Anti-Money Laundering (AML) Policy

1. Introduction

Kigali Estates Limited is committed to preventing money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to ensure compliance with applicable laws and regulations in Rwanda and other jurisdictions where we operate.

2. Legal Framework

Our AML procedures are designed to comply with:

• Rwanda Law No. 47/2018 on Prevention and Punishment of Money Laundering and Financing of Terrorism
• Financial Action Task Force (FATF) Recommendations
• Rwandan Community AML/CFT Guidelines
• Other applicable international standards

3. Customer Due Diligence (CDD)

Identity Verification

We verify the identity of all clients through:

• Government-issued photo identification
• Proof of address documentation
• Source of funds verification
• Beneficial ownership identification

Enhanced Due Diligence (EDD)

Enhanced due diligence is required for:

• High-value transactions (above $10,000 USD)
• Politically Exposed Persons (PEPs)
• Clients from high-risk jurisdictions
• Complex or unusual transaction patterns

4. Transaction Monitoring

We monitor all transactions for suspicious activities, including:

• Unusual payment patterns or methods
• Transactions inconsistent with client profile
• Rapid succession of transactions
• Use of third parties without clear justification
• Cash transactions above regulatory thresholds

5. Suspicious Activity Reporting

All employees are trained to identify and report suspicious activities. When suspicious activity is detected, we will:

• Immediately suspend the transaction
• Conduct additional investigation
• Report to the Financial Intelligence Unit (FIU)
• Maintain detailed records of the investigation

6. Record Keeping

We maintain comprehensive records of all client transactions and due diligence procedures for a minimum of five years from the date of the transaction or relationship termination, as required by law.

7. Training and Awareness

All employees receive regular AML training to ensure they understand their responsibilities and can identify potential money laundering activities. Training covers:

• AML laws and regulations
• Customer due diligence procedures
• Red flags and suspicious activity indicators
• Reporting requirements and procedures

8. Risk Assessment

We conduct regular risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our business activities, clients, and geographic locations.

9. Sanctions Screening

We screen all clients and transactions against international sanctions lists, including those maintained by the United Nations, European Union, and other relevant authorities.

10. Compliance Monitoring

Our compliance function regularly reviews and monitors our AML procedures to ensure effectiveness and regulatory compliance. Independent audits are conducted annually to assess our AML framework.

11. Client Cooperation

We appreciate our clients' cooperation in providing accurate and complete information for due diligence purposes. Failure to provide required information may result in the termination of our services.

12. Contact Information

For questions about our AML procedures, please contact:

13. Policy Updates

This AML Policy is reviewed regularly and updated as necessary to reflect changes in laws, regulations, or business practices. Clients will be notified of material changes.

Last Updated

This Anti-Money Laundering Policy was last updated on January 15, 2025.