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AML Compliance Statement

Last updated: June 2026

Draft / placeholder. This statement is provided for information only and is awaiting final review by legal counsel. It does not constitute legal advice.
01

Our commitment

Abanzuri is committed to preventing money laundering and the financing of illicit activity through any transaction we facilitate. We apply controls proportionate to the risk presented by each client, property, and transaction, and we co-operate fully with the relevant authorities. [PLACEHOLDER — confirm regulatory references with counsel.]

02

Know Your Customer (KYC)

Before progressing a transaction, we verify the identity of buyers, sellers, and their representatives. This typically includes a valid government ID (National ID or passport), KRA PIN, proof of address, and, for companies, registration and beneficial-ownership documents. We may decline to proceed where verification cannot be completed. [PLACEHOLDER — confirm document set with counsel.]

03

Source of funds

For purchase transactions, we conduct source-of-funds and, where appropriate, source-of-wealth checks. Clients may be asked to evidence the origin of funds (e.g. bank statements, sale agreements, employment or business records) before completion. [PLACEHOLDER — confirm thresholds and evidence requirements.]

04

Risk-based due diligence

We assess each engagement on a risk basis. Higher-risk situations — including politically exposed persons (PEPs), unusual structures, cash-intensive arrangements, or third-party payments — trigger enhanced due diligence and senior sign-off. [PLACEHOLDER — confirm EDD triggers.]

05

Reporting obligations

Where we know or suspect that funds are the proceeds of crime, or that a transaction is connected to money laundering, we are obliged to make a report to the Financial Reporting Centre (FRC) and to take no action that could prejudice an investigation. We do not disclose ("tip off") that a report has been or may be made. [PLACEHOLDER — confirm reporting channel and timelines.]

06

Record keeping

We retain identification, transaction, and due-diligence records for the period required by law (currently understood to be at least seven years from the end of the business relationship or transaction). [PLACEHOLDER — confirm retention period.]

07

Training & governance

Our team receives periodic AML awareness training, and a designated compliance officer oversees our policies, monitoring, and reporting. [PLACEHOLDER — name the Money Laundering Reporting Officer / contact.]

08

Contact

Questions about our AML programme can be directed to hello@abanzuri.com. This statement will be updated as our obligations evolve. [PLACEHOLDER — confirm compliance contact.]