By engaging with us you acknowledge that you have read, understood, and agree to the terms outlined herein.
Part 1: Scope and Purpose
Purpose of the Policy
This Acceptable Use and KYC/KYB (Know Your Customer/Know Your Business) policy outlines the standards and procedures we follow to verify the identities, backgrounds, and intentions of individuals, entities, and organizations seeking our services.
Our goal is to establish a secure, transparent environment that respects your privacy while upholding all relevant legal and regulatory requirements.
People-Centered Approach
We recognize that compliance procedures can feel complex. Our team is committed to guiding you through the KYC/KYB process with clear communication, understanding, and support.
We aim to ensure you understand why certain information is required and how providing it helps maintain a safe and compliant environment for all clients.
Application of the Policy
This policy applies to all prospective and existing clients, including but not limited to:
- Individuals (e.g., private investors, shareholder, cryptocurrency owners)
- Companies
- Trusts, Foundations, and Other Legal Arrangements
By requesting or continuing to use our services, you agree to comply with this policy. Failure to meet the standards set forth herein may result in denial, suspension, or termination of services.
Part 2: Information Collection and Documentation Requirements
Types of Information Collected
To comply with applicable laws, mitigate risk, and deliver high-quality services, we may request various forms of documentation. This can include, but is not limited to:
Individuals:
- Government-issued photo ID (e.g., passport, national ID, driver’s license)
- Proof of address (e.g., recent utility bill, bank statement)
- Source of funds (e.g., employment details, investment records)
- Personal background information as relevant to the nature of the services requested
Companies:
- Registration documents (e.g., Certificate of Incorporation, Articles of Association)
- Shareholder and director information
- Ultimate Beneficial Owner (UBO) details
- Financial statements, where applicable
- Compliance history, if any
Trusts, Foundations, and Similar Legal Arrangements:
- Trust deeds or foundation statutesInformation on settlors, protectors, trustees, beneficiaries, and any related partiesDocumentation detailing the purpose and intended activities of the trust or foundation
Future Business Plans & Other Sensitive Information
During our initial assessment and service provision, we may request information about:
- Planned services or product offeringsIntended target markets and client segments
- Projected transaction volumes and capital flowsGrowth strategies, expansion goals, and timeline for entering new jurisdictions
Collecting this data helps us tailor our advice, ensure compliance with regional regulations, and anticipate ongoing support needs. By providing these details, you acknowledge and consent that we may share relevant insights with our vetted partners (e.g., banking, licensing, or legal associates) strictly for the purpose of fulfilling your service requests and ensuring compliant operations.
Data Protection and Privacy
We handle all collected information with strict confidentiality, using secure methods to store, process, and transmit data. Access to your personal and corporate information is granted only to authorized personnel and trusted partners necessary for delivering the requested services. You explicitly grant us the right to share your information with these third-party partners, where needed, to facilitate licensing, compliance checks, or other essential steps in our engagement.
Part 3: Unacceptable Activities and Prohibited Conduct
Prohibited Activities
We do not assist, support, or engage with clients involved in any form of illegal, unethical, or illicit activities. Examples of prohibited conduct include, but are not limited to:
- Money laundering, terrorist financing, or proliferation financing
- Fraud, tax evasion, or other financial crimes
- Financing illegal arms trade, human trafficking, or drug trafficking
- Engaging in transactions intended to circumvent sanctions or embargoes
- Activities related to child exploitation, violent extremism, or other severe unlawful acts
If we have reason to believe that any client is involved in these or similar activities, we reserve the right to refuse, suspend, or terminate services immediately.
Sanctioned Countries and Non-Cooperative Jurisdictions
We do not provide services to entities or individuals based in, or operating from, jurisdictions subject to comprehensive sanctions, embargoes, or identified by the Financial Action Task Force (FATF) as non-cooperative. Such restrictions may include, but are not limited to:
- United Nations, European Union, UK, or U.S. sanctioned countries (e.g., North Korea, Iran, Syria)
- Jurisdictions flagged by FATF for strategic AML/CFT deficiencies (these may change over time and will be updated accordingly, e.g., Myanmar, certain listed territories)
We regularly review official sanctions lists and FATF advisories to ensure compliance. Clients are responsible for informing us if they operate in or have links to these high-risk jurisdictions.
Part 4: Compliance, Reviews, and Amendments
Ongoing Compliance and Monitoring
We conduct periodic reviews of client information to ensure continued adherence to regulatory standards. You may be asked to refresh or update your documentation periodically. Failure to provide requested updates or additional details may result in service interruptions or termination.
Client Responsibility
By engaging our services, you warrant that all information provided is accurate, honest, and up-to-date. You agree to promptly inform us of any significant changes to your circumstances, business activities, or operational jurisdictions.
Amendments to Policy
We may update this Acceptable Use and KYC/KYB Policy to reflect evolving regulations, industry standards, or internal best practices. We will notify clients of material changes, and continued use of our services constitutes acceptance of the updated terms.
Enforcement and Consequences
Non-compliance with this policy, refusal to provide required documentation, or engagement in prohibited activities will lead to immediate remedial action, which may include denial of service, account closure, or reporting to appropriate regulatory or law enforcement authorities, as required by law.
Acceptance of Terms
By proceeding with our services, you acknowledge that you have read, understood, and agree to the terms of this Acceptable Use and KYC/KYB Policy. If you have any questions or concerns, we encourage open communication and will aim to provide clear guidance.