Citiliving AML (Anti-Money Laundering) Policy

1. Purpose

Citiliving is committed to upholding the highest standards of integrity and transparency within the property rental and listing industry. We recognize that engaging with users who may attempt to exploit our platform for illegal activities, such as money laundering, can severely damage the reputation of our company.

The purpose of this User Verification and Anti-Money Laundering (AML) Policy is to outline the principles for detecting and preventing any misuse of Citiliving's platform for illicit activities, particularly money laundering.

2. Application

This policy applies to all employees, directors, contractors, agents, and third-party partners of Citiliving. All individuals and organizations interacting with the Citiliving platform must be aware of and adhere to the guidelines outlined in this policy.

3. Definitions, Acronyms, and Abbreviations

Terms	Definition
Anti-Money Laundering (AML)	Refers to a set of policies and practices to ensure that Citiliving and other regulated entities detect and prevent financial crimes, especially money laundering.
User	An individual or entity engaging with Citiliving to rent, list, or manage properties on the platform.
AML Compliance Officer	The person responsible for ensuring that Citiliving adheres to AML regulations and policies.
Money Laundering	The process of concealing the origins of illegally obtained money, often derived from activities such as fraud, drug trafficking, or corruption, to make it appear legitimate.
Verification	The process of confirming the identity of users and ensuring they comply with all required legal standards before interacting with the platform.
PEPs (Politically Exposed Persons)	Individuals with prominent public functions who may pose a higher risk of involvement in bribery or corruption.
High-Risk Jurisdictions	Countries or regions identified as having weak AML controls or high levels of financial crime.
Suspicious Activity	Any transaction or behavior that appears unusual, inconsistent, or indicative of potential financial crime.

4. Policy Details

4.1. Applicability of AML Obligations

Citiliving must regularly assess whether the nature of its business activities requires compliance with anti-money laundering regulations. This includes reviewing the potential risk of money laundering activities, particularly in relation to property listings and transactions.

4.2. Designated AML Compliance Officer

Citiliving will appoint an AML Compliance Officer who will oversee the company’s efforts to ensure compliance with anti-money laundering regulations. The officer will be responsible for verifying user identities, ensuring adherence to AML procedures, and reporting suspicious activities as needed.

• Ensuring thorough verification of users' identities and documents.
• Providing staff with training on AML policies.
• Reporting any suspicious activities or transactions to the relevant authorities.

4.3. Risk-Based Approach

Citiliving will adopt a risk-based approach to identify and assess potential money laundering risks. Higher-risk users, such as those with multiple accounts, businesses, or transactions from high-risk regions, will be subject to additional scrutiny.

Factors to be assessed include:

• User type: Are they an individual or a company? Are they a high-risk person or entity (e.g., politically exposed persons)?
• Property type: Certain properties, such as high-value or foreign-owned assets, may require extra attention.
• Transaction patterns: Unusual patterns such as frequent or large transactions may trigger additional verification.

4.4. Customer Identification and Verification

Before onboarding a new user (whether a tenant, property manager, or investor), Citiliving will verify their identity. This process involves checking personal and business details against reliable independent sources to ensure the information provided is accurate.

Verification Steps:

• Collect basic personal information such as name, address, and ID verification documents.
• Cross-check the information against reliable third-party sources (e.g., government databases).
• If a user is found to be a politically exposed person (PEP) or presents high-risk attributes, enhanced due diligence measures will be implemented.

4.5. Enhanced Due Diligence

For high-risk users, such as those with complex transactions or foreign involvement, Citiliving will implement enhanced due diligence. This will involve:

• Additional verification of financial resources or income sources.
• Detailed background checks on business affiliations.
• Obtaining approval from the AML Compliance Officer before processing transactions.

4.6. Reporting Suspicious Activities

Citiliving will establish a process for reporting suspicious transactions, such as transactions that appear irregular or above a certain monetary threshold. All employees and partners must be trained to recognize these activities and report them promptly.

Citiliving will:

• Report any suspicious activity to the appropriate authorities, including the Nigerian Financial Intelligence Unit (NFIU), the Central Bank of Nigeria (CBN) and the Securities and Exchange Commission (SEC), as required by law.
• File Suspicious Activity Reports (SARs) promptly and maintain confidentiality in all reporting processes.
• Cooperate fully with law enforcement agencies and regulatory bodies in investigations related to financial crime.

4.7. Training and Awareness

Citiliving will provide regular training to all staff members regarding AML policies and procedures. This ensures that employees are well-equipped to detect potential money laundering activities and comply with regulations.

4.8. Record Keeping

Citiliving will maintain records of:

• Customer identification information.
• Transaction details, including amounts, parties involved, and the nature of the transaction.
• All KYC documentation is securely stored and accessed only by authorized personnel.

4.9. Right to Reject

Citiliving Limited reserves the right to reject any financer, investor, developer, landlord, property manager, host, or other person who intends to carry on real estate business through its website if:

• They fail to provide accurate or complete information during the KYC process.
• They are identified as high-risk or involved in suspicious activity.
• They do not meet Citiliving Limited’s compliance standards or legal requirements.

5. No Warranty on Source of Funds

Citiliving Limited does not, by this AML policy or otherwise, warrant or guarantee the legitimacy, accuracy, or legality of the source of funds or any other information provided by users on its platform. Users are solely responsible for ensuring that their funds and activities comply with applicable laws and regulations.

6. Non-Compliance

Any individual or entity found to be non-compliant with this policy may be subject to disciplinary action. This includes terminating relationships with users who fail to meet verification standards or engaging in suspicious activities.

Initiated by: AML Compliance Officer

Reviewed by: Legal & Compliance Team

Approved by: CEO