Know Your Customer (KYC) Policy


1. Introduction

  • 1.1 Purpose:
    • This Know Your Customer (KYC) policy establishes the framework for customer identification, verification, and ongoing monitoring to ensure compliance with applicable regulations and to prevent financial crimes.

  • 1.2 Scope:
    • Applies to all new and existing customers, including individuals, corporations, partnerships, and other legal entities engaging with [Organization Name].

  • 1.3 Regulatory Framework:
    • Local AML/CFT regulations
    • FATF Recommendations
    • Applicable international standards
    • Data protection and privacy laws

2. Customer Due Diligence (CDD)

  • 2.1 Basic Customer Information Requirements
    • 2.1.1 Individual Customers:
      • Full legal name
      • Date of birth
      • Residential address
      • Nationality
      • Government-issued identification number
      • Tax identification number (where applicable)
      • Employment information
      • Source of funds/wealth

    • 2.1.2 Legal Entities:
      • Legal entity name
      • Registration number
      • Registered address
      • Business address
      • Nature of business
      • Directors' information
      • Beneficial ownership information
      • Tax identification number
      • Source of funds/wealth

  • 2.2 Verification Requirements
    • 2.2.1 Identity Verification Documents: Government-issued photo ID, Passport, Driver's license, National identity card
    • 2.2.2 Address Verification Documents: Utility bills (≤ 3 months), Bank statements, 2 pieces of government-issued documents, Registered lease agreement
    • 2.2.3 Legal Entity Documents: Certificate of incorporation, Memorandum and articles of association, Board resolution, Ownership structure chart, Beneficial ownership declaration, Latest financial statements

3. Risk-Based Approach

  • 3.1 Customer Risk Categories
    • Low Risk: Domestic retail customers, Small business accounts, Salaried employees, Government entities
    • Medium Risk: High-value accounts, Non-resident customers, Private banking customers, Cash-intensive businesses
    • High Risk: Politically Exposed Persons (PEPs), High-risk jurisdictions, Complex ownership structures, High-risk industries

  • 3.2 Risk Assessment Factors:
    • Customer type
    • Geographic location
    • Products/services used
    • Transaction patterns
    • Distribution channels
    • Business type
    • Source of funds/wealth

4. Enhanced Due Diligence (EDD)

  • 4.1 Triggers for EDD:
    • High-risk customers, Complex transactions, Unusual patterns, High-risk jurisdictions, PEP relationships

  • 4.2 Additional Requirements:
    • Senior management approval, Enhanced monitoring, Additional verification, Source of wealth checks, Frequent reviews

5. Ongoing Monitoring

  • 5.1 Transaction Monitoring:
    • Regular reviews, Unusual activity detection, Automated monitoring, Risk-based frequency

  • 5.2 Profile Updates:
    • Annual for high-risk, Biennial for medium-risk, Triennial for low-risk, Event-triggered reviews

6. Record Keeping

  • 6.1 Document Retention:
    • Customer IDs, Transactions, Risk assessments, Due diligence, Investigations – all for minimum 5 years

  • 6.2 Security:
    • Secure systems, Access control, Encryption, Backup procedures

7. Staff Responsibilities

  • 7.1 Roles:
    • Board, Senior Management, Compliance Officer, Front-line Staff, Internal Audit

  • 7.2 Training:
    • Initial KYC, Annual refresher, Specialized high-risk training, Training documentation

8. Reporting

  • 8.1 Internal:
    • Suspicious activity reports, Compliance updates, Risk assessments, Training reports

  • 8.2 Regulatory:
    • Suspicious transaction reports, Large transactions, Annual compliance reports, Regulatory audits

9. Quality Assurance

  • 9.1 Internal Controls:
    • Audits, Quality checks, Testing, Monitoring

  • 9.2 Independent Review:
    • External audits, Regulatory exams, Third-party assessments

10. Non-Compliance

  • 10.1 Consequences:
    • Disciplinary actions, Penalties, Legal issues, Reputation risk

11. Policy Review and Updates

  • 11.1 Regular Review:
    Annual check, Regulation alignment, Risk updates, Procedure revisions

  • 11.2 Change Management:
    Version control, Communication, Training, Implementation schedule

12. Approval

This policy is approved by: SweepstakeBingo

Effective Date: January 1, 2025


Document Control

  • Version 1.0: January 1, 2025 - Initial policy
  • Last Review: March 1, 2025
  • Next Review: January 1, 2026
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