Anti–Money Laundering Policy and Procedure

Last Updated: 30th March, 2024

Proppal Technologies Ltd “the Company” recognizes the critical importance of preventing money laundering and terrorism financing within the Nigerian real estate technology sector. 

As a as a designated non-financial institution (DNFI), Proppal Technologies is committed to upholding the highest standards of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT). This policy establishes the framework for identifying, assessing, and mitigating the risks associated with money laundering and terrorism financing activities.

  1. Scope Money Laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Criminal proceeds may take any form, including money or money’s worth, securities, tangible property and intangible property. Terrorism Financing is defined as providing, depositing, distributing or collection funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially use, for the committing of terrorist acts. This policy applies to all customers, employees, contractors, and business partners of Proppal Technologies Ltd involved in the company's real estate technology operations. It encompasses all activities related to customer engagement, transactions, and business relationships within the Company’s local and global real estate market.

  2. Legal Compliance

    Proppal Technologies Ltd operates in accordance with applicable Nigerian laws and regulations related to AML and CFT, including but not limited to the Money Laundering Prevention and Prohibition Act 2022, Terrorism Prevention Act 2013, and any other relevant legislation. Compliance with these laws is mandatory for all employees and business operations.

  3. Customer Due Diligence (CDD)

    1. Customer Identification and Verification:

      1. Proppal Technologies will implement robust processes and procedures for identifying and verifying the identity of customers using reliable and independent sources.

      2. Customer identification documents will be collected and verified in accordance with the company's Know Your Customer (KYC) principles.

    2. Risk-Based Approach:

      1. A risk – based approach will be adopted to assess the level of AML/CFT risk associated with each customer and transaction.

      2. Enhanced due diligence measures will be applied to high – risk customers or transactions.

  4. Transaction Monitoring and Reporting

    1. Transaction Monitoring:

      1. Proppal Technologies will deploy advanced transaction monitoring systems to detect and report suspicious activities in real-time.

      2. Unusual or suspicious transactions will be promptly investigated and reported to the designated Anti Money laundering Officer “AMLO”.

    2. Reporting Suspicious Activities:

      1. Employees, contractors, and business partners are required to report any suspicion or knowledge of possible money laundering or terrorist financing activities to the AMLO without delay.

      2. Reports should include relevant details such as the identity of the individuals involved, nature of the suspicious activity, and any other pertinent information.

  5. Record Keeping

    1. Document Retention:

      1. Proppal Technologies will maintain accurate records of customer identification documents, transaction data, and other relevant information for a minimum period of five (5) years.

      2. Records may be stored electronically or in physical form, as per regulatory requirements.

  6. Training and Awareness

    1. Employee Training:

      1. All employees will receive comprehensive training on AML/CFT policies, procedures, and regulatory requirements.

      2. Regular refresher training sessions will be conducted to ensure ongoing awareness and compliance with AML/CFT measures.

  7. Compliance Oversight

    1. Anti-Money Laundering Reporting Officer (AMLO):

      1. Proppal Technologies will designate a qualified individual as the AMLO responsible for overseeing AML/CFT compliance.

      2. The AMLO will receive and investigate reports of suspicious activities, liaise with regulatory authorities, and ensure the implementation of AML/CFT processes and procedures.

  8. Policy Review and Audits

    1. Policy Review:

      1. This AML/CFT policy will be subject to regular reviews to assess its effectiveness and relevance.

      2. Periodic audits will be conducted to evaluate compliance with the policy and identify areas for improvement.

  9. Conclusion

    PropPal Technologies Ltd is committed to maintaining the highest standards of integrity, transparency, and compliance with anti-money laundering and counter-terrorism financing regulations. By adhering to this policy and collaborating with regulatory authorities, we aim to safeguard our operations and contribute to the integrity of the Nigerian real estate technology sector.

    We reserve the right to update this privacy policy at any time so that it always meets the current legal requirements or to implement changes to the services.