Anti-Money Laundering (AML) Policy

1. Purpose & Scope

1908 Property Management (RC 9713124), operating as Prop Smart Hub, is committed to complying with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws in Nigeria, including the Money Laundering (Prevention and Prohibition) Act and regulations issued by the Special Control Unit Against Money Laundering (SCUML) and the Nigerian Financial Intelligence Unit (NFIU). This policy applies to all estate accounts, transactions, and users on our platform.

2. Customer Due Diligence (CDD)

• We verify the identity of all homeowners, staff, and administrators through FICA documentation (national ID, driver's license, NIN, international passport, or voter's card).
• We collect and verify estate ownership, property assignments, and beneficial ownership details where applicable.
• Enhanced due diligence is performed for high-risk accounts or transactions.

3. Transaction Monitoring

All invoices, payments, and financial transactions on the platform are recorded with full audit trails. We monitor for:

• Unusually large or frequent cash payments.
• Payments that do not match invoiced amounts or expected rent/service charge ranges.
• Suspicious patterns inconsistent with normal estate operations.

4. Reporting Suspicious Activity

Where suspicious transactions are identified, Prop Smart Hub will report them to the Nigerian Financial Intelligence Unit (NFIU) in accordance with applicable law. Internal reports are made to our designated Compliance Officer for assessment and action.

5. Record Keeping

We maintain records of all identity verification documents, transactions, and compliance reports for a minimum of five (5) years, or longer where required by law.

6. Staff Training & Awareness

All staff with access to financial data receive AML training appropriate to their role. Training covers identification of suspicious activity, reporting procedures, and legal obligations.

7. Risk Assessment

We conduct periodic risk assessments to identify and mitigate money laundering and terrorism financing risks associated with our estate management operations, including property types, payment methods, and geographic factors.

8. Compliance Officer

Our designated Compliance Officer is responsible for overseeing this AML policy, conducting reviews, and liaising with regulatory authorities. Contact details are available on the Contact page.