AML/KYC Policy

1. Policy Overview

PropertyHandle Africa (Pvt) Ltd is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures for customer identification, verification, and ongoing monitoring.

2. Know Your Customer (KYC) Requirements

2.1 Individual Investors

All individual investors must provide:

• Identity Document: Valid passport or National ID (Zimbabwe ID preferred)
• Proof of Address: Utility bill, bank statement, or government letter (dated within 3 months)
• Selfie Verification: Live photo for biometric matching
• Source of Funds Declaration: For investments above $10,000

2.2 Corporate Investors

Corporate entities must additionally provide:

• Certificate of Incorporation (CR14)
• Memorandum and Articles of Association
• Board Resolution authorizing investment
• Identity documents for all directors and beneficial owners (>25% ownership)
• Company bank statement

2.3 Enhanced Due Diligence

Enhanced verification is required for:

• Politically Exposed Persons (PEPs) and their associates
• Investments exceeding $50,000
• High-risk jurisdictions (as per FATF grey/blacklist)
• Complex ownership structures

3. Verification Process

3.1 Identity Verification

We use automated and manual verification processes:

1. Document Upload: User uploads ID and proof of address
2. Automated Checks: Document authenticity verification, face matching
3. Sanctions Screening: Check against global sanctions and PEP lists
4. Manual Review: Compliance team review for flagged cases
5. Approval/Rejection: User notified within 24-48 hours

3.2 Verification Tiers

4. Transaction Monitoring

We continuously monitor transactions for suspicious activity including:

• Unusual transaction patterns or volumes
• Rapid movement of funds in and out
• Transactions inconsistent with stated source of funds
• Structuring (breaking transactions to avoid thresholds)
• Transactions involving high-risk jurisdictions

Suspicious transactions are escalated to our Compliance Officer and may be reported to the Financial Intelligence Unit (FIU) of Zimbabwe as required by law.

5. Prohibited Activities

The following are strictly prohibited on our platform:

• Using false or fraudulent identity documents
• Investing proceeds of crime or illegal activities
• Using the platform for money laundering or terrorist financing
• Circumventing KYC requirements through third parties
• Opening accounts on behalf of sanctioned individuals or entities

6. Record Keeping

In accordance with regulatory requirements, we maintain:

• KYC documents for 5 years after account closure
• Transaction records for 10 years
• Suspicious activity reports indefinitely
• Correspondence related to compliance matters

7. SECZ Compliance

PropertyHandle Africa operates under the regulatory oversight of the Securities and Exchange Commission of Zimbabwe (SECZ). We adhere to:

• SECZ licensing requirements for securities intermediaries
• Investor protection guidelines
• Disclosure and transparency requirements
• Regular regulatory reporting obligations

8. Reporting Obligations

We are obligated to report:

• Suspicious Transaction Reports (STRs) to the FIU
• Cash Transaction Reports above prescribed thresholds
• Quarterly compliance reports to SECZ
• Annual AML audit findings

9. Contact

For compliance-related inquiries:

• Compliance Officer: legal@propertyhandleafrica.com
• Phone: +263 778 132 080 / +263 771 339 140
• Address: Eight2Five Innovation Hub, Three Anchor House, 54 Jason Moyo Avenue, Harare, Zimbabwe