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

KYC

Know Your Customer (KYC) Policy

1. Introduction

2. Customer Due Diligence (CDD)

3. Risk-Based Approach

4. Enhanced Due Diligence (EDD)

5. Ongoing Monitoring

6. Record Keeping

7. Staff Responsibilities

8. Reporting

9. Quality Assurance

10. Non-Compliance

11. Policy Review and Updates

12. Approval

Document Control

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