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Anti-Money Laundering (AML) Policy

Last updated on September 1, 2025

1. Policy Statement

Clea, a product of Autoclear Inc., is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We recognize our responsibilities under applicable laws and regulations in the jurisdictions where we operate, including but not limited to the Bank Secrecy Act (BSA) and USA PATRIOT Act, and are committed to preventing our platform from being used for money laundering, terrorist financing, or other financial crimes.

2. Objectives

  • Prevent, detect, and report any suspicious activities that may be indicative of money laundering or terrorist financing.

  • Ensure that all users are properly identified and verified (Know Your Customer – KYC).

  • Comply with all applicable AML/CTF laws and regulatory frameworks in the United States and across Africa where our users operate.

  • Provide adequate training and tools to team members responsible for AML compliance.

3. Scope of Application

This policy applies to:

  • All users of the Clea platform, both individuals and businesses.

  • All Clea employees, agents, partners, and stakeholders involved in onboarding, transaction monitoring, and compliance.

  • All activities on the platform, including funding in local currencies, conversion to USD, and cross-border disbursements to suppliers, auction houses, and shippers.

4. Know Your Customer (KYC) and Customer Due Diligence (CDD)

Clea requires all users to complete full KYC before being permitted to conduct any financial transactions. This includes:

  • Individuals: Government-issued ID, proof of address, and selfie verification.

  • Businesses: Business registration documents, proof of ownership/directorship, and authorization to transact.

KYC and verification are powered by third-party services that meet global compliance standards. All user data is encrypted and stored securely.

5. Monitoring and Risk Assessment

Clea implements a risk-based approach to monitor user activities:

  • Real-time monitoring of all transactions to detect suspicious patterns (e.g., unusually high frequency, rapid movement of funds, or blacklisted destinations).

  • Tiered user levels with specific transaction limits and review thresholds.

  • Flagging and manual review of transactions that exceed predefined limits or match suspicious behavior profiles.

6. Record Keeping

We maintain comprehensive records of all user verifications, transactions, and AML reviews for a minimum of 5 years, as required by law. These may be shared with regulators upon request or in compliance with legal obligations.

7. Reporting Suspicious Activities

All suspicious activities will be reported to the appropriate regulatory bodies such as:

  • FinCEN in the United States,

  • EFCC in Nigeria

  • Local financial intelligence units (FIUs) in African jurisdictions where users operate.

The Compliance Officer is responsible for reviewing internal reports and determining whether to escalate or file a Suspicious Activity Report (SAR).

8. Compliance

Our compliance team oversee AML program implementation.

  • Ensuring KYC/AML procedures are enforced across all levels.

  • Monitoring transactions and reviewing red flags.

  • Conducting compliance training for staff.

  • Acting as a liaison with regulatory authorities.

9. Staff Training

All team members involved in compliance, onboarding, or payment processing receive regular training to:

  • Identify and escalate suspicious activity.

  • Stay current with regulatory updates and emerging risks.

  • Understand and follow internal procedures for AML compliance.

10. Policy Review

This AML Policy is reviewed at least once annually or whenever there are changes in applicable laws or the nature of Clea’s operations.