Anti-Money Laundering (AML) Policy

At PROPERTIESLIBERIA.COM, LTD., we take financial integrity seriously. As a company operating in the real estate and property services space, we understand that we have a responsibility to prevent our platform from being misused for illegal activities like money laundering or terrorist financing.

This Anti-Money Laundering (AML) Policy outlines the steps we take to protect our business, our customers, and the financial system from being exploited by bad actors. Our goal is to create a secure and trustworthy environment for all users, whether they're property owners, buyers, renters, or partners.

We are committed to complying with all applicable AML laws in Liberia, as well as aligning ourselves with international best practices. This includes verifying our users, monitoring activity on the platform, and reporting anything suspicious to the relevant authorities when required.

By having this policy in place, we're not just checking a box—we're doing our part to ensure transparency, accountability, and security across everything we do.

This AML Policy applies to everyone who interacts with the PROPERTIESLIBERIA.COM, LTD. platform in a meaningful way. That includes:

• All individual users who register to search or pay for property listings
• Real estate agents, brokers, or businesses using our services to advertise or manage properties
• Internal staff and administrators handling customer verification and payment oversight
• Any third-party partners or service providers involved in payments or user onboarding

Whether someone is making a one-time payment or using our services regularly, the same basic AML principles apply. We expect all users to follow this policy and cooperate with any reasonable requests for verification, clarification, or investigation related to compliance with anti-money laundering regulations.

This policy covers activity on our website, mobile platforms, and any future payment channels we introduce, including integrations with providers like MTN Mobile Money or Orange Money.

Our scope may expand over time as we grow, but our commitment to transparency and due diligence will remain consistent.

PROPERTIESLIBERIA.COM, LTD. operates in full alignment with the laws of the Republic of Liberia and follows key international standards for preventing money laundering and terrorist financing.

In particular, we recognize and follow guidance from:

• Liberian AML regulations, including any rules set by the Central Bank of Liberia or the Financial Intelligence Unit (FIU)
• International standards from the Financial Action Task Force (FATF), which sets the global framework for AML compliance
• Partner requirements, such as those from Lonestar Cell MTN Mobile Money Inc., that ensure we meet the same AML expectations expected of licensed financial institutions

While we're not a bank or financial institution, we process payments through our platform — and that comes with responsibility. So even though some regulations may not legally mandate our level of compliance, we choose to implement these standards because it's the right thing to do.

By staying proactive and aligning with both local and international laws, we protect our business and give our users peace of mind.

Before any user can make a payment or engage meaningfully on our platform, we verify who they are. This isn't just about ticking boxes — it's about protecting the platform and everyone on it from fraud and abuse.

We collect key information from users such as:

• Full name
• Mobile number and email address
• Government-issued ID (for individuals)
• Business registration or license (for corporate users)

We use this information to confirm that the user is a real person or legitimate business with valid intent. We store this data securely and only use it for compliance and verification purposes.

We also perform basic risk assessments — especially for large transactions or unusual behavior — and we reserve the right to ask for additional documents or clarification if needed.

For returning users, we may occasionally request updates to their details, especially if something changes (e.g., phone number, business status, or flagged activity).

We take extra caution when it comes to dealing with Politically Exposed Persons (PEPs). These are individuals who hold or have held prominent public positions, or those closely related to them, such as family members or business associates.

During sign-up or onboarding, we ask all users to declare whether they are a PEP. If someone identifies as a PEP, we flag the account for manual review and assess the level of risk. Depending on the outcome, we may request further verification or escalate the case to our payment partner (like MTN Mobile Money) before allowing access to our services.

This step is not about discrimination — it's about ensuring the platform isn't used to move money inappropriately or to conceal the source of funds.

Note: A full breakdown of our PEP procedures is detailed in a separate PEP Policy document.

To protect our platform from being used for unlawful transactions, we screen all users and payments against global sanctions lists. These include:

• United Nations Security Council (UNSC) Consolidated List
• U.S. OFAC Sanctions Lists (e.g., Specially Designated Nationals – SDN)
• European Union Sanctions List
• UK Sanctions List (OFSI)
• Australian DFAT Consolidated List
• FATF list of high-risk and non-cooperative jurisdictions

We don't allow any business or individual linked to a sanctioned country, group, or person to use our platform. If a user matches a known sanctions list or their activity appears connected to a high-risk jurisdiction, we'll block the account and notify relevant parties if needed.

This is non-negotiable — compliance here helps us keep the platform clean and safe.

We do not allow shell companies or anonymous legal entities to operate on our platform. A shell company is typically an entity that exists only on paper, has no active operations, and is often used to hide ownership or move money without transparency.

To open a business account on PropertiesLiberia.com, companies must:

• Provide proof of legal registration
• Demonstrate active operations (such as a website, service documentation, or online presence)
• Disclose the names of all beneficial owners — those who ultimately own or control the business

If we believe a business is a front or cannot clearly prove who is behind it, we will deny access. We're building a real platform for real people — not a playground for anonymous money movement.

We actively monitor transactions and user behavior for anything unusual or suspicious. This includes:

• Sudden large payments that don't match normal activity
• Use of multiple accounts by the same person
• Patterns that mimic fraud or money laundering tactics

When something doesn't look right, we flag the account internally and investigate. If the situation is serious or involves clear red flags (like fraud, identity mismatch, or sanction list matches), we escalate it and may report it to relevant authorities or to our payment provider for further action.

We don't need to wait for something to go wrong — we act early to keep the system safe for everyone.

We keep detailed records of our KYC verifications, customer declarations, and any suspicious activity reports. These records are stored securely and retained for a minimum of 5 years after the end of the user relationship or transaction.

Records may include:

• ID documents
• Business verification records
• User declarations (e.g., PEP status)
• Notes from manual reviews or investigations

This helps us comply with the law, defend our decisions, and support investigations if needed.

Even though we run a digital platform, our team understands the importance of staying alert to financial risks. Anyone involved in onboarding, reviewing, or handling user data gets basic training on AML risks and how to spot red flags.

Our goal is to make sure everyone in the business knows what to look for — and knows that they have the support to act if something feels wrong.

Training is refreshed annually, and as new risks emerge, we keep our procedures updated to match.

To keep our AML processes effective and trustworthy, we've put internal controls in place. These include:

• Manual reviews for flagged users or transactions
• Cross-checking user data with known risk indicators
• Clear documentation of every compliance-related decision
• Escalation processes when higher-level approval is needed

We also perform internal audits of our AML procedures on a regular basis. This helps us catch gaps, update our approach, and make sure we're always improving how we detect and prevent suspicious activity.

Even as a growing business, we're committed to acting with the same discipline and oversight expected of much larger organizations.

We review this AML Policy at least once every 12 months — or sooner if the law changes, new risks arise, or we expand our services.

We take AML compliance seriously, and if you have any questions, concerns, or need to report suspicious activity, you can contact us directly at:

We reserve the right to update this policy as our business evolves and our risk landscape changes.