Know Your Customer (KYC)/Customer Due Diligence(CDD) Policy

Purpose

The purpose of KYC/CDD is to prevent financial services providers from being used, intentionally or unintentionally, by criminal elements for money laundering activities. KYC/CDD policies enable financial services providers to know or understand their customers and their financial dealings.

Overview: The KYC/CDD Policy identifies the specific customer and transaction information collected and recorded, as well as the verification of customer identification and government filings in accordance with regulatory expectations.

Summary: CoinDeal Limited ("CoinDeal") collects and records certain information from every customer that completes a transaction, utilizes a risk-based approach to verify the identity of customers and customer-provided information, and records transaction information, customer identification, and verification methods.

Exceptions

CoinDeal will not grant any exceptions to its KYC/CDD Policy without the written approval of the BSA Compliance Officer.

CoinDeal will not execute the customer-requested transaction under the following circumstances: (1) the customer is unable to provide the requisite information, (2) the customer is unable to present an unexpired government-issued photo identification, (3) CoinDeal is otherwise unfamiliar with the type of documentation or identification presented, (4) CoinDeal cannot form a reasonable belief as to the true identity of the customer, and/or (5) the customer presents identification issued by state within which CoinDeal is not licensed or otherwise permitted to engage in money transmitter activities.

If a prospective or existing customer either refuses to provide the information described below upon request or appears to have intentionally provided misleading information, CoinDeal will not conduct the transaction and, after considering the risks involved, may block all future customer transactions. In either case, the BSA Compliance Officer will be notified and determine whether a Suspicious Activity Report ("SAR") is warranted.

Discretion

In an effort to maintain a risk-based approach, CoinDeal may require any customer, at its discretion, to provide additional pieces of information and identification above and beyond the minimum criteria set forth within this policy.

Details

The KYC/CDD for individual and non-individual customers are detailed below.

INDIVIDUAL: Individual Customer

CoinDeal will collect, record, and maintain the following information from customers

  1. Full name
  2. Physical address
  3. Date of birth
  4. Email address
  5. Mobile phone number
  6. Government-issued photo identification, unexpired
  7. Selfie picture of customer
  8. Country of residence
  9. Cryptocurrencies (e.g. BTC, LTC)
  10. Currency amount (crypto, fiat-equivalent)
  11. Wallet address - source
  12. Wallet address - destination
  13. Geolocation data
  14. Attestation and agreement to "Terms of Service" and/or other disclosures

Additional action(s)

  1. OFAC screening
  2. Other watchlist screening
  3. Politically Exposed Person (PEP) screening
  4. Non-documentary and/or documentary verification of customer information, including identification
  5. Geolocation analysis
  6. Proof of residency (e.g. utility bill)
  7. Secondary proof of residency (e.g. bank statement)
  8. Tax identification number (e.g., SSN, ITIN)
  9. Sources of funds
  10. Sources of income
  11. Completed CDD Questionnaire
  12. Review of blockchain explorer data
  13. Review of completed CDD Questionnaire
  14. Referral for enhanced due diligence (EDD)

Business: Non-Individual Customer

CoinDeal will collect, record, and maintain the following information from any non-individual customer. Certificate of good standing or copies of memorandum of association or memorandum of partnership / articles of partnership or articles of incorporation confirming non-individual customer shareholders statement and rights for representation will be requested every six months.

  1. Entity legal name
  2. Registered address
  3. Business address (if different, no P.O. boxes)
  4. Phone number (preferably fixed line)
  5. Copy of bank statement (not older than 3 months)
  6. Corporate identification number
  7. Entity type
  8. Copies of Memorandum of association or Memorandum of partnership / Articles of partnership or Articles of incorporation (not older than 3 months)
  9. Certificate of good standing (not older than 3 months)
  10. Country of domicile
  11. Other business document with legal address (e.g., utility bill, lease agreement, fixed line invoice ) (not older than 3 months)
  12. Nature of business
  13. Legal names of directors
  14. Legal names of officers
  15. Legal names of all shareholders with >25% equity (see "Additional action(s)")
  16. Legal name and phone number of primary contact
  17. Sources of funds
  18. Completed CDD Questionnaire
  19. Cryptocurrencies (e.g. BTC, LTC)
  20. Currency amount (crypto, fiat-equivalent)
  21. Wallet address - source
  22. Wallet address - destination
  23. Geolocation data
  24. Attestation and agreement to "Terms of Service" and/or other disclosures

Additional action(s)

  1. OFAC screening
  2. Other watchlist screening
  3. Politically Exposed Person (PEP) screening
  4. Non-documentary and/or documentary verification of customer information, including identification
  5. Geolocation analysis
  6. Review of blockchain explorer data
  7. Verification customer is not a "financial institution" under the Bank Secrecy Act
  8. Review of completed CDD Questionnaire