Effective Date: April 1, 2025

1. Introduction

DecluttaKing is committed to preventing money laundering and terrorist financing in all its operations. As a business certified by the Economic and Financial Crimes Commission (EFCC) with certificate number SC311300880, DecluttaKing adheres to the provisions of the Money Laundering (Prevention and Prohibition) Act, 2022, and other relevant Nigerian laws, as well as international AML standards. This policy outlines our commitment to detecting, preventing, and reporting suspicious activities to ensure compliance and protect the integrity of our operations.

2. Scope

This AML Policy applies to all employees, contractors, agents, and third parties acting on behalf of DecluttaKing. It covers all transactions, client interactions, and business processes conducted by the company.

3. Objectives

The objectives of this AML Policy are to:

• Prevent DecluttaKing from being used as a conduit for money laundering or terrorist financing.
• Ensure compliance with Nigerian AML laws and regulations, including those enforced by the EFCC.
• Protect DecluttaKing’s reputation and maintain trust with clients, partners, and regulators.
• Promote a culture of vigilance and accountability among employees and stakeholders.

4. Key AML Measures

4.1. Customer Due Diligence (CDD)

DecluttaKing will implement robust CDD procedures to verify the identity of its customers and understand the nature of their transactions. This includes:

• Know Your Customer (KYC): Collecting and verifying customer information, including government-issued identification, proof of address, and, where applicable, source of funds.
• Enhanced Due Diligence (EDD): Conducting additional scrutiny for high-risk customers, such as politically exposed persons (PEPs), clients from high-risk jurisdictions, or those involved in large cash transactions.
• Ongoing Monitoring: Regularly reviewing customer transactions to identify and investigate unusual or suspicious activities.

4.2. Risk Assessment

DecluttaKing will conduct regular risk assessments to identify and mitigate potential money laundering risks associated with its business activities, customers, and geographic locations. High-risk areas will be subject to stricter controls and monitoring.

4.3. Suspicious Activity Reporting

• Employees are required to report any suspicious transactions or activities to the designated AML Compliance Officer immediately.
• DecluttaKing will file Suspicious Activity Reports (SARs) with the Nigerian Financial Intelligence Unit (NFIU) in accordance with the Money Laundering (Prevention and Prohibition) Act, 2022.
• Reports will be submitted promptly when transactions are suspected to involve proceeds of crime, terrorist financing, or other illicit activities.

4.4. Record Keeping

DecluttaKing will maintain accurate and secure records of all customer transactions, KYC/EDD documentation, and SARs for a minimum of five (5) years, as required by Nigerian law. Records will be stored in compliance with data protection regulations and made available to the EFCC or NFIU upon request.

4.5. Training and Awareness

• All employees will undergo mandatory AML training upon onboarding and annually thereafter to ensure awareness of money laundering risks and compliance obligations.
• Training will cover recognizing red flags, reporting procedures, and updates to AML regulations.
• The AML Compliance Officer will oversee training programs and ensure continuous education.

5. AML Compliance Officer

DecluttaKing has appointed a designated AML Compliance Officer responsible for:

• Overseeing the implementation of this AML Policy.
• Serving as the primary point of contact with the EFCC, NFIU, and other regulatory bodies.
• Reviewing and investigating suspicious activities.
• Ensuring compliance with all AML laws and regulations.

6. EFCC Certification

DecluttaKing is proudly certified by the Economic and Financial Crimes Commission (EFCC) with certificate number SC311300880. This certification underscores our commitment to maintaining a robust AML framework and cooperating fully with regulatory authorities to combat financial crimes.

7. Third-Party Relationships

• DecluttaKing will conduct due diligence on all third-party partners, including vendors and service providers, to ensure they comply with AML standards.
• Contracts with third parties will include clauses requiring adherence to AML laws and cooperation with DecluttaKing’s AML procedures.

8. Internal Controls and Audits

• DecluttaKing will implement internal controls to monitor compliance with this AML Policy.
• Regular audits will be conducted to assess the effectiveness of AML measures and identify areas for improvement.
• Audit findings will be reported to senior management and addressed promptly.

10. Sanctions for Non-Compliance

• Failure to comply with this AML Policy may result in disciplinary action, including termination of employment or contracts.
• Non-compliance may also lead to legal or regulatory penalties under Nigerian law.

11. Reporting Channels

Employees and stakeholders are encouraged to report any concerns or suspicious activities to the AML Compliance Officer confidentially. DecluttaKing maintains a whistleblower policy to protect individuals reporting in good faith.

11. Policy Review

This AML Policy will be reviewed annually or as needed to reflect changes in regulatory requirements, business operations, or risk profiles. Updates will be communicated to all employees and relevant stakeholders.

12. Contact Information

For inquiries or to report suspicious activities, contact the AML Compliance Officer at: aml@decluttaking.com

13. Commitment to Compliance

DecluttaKing is fully committed to upholding the highest standards of integrity and compliance. By adhering to this AML Policy and maintaining our EFCC certification (SC311300880), we aim to contribute to a transparent and secure financial ecosystem in Nigeria.