and applied consistently, working together to address any gaps and implement improvements ● Support and working with the regulatory oversight teams in identifying all the testing errors in the client KYC file. ● Support and coordinating the EDD KYC Shout Ups where relevant queries are raised and added to the logs and expert advice given for case completion. ● Building and maintaining relationships with peers and relevant stakeholders who will support the development of the Financial Crime Hub, representing the function on specialist working parties

● Responsible for day-to-day AML and Sanctions Quality Control testing ● Ensure quality standards, procedural adherence, and departmental SLAs are upheld. ● Review investigations with attached documentation and rationale using various tools. ● Document a view on whether the outcome reached by AML and Sanctions Analyst is correct. ● Provide timely and appropriate feedback to relevant AML & Sanctions team. ● Collate relevant QC MI on team tasks and identified risks/issues, including trend analyses and improvement areas. ● Prepare scheduled reports on workload status, highlighting emerging issues to AML and Sanctions Quality Control Manager ● Engage with relevant stakeholders, including Line 1 Financial Crime Operations, Line 2 Financial Crime and Compliance functions, Product and Technology teams, and front-office relationship managers. ● Provide advice on draft suspicious activity reports and alerts review. ● Contribute to the ongoing improvement of AML and Sanctions function's systems and controls. ● Uphold, transmit, and reinforce company and departmental values. ● Review and analysis of Client Due Diligence reports and Know Your Client (KYC) data. ● Responsible for screening against sanctions lists and provide expert judgment regarding match validity. ● Responsible for tracking, reviewing and escalating metrics and reporting to identify Key Performance Indicators (KPI) and Key Risk Indicators (KRI) to management and other key stakeholders ● Participate in ongoing development of the sanctions screening systems, including User Acceptance Testing as needed ● Participate in cross-functional sanctions compliance meetings and carry out project plan for roadmaps ● Review and prepare all KYC documentation ready for approval from QC or QA checks. ● Continuous review of all OFAC/HMT generated lists of all SDN’s and sanctioned entities to mitigate client risks. ● Identification of all IRAN and RUSSIAN listed entities and individuals in line with the OFAC/HMT sanction list.