Anti-Money Laundering (AML) and Know Your Customer (KYC) & Customer Due Diligence (CDD)

Introduction

Evergreen Estate Management Limited (EEM) is fully committed to complying with Ghana’s Anti-Money Laundering Act, 2008 (Act 749) as amended, the Anti-Terrorism Act, 2008 (Act 762), and all related regulatory requirements, as well as international standards set by the Financial Action Task Force (FATF).

We recognise that real estate transactions can be targeted by criminals to launder illicit funds or finance terrorism. This policy sets out EEM’s framework for preventing such abuse by implementing robust Anti-Money Laundering (AML) and Know Your Customer (KYC) & Customer Due Diligence (CDD) measures.

Our aim is to:

• Protect our business, clients, and stakeholders.

• Prevent criminal use of EEM’s services.

• Maintain the integrity of Ghana’s financial and property sectors.

1. Policy Statement

EEM maintains a zero-tolerance approach to money laundering, terrorist financing, and all other forms of financial crime.
We are committed to:

• Conducting appropriate checks before entering any business relationship.

• Monitoring transactions and reporting suspicious activities.

• Training our staff to identify and mitigate AML/CTF risks.

2. Scope

This policy applies to:

• All EEM employees, officers, and directors.

• Agents, brokers, consultants, and contractors representing EEM.

• All clients, vendors, and business partners engaged in real estate transactions, property management, or related financial activities.

3. Key AML and KYC/CDD Measures

3.1 Customer Due Diligence (CDD)

Before establishing a business relationship or completing a transaction, EEM will:

• Identify and verify the identity of all clients.

• For individuals – Obtain full name, date of birth, residential address, nationality, and valid photo identification (passport, Ghana Card, driver’s licence, etc.).

• For corporate entities – Verify legal status, business registration, beneficial ownership, and identity of directors.

• Keep copies of all identification documents for at least six (6) years.

3.2 Enhanced Due Diligence (EDD)

EEM applies stricter checks where the risk of money laundering or terrorist financing is higher, such as:

• Politically Exposed Persons (PEPs) and their associates.

• Clients from high-risk jurisdictions (as defined by FATF or Ghana’s Financial Intelligence Centre).

• Complex ownership structures that obscure the true owner.

• Large or unusual property transactions without clear economic justification.

EDD may include:

• Additional identity verification steps.

• Source of funds and wealth verification.

• Senior management approval before proceeding.

3.3 Ongoing Monitoring

• Review all transactions to ensure they match the client’s profile.

• Flag and investigate unusual payment methods (e.g., large cash payments, cryptocurrency, or third-party transfers).

• Conduct periodic client profile updates, particularly for long-term relationships.

4. Record-Keeping

EEM will maintain accurate and secure records of:

• Client identification and verification documents.

• Transaction history and communications.

• Internal reports of suspicious activity.
  Records will be kept for a minimum of six (6) years in accordance with Ghanaian law.

5. Suspicious Transaction Reporting

• Any staff member who identifies a suspicious transaction must immediately report it to the EEM AML Compliance Officer.

• The Compliance Officer will assess the report and, if necessary, submit a Suspicious Transaction Report (STR) to the Financial Intelligence Centre (FIC).

• Tipping-off (informing a client or third party about an STR) is strictly prohibited.

6. Roles and Responsibilities

Board of Directors – Provide oversight and ensure AML/KYC compliance is embedded in corporate governance.
AML Compliance Officer –

• Implement this policy.

• Serve as point of contact with the FIC.

• Conduct risk assessments, audits, and staff training.
  Employees & Agents –

• Follow all AML/KYC procedures.

• Immediately report suspicious activities.

7. Risk Assessment

EEM conducts regular AML/KYC risk assessments, evaluating:

• Customer profile and business nature.

• Geographic risk.

• Transaction type and value.

• Delivery channels (in-person, online, third-party intermediaries).

8. Training and Awareness

• All staff will receive AML/KYC training upon joining and periodically thereafter.

• Training will cover recognising suspicious behaviour, applying CDD and EDD, and complying with record-keeping obligations.

9. Disciplinary Measures

Failure to comply with this policy may result in:

• Disciplinary action up to and including termination of employment.

• Legal consequences under Ghanaian law.

10. Compliance Monitoring

This policy will be reviewed annually and updated in line with legal, regulatory, and industry developments.

Contact Information

Evergreen Estate Management (EEM)
Company: Evergreen Estate Management Limited
Website: evergreenestatesmanagement.com
Email: info@evergreenestatesmanagement.com
Office Phone: +233 54 804 4340
Address (GH): Flower Street, Tabora Number 2, Adebreka, Accra, Ghana.
Director: Vincent Santeng