KNOW YOUR CUSTOMER (KYC)

This Know Your Customer Policy (hereinafter referred to as” Policy”) establishes the framework and procedures for [INSERT COMPANY NAME] to verify customer identities, including document verification and periodic reviews.

1. PURPOSE
   1. The Purpose of this policy is to establish a systematic framework to verify accurate customer identities, associated risks and maintain compliance with relevant regulatory authorities. This policy aims to ensure the integrity of customer relationships, mitigate potential risks, and upholds the highest standards of transparency and legal compliance in business operations.
2. SCOPE
   1. This policy applies to all employees, contractors or any individual facing customer operations such as account opening, transaction processing and any ongoing customer relationships within the Company.
3. CUSTOMER DUE DILIGENCE(CCD)
   1. Our Company will conduct CCD procedures, to assess and manage risks associated with our customers. Our Company will identify all customers before establishing a business relationship or conducting any transactions with the customers. This includes individuals, legal entities, and beneficial owners.
   2. We will verify the identity of customers using reliable and independent sources of information, which may include government-issued identification documents, official databases, or other trusted sources.
   3. We will continuously monitor customer transactions and activities to ensure they align with their established profiles and business relationships. Any discrepancies or unusual patterns will be investigated promptly and reported in accordance with our KYC policy.
   4. All CDD documentation, including customer identification records and verification results, will be maintained securely and retained as per regulatory requirements.
4. ONGOING MONITORING
   1. Our Company will periodically review customer information to ensure it remains current and accurate.
   2. Our Company will implement periodic assessments of customer risk profiles based on evolving business transactions and activities.
   3. The Risk Management team will monitor regular updates and conduct Risk Assessments to mitigate those risks.
5. REPORTING SUSPICIOUS ACTIVIES
   1. All Employees have a responsibility to promptly report any suspicious activities they encounter or become aware of during the course of their duties, to the designated KYC compliance officer.
   2. The KYC Compliance officer will investigate the reported activity to determine if they warrant further action, including filing suspicious activity with the appropriate authorities.
   3. All Suspicious Activity reports and related information will be kept confidential to the extent required by law and used solely for the required purposes.
   4. The Company will take reasonable measures to protect employees involved in reporting suspicious activities from potential threats or retaliation.
6. RECORD-KEEPING
   1. All information collected during KYC and CDD, including customer identification records and monitoring records will be maintained securely and retained in accordance with regulatory requirements.
   2. Confidential information should only be collected for specific, legitimate purposes and should not be used or disclosed for other purposes without obtaining consent, unless required by law.
   3. Access to personal information during KYC and CDD should be restricted to authorized personnel on a need-to-know basis.
7. CONFIDENTIALITY, INFORMATION SECURITY, PROPRIETARY INFORMATION AND INTELLECTUAL PROPERTY
   1. We are committed to business information confidentiality, integrity and accessibility, we implement proper technical security measures this and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers, business partners if disclosed to unauthorized parties. All members must handle any such information as secret. It also covers that, no one is entitled to trade with securities while in possession of non-public information or deliver non-public information to others that could have impact on the securities. Every rule ensuring information security must be followed all times.
   2. Employees must maintain the confidentiality of the company and information. Sharing sensitive information with unauthorized individuals is strictly prohibited.
8. PRIVACY, PERSONAL DATA PROTECTION
   1. We respect Employee’s privacy and we acknowledge customers, employees and other natural persons’ need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to comply with all personal data protection laws. We only acquire and keep personal information that is necessary and we give proper information on these activities to data owners. We implement proper security measures to assure confidentiality, integrity and availability of personal information.
9. COMPLIANCE
   1. Compliance with this policy and applicable anti-money laundering laws should be regularly monitored and audited to identify and address any potential gaps or non-compliance.
   2. Any identified breaches or non-compliance should be promptly investigated and appropriate corrective actions should be taken.
10. CHANGES TO THE POLICY
    1. We reserve to right to update and make changes to this policy from time to time based on the working conditions of the Company. The Company on updating this policy will inform the members of the Company.
11. FURTHER INFORMATION
    1. For any queries or further Information regarding our Company or about this Policy, the concerned person can contact us through email[INSERT EMAIL ADDRESS OF THE COMPANY].
12. ACKNOWLEDGEMENT
    1. We expect all employees to adhere to this policy of the Company. The Company will apply this policy consistently and fairly to ensure a harmonious and productive workplace for all.
    2. By signing below, you acknowledge that you have carefully read and understood the terms and contents of this policy.

COMPANY                  

Authorized Signature

Print Name and Title

[INSERT SIGNING AUTHORITY AND DESIGNATION]