AML and sanctions

1. Purpose

This policy states the anti-money laundering, counter-terrorist financing, and sanctions program of Clive Alliance for Lenz. It is effective 19 October 2026 and is part of the Terms of Service. It applies to every workspace and every account. Clive Alliance LLC is responsible for the program as it applies to US dollar accounts provided by Column N.A. Clive Alliance is responsible for the program as it applies to naira accounts.

Lenz is not a bank. The program is ours. Column N.A. and the Nigerian banking partner have their own obligations, which this policy does not replace. We cooperate with them and we answer their requests for information about a customer.

2. Governance

Clive Alliance LLC designates a BSA/AML Officer for the US dollar program. The Officer reports to the managing member, is not paid on the volume of accounts opened, and has authority to decline an application, to restrict an account, to refuse a payment, and to close a relationship. Customers and banking partners reach the compliance function at compliance@lenzfinance.com. The Officer’s name is given to Column N.A. and to regulators. It is not published here, so that a customer cannot route around the function.

No production US dollar account is opened unless the Officer is in seat, this policy is in force, and the controls in sections 4, 5, and 6 are operating for that account. Naira accounts are already subject to the verification, screening, and reporting controls below.

The program is reviewed at least once a year, and an independent review of the US dollar program is commissioned before production accounts are opened and annually after that. A material weakness found in a review is closed before new US dollar accounts are opened.

3. Risk appetite

Lenz serves operating companies whose business we can understand and whose owners we can identify. We do not serve the businesses listed in the Acceptable Use Policy. We do not onboard a customer whose activity we cannot explain, whose owners are hidden behind companies we cannot look through, or whose expected payments do not match the business it described.

Countries subject to comprehensive sanctions, and countries that the Financial Action Task Force calls on members to apply countermeasures to, are outside our appetite. Countries the Financial Action Task Force lists for increased monitoring are higher risk and require a recorded reason before we approve a customer that deals with them.

4. Customer due diligence

The information we collect, and the checks we run before approval, are set out in the Business verification policy. In summary we identify the company, every director, every signatory, and every beneficial owner at 5 percent or more, and we will not approve an account while any of those checks is outstanding.

We score each application. The score considers the industry, the countries of activity, whether ownership is transparent, sanctions and politically exposed person results, adverse media, and whether a newly formed company expects high volume. A high-risk file requires enhanced due diligence before approval: a source-of-wealth explanation, a site visit or a video meeting that is written up, and approval by a compliance officer or a supervisor. The person who recommends approval cannot be the person who gives it.

A customer is reviewed again on a cycle: every year if high risk, every two years if medium risk, and every three years if low risk. A change of ownership, a sanctions hit, or activity that does not match what the customer declared brings the review forward.

5. Screening

Before approval, and again on a rolling basis while the account is open, we screen the company, its directors, its signatories, and its beneficial owners against:

• the Specially Designated Nationals and Blocked Persons list, and the other sanctions lists administered by the Office of Foreign Assets Control;
• United Nations, European Union, and United Kingdom sanctions lists;
• Nigerian sanctions lists;
• politically exposed person lists; and
• adverse media.

Screening is performed through Dojah and recorded with the list, the match, and the decision. A potential match opens an internal case. The customer is not told that a match exists. A match is cleared only as a false positive with a written reason, or confirmed. A confirmed sanctions match is a mandatory rejection or, if the account is already open, a block and a report. It cannot be approved.

For a US dollar payment, the payee is screened before the payment is released, and the originator of an incoming payment is screened when the payment arrives. A hit stops the payment until the case is decided.

6. Monitoring and reporting

We monitor activity against the business and the volumes the customer declared. We review activity that is inconsistent with that declaration, activity involving a higher-risk country, payments that move through the account without a commercial purpose we can see, and changes to a payee’s account details. Separate from that review, a changed payee account and a duplicate payout are held inside the product until a named person at the customer confirms them.

An analyst records the disposition of an alert: closed with a reason, or escalated. Where the law requires, we file a suspicious transaction report with the Nigerian Financial Intelligence Unit, and, for the US dollar program, a suspicious activity report with FinCEN. We also refer the matter to the banking partner that holds the account. We do not inform the customer that a report has been filed, and staff are forbidden from doing so.

Currency transaction reports are filed where the law sets a threshold for a reportable transaction. Lenz does not accept cash. A threshold that applies to a non-cash transaction is applied as the statute writes it.

US dollar transaction monitoring, payee screening, and FinCEN reporting are conditions of opening a production Column account. They are operated for every such account from the day it is opened.

7. Holds and exits

We may delay or refuse a payment, restrict an account, or exit a customer where this policy, a partner, or the law requires it. The customer sees the restriction and the next action available to them, unless telling them would itself be unlawful. Funds that are blocked under sanctions are handled as the relevant sanctions authority directs and are not returned to the customer on request.

8. Training and records

Everyone who onboards customers, reviews alerts, or can approve an account is trained on this policy before they do that work, and retrained at least annually. Training is recorded.

We keep customer due diligence, screening decisions, alerts, reports, and the supporting records for at least five years after the account is closed or the report is filed, whichever is later. Records are available to Column N.A., to the Nigerian banking partner, and to the authorities entitled to them.

9. Questions

Customers write to compliance@lenzfinance.com. A question about a specific payment is a support matter and can also be sent to complaints@lenzfinance.com. We will not confirm or deny that a person is the subject of a report.