KYC (Know Your Customer) Policy

1. Purpose

This Know Your Customer (KYC) policy is established to:

• Verify the identity of clients.

• Mitigate risks related to money laundering, identity theft, and fraud.

• Comply with legal and regulatory obligations.

2. Scope

This KYC policy applies to all clients and entities engaging with our services, including both individual and corporate clients.

3. Objectives

The objectives of this KYC policy are to:

• Identify and verify customers before they access our products or services.

• Monitor client activities to detect and report any suspicious behavior.

• Maintain records to support ongoing compliance.

4. Customer Identification Process (CIP)

To ensure accurate identification of each client, we require the following:

For Individual Clients:

• Full Legal Name: Must match legal documents.

• Date of Birth: To confirm age and identity.

• National Identification: Passport, Driver’s License, or National ID.

• Residential Address: Proof of address (utility bill, bank statement).

• Contact Information: Phone number and email address.

• Photograph: For identity verification purposes.

For Corporate Clients:

• Business Name and Address: Registered name and physical address.

• Tax Identification Number (TIN): Or equivalent business registration ID.

• Incorporation Documents: Registration certificate, Articles of Incorporation.

• Directors and Shareholders: List of primary stakeholders.

• Authorized Signatories and Beneficial Owners: Identification of persons who have control over the account or funds.

5. Customer Due Diligence (CDD)

• Standard CDD: Conducted on all clients to verify identity and gather necessary documentation.

• Enhanced Due Diligence (EDD): For high-risk clients, including those with large transactions, non-local clients, and politically exposed persons (PEPs). Additional documentation and scrutiny may be required.

6. Risk Assessment

Each client will be assigned a risk level based on factors such as:

• Geographic location.

• Type and volume of transactions.

• Relationship with high-risk industries.

Risk Levels:

• Low Risk: Verified clients with minimal risk factors.

• Medium Risk: Clients with a few elevated risk indicators.

• High Risk: Clients with notable risk indicators; subject to additional scrutiny.

7. Ongoing Monitoring

• Monitor customer activity continuously to detect unusual behavior.

• Investigate and escalate flagged transactions or clients as appropriate.

• Update client information periodically to maintain current records.

8. Record-Keeping

• Maintain records of all identification documents, customer profiles, and transaction histories for at least five years.

• Store and protect records in a secure, easily accessible format for auditing and regulatory review.

9. Compliance and Reporting

• Train employees on KYC obligations and risk management practices.

• Report suspicious activities to relevant authorities in compliance with legal requirements.

• Cooperate with law enforcement and regulatory agencies as necessary.

10. Data Privacy and Security

• Ensure the confidentiality and security of all customer data.

• Protect data in accordance with applicable data protection regulations.

11. Policy Review

• This policy will be reviewed and updated regularly to align with regulatory changes, business needs, and best practices.