AML Policy

Our AML Policy consist of the following elements described below: Kunzle AML Policy Reporting Training Risk Mitigation Risk identification and assessment Each element of our AML Policy is described below.

The identification and assessment of Kunzle’s AML risk As Kunzle conducts its business mainly over the internet and is currently focused on the one-way transfer of funds from the UK to Nigeria, the Board has identified the following AML risks listed in the table below: I. Fraud risk Kunzle’sfraud risk includes the following: ▪ Use of stolen credit and/or debit cards As transactions are conducted over the internet through card payments, there is the risk that a customer may want to transfer funds to Nigeria through fraudulently obtained credit or debit card. ▪ Impersonation i.e. the use of false identity documents There is the risk that some customers might attempt to use false identity documents e.g. passport to access the Kunzle service II. Facilitating the transfer of proceeds of crime from UK to Nigeria and vice versa These risks arise from the fact that Kunzle services enables UK customers to transfer £ from the UK to Nigeria whilst enabling the transfer of Naira out of Nigeria. There is the risk that criminals could use our services, in the absence of checks and vigilance, to facilitate the transfer of proceeds of crime out of the UK and /or Nigeria. III. Inadequate due diligence on customers resulting in the non-identification of Politically Exposed Persons and/or individuals on sanctions list. Due to the online nature of Kunzle's business, there is the risk that inadequate due diligence will be undertaken on its customers in the UK. Unlike traditional face-to-face business, where customers are physically present and originals of ID documents can be obtained, the online nature of our business does not enable us to undertake customer due diligence in the same way. IV. Dealing with non-authorised counterparties in Nigeria Kunzle meets its Naira obligations to its customers by obtaining Naira from counterparties based in Nigeria. In Nigeria, the sale and transfer of Naira and foreign currencies are controlled by the Central Bank of Nigeria. However, Kunzle may not be conversant with Nigeria’s foreign exchange regulation(s) and as a result it could end up sourcing Naira from an unauthorised source, thus inadvertently facilitating money laundering.