Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last updated: January 07, 2026

Effective Date: January 1, 2025

1. Purpose and Scope

This policy outlines RentQuarters' approach to:

• Preventing the use of our platform for money laundering activities
• Detecting and reporting suspicious transactions
• Verifying the identity of our users (KYC)
• Maintaining records in compliance with regulatory requirements
• Ensuring our services are not used for terrorism financing

This policy applies to all RentQuarters users, employees, and third-party service providers.

2. Regulatory Framework

Our AML/KYC program is designed to comply with:

• Money Laundering (Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• Central Bank of Nigeria (CBN) Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Regulations
• Nigeria Financial Intelligence Unit (NFIU) Guidelines
• Financial Action Task Force (FATF) Recommendations
• Economic and Financial Crimes Commission (EFCC) Regulations

3. Know Your Customer (KYC) Requirements

3.1 Customer Identification Program

All users must provide the following information during registration:

• Full legal name
• Date of birth
• Phone number (verified via OTP)
• Email address (verified)
• Residential address

3.2 Enhanced Due Diligence (EDD)

For users accessing financial services (wallet, payments, withdrawals), additional verification is required:

3.3 Ongoing Monitoring

We continuously monitor user accounts and transactions for:

• Changes in user risk profile
• Unusual transaction patterns
• Inconsistencies with expected behavior
• Updates to sanctions lists and watchlists

4. Transaction Monitoring

4.1 Automated Monitoring

We employ automated systems to monitor transactions for suspicious activity, including:

• Transactions that exceed normal thresholds
• Unusual frequency of transactions
• Transactions inconsistent with user profile
• Multiple accounts linked to same identifiers
• Rapid movement of funds through accounts

4.2 Red Flag Indicators

The following activities are considered red flags and may trigger additional review:

• Large cash payments for property rentals
• Frequent changes to bank account details
• Use of multiple payment methods for single transaction
• Transactions involving high-risk jurisdictions
• Reluctance to provide required documentation
• Discrepancies in information provided
• Transactions structured to avoid reporting thresholds
• Properties with unusually high or low rental values

5. Suspicious Activity Reporting

In accordance with Nigerian law, we are required to report suspicious transactions to the Nigeria Financial Intelligence Unit (NFIU).

5.1 Reporting Obligations

• Suspicious Transaction Reports (STRs) are filed for transactions that appear suspicious
• Currency Transaction Reports (CTRs) are filed for cash transactions above the reporting threshold
• Reports are filed within the timeframes required by law

5.2 Confidentiality

It is a criminal offense to "tip off" individuals about suspicious activity reports. We are prohibited from informing users that a report has been filed about their activity.

6. Risk-Based Approach

We apply a risk-based approach to AML/KYC, with higher scrutiny for:

6.1 High-Risk Categories

• Politically Exposed Persons (PEPs)
• Users from high-risk jurisdictions
• Users with complex ownership structures
• High-value transactions
• Users who have been subject to previous suspicious activity

6.2 Enhanced Measures

For high-risk users, we may:

• Request additional documentation
• Conduct more frequent reviews
• Require senior management approval for transactions
• Limit transaction amounts or types
• Refuse to establish or maintain the relationship

7. Sanctions Screening

We screen all users against relevant sanctions lists, including:

• United Nations Security Council Consolidated List
• OFAC (Office of Foreign Assets Control) Sanctions List
• EFCC Watch List
• Interpol Wanted List
• Nigerian national sanctions lists

Users who appear on sanctions lists are prohibited from using our platform.

8. Record Keeping

In compliance with Nigerian law, we maintain records for the following periods:

• Customer identification records: Minimum 7 years after the relationship ends
• Transaction records: Minimum 7 years from the date of transaction
• Suspicious activity reports: Minimum 7 years from the date of report
• Staff training records: Minimum 5 years

9. User Obligations

By using RentQuarters, you agree to:

• Provide accurate and up-to-date information
• Complete required verification processes
• Use the platform only for legitimate purposes
• Not use the platform to launder money or finance terrorism
• Report any suspicious activity you observe
• Cooperate with any investigations

10. Account Restrictions

We may restrict or terminate accounts if:

• User fails to complete required verification
• Information provided is found to be false
• Suspicious activity is detected
• User appears on a sanctions list
• User refuses to cooperate with investigations
• Required by law enforcement or regulatory authorities

11. Staff Training

All RentQuarters employees receive regular training on:

• AML/CFT laws and regulations
• Red flag indicators
• KYC procedures
• Reporting requirements
• Record-keeping obligations

12. Compliance Officer

Our Chief Compliance Officer is responsible for:

• Overseeing the AML/KYC program
• Ensuring compliance with applicable laws
• Filing required reports
• Liaising with regulatory authorities
• Conducting internal audits

13. Reporting Suspicious Activity

If you suspect money laundering or other financial crimes on our platform, please report it:

• Email: compliance@rentquarters.app
• Phone: +234 802 471 7179

Reports may also be made anonymously. We will not retaliate against anyone who reports suspected violations in good faith.

14. Updates to This Policy

This policy is reviewed and updated regularly to reflect changes in laws, regulations, and best practices. Users will be notified of significant changes.

15. Contact Information

For questions about this AML/KYC Policy:

• Compliance Team: compliance@rentquarters.app
• General Inquiries: support@rentquarters.app
• Address: Enugu, Nigeria