KYC and AML - Finscorpio

Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy

FinScorpio (“Company”, “we”, “us”, or “our”) is fully committed to compliance with all applicable Anti-Money Laundering (AML) laws and regulations. This commitment aligns with international standards and the laws of the British Virgin Islands (BVI), as well as best practices adopted across the global financial services industry.

This KYC and AML Policy form a critical part of our compliance framework, designed to:

Maintain the integrity of the financial system
Protect our Company and Clients from misuse by criminal or illicit actors
Ensure transparency and accountability in all transactions

This policy applies to all Clients and Users, whether individuals or corporate entities, and covers all account types and transactions conducted via our Site or Platform.

1. Purpose

The primary objectives of this Policy are to:

Verify the Identity of Clients – Ensure that each Client is accurately identified prior to providing Services.
Monitor Account Activity – Detect unusual or suspicious patterns, including transactions inconsistent with the Client’s profile.
Maintain Comprehensive Records – Retain documentation in compliance with legal and regulatory obligations.
Report Suspicious Activity – Notify relevant authorities in accordance with AML regulations.
Employee Awareness and Training – Equip employees with the knowledge to identify and respond to potential risks.
Risk Mitigation – Minimize exposure to financial, reputational, and regulatory risks.

2. Definition of Money Laundering

Money Laundering refers to any act of processing, transferring, or concealing funds derived from criminal activities, including but not limited to: fraud, bribery, corruption, or other unlawful acts, to disguise the true source of funds.

A typical money laundering process involves:

Placement: Introducing illicit funds into the financial system (e.g., bank deposits, transfers).
Layering: Conducting complex transactions to obscure the origin of funds.
Integration: Reintroducing the funds into the legitimate economy to make them appear lawful.

All money laundering activities are strictly prohibited, and the Company takes robust measures to detect and prevent such activity.

3. KYC Procedures

3.1 Client Onboarding

All Clients must complete a detailed application and verification process before accessing our Services. The Company collects information necessary to establish the identity of each Client and assess potential risk.

Information Collected:

Full legal name and any aliases
Date of birth and nationality
Country of residence
Contact details (address, email, phone)
Occupation or business activity
Source of funds and source of wealth

Documentation Required for Verification:

Individuals:

Valid government-issued passport or national ID
Proof of residence (utility bill, bank statement, or tax document)

Corporate Clients:

Certificate of Incorporation or equivalent
Constitution, Memorandum, and Articles of Association
Board resolution authorizing account operation
Registers of Directors and Shareholders
Verification of beneficial owners and major stakeholders
Business profile and latest financial statements

All documents may be verified electronically or in certified copy format, in compliance with regulatory standards.

3.2 Customer Acceptance and Risk Assessment

The Company conducts a risk-based assessment before accepting any Client, including:

Verification of source of funds and financial background
Assessment of country of residence and compliance with sanctions lists
Identification of Politically Exposed Persons (PEPs) and high-risk Clients
Analysis of linked accounts, unusual transaction patterns, or atypical business activities

Clients classified as high-risk require enhanced due diligence and senior management approval prior to onboarding.

3.3 Restricted and Prohibited Clients

The Company does not accept:

Clients from sanctioned, restricted, or high-risk jurisdictions (per OFAC, FATF, and other recognized lists)
U.S. persons or entities
Anonymous accounts or accounts maintained through shell banks
Third-party deposits or withdrawals that do not comply with KYC standards

3.4 Ongoing Monitoring

All Client accounts are subject to continuous monitoring for suspicious or atypical activity. Monitoring includes:

Transaction volumes, patterns, and frequency
Deposits inconsistent with expected account activity
Transactions lacking economic or commercial rationale
Activity exceeding established thresholds for account type

Enhanced monitoring is applied to high-risk Clients, focusing on:

Country of origin and risk indicators
Source of funds
Nature and purpose of transactions

Suspicious activity is promptly investigated and escalated to relevant regulatory authorities when necessary.

3.5 Reporting Suspicious Activity

The Company reports all suspicious transactions in compliance with AML laws. Examples include:

Transactions inconsistent with the Client’s stated investment strategy or financial profile
False, misleading, or incomplete information regarding source of funds
Refusal or inability to provide requested identification or documentation
Publicly available information indicating potential regulatory, civil, or criminal concerns
Unusual transaction patterns, unusually large deposits, or unexplained withdrawals

3.6 Record-Keeping

Client records are maintained for a minimum of five (5) years following account closure or transaction completion. Records include:

Verification and identification documents
Account and transaction history
Correspondence with Clients

All records are stored securely, protected by state-of-the-art security measures, and made available to regulatory authorities upon request.

3.7 Employee Training

Employees receive role-based KYC/AML training, covering:

Customer verification and due diligence procedures
Detection and reporting of suspicious activity
Awareness of money laundering and financial crime risks

Training is updated regularly to reflect changes in regulations, industry best practices, and operational procedures.

3.8 Audits and Policy Review

Regular internal and external audits are conducted to ensure:

Compliance with the KYC/AML Policy
Adherence to applicable laws and regulatory guidelines
Continuous improvement in risk management and due diligence procedures

The Policy is reviewed periodically to incorporate regulatory updates, technological advances, and operational improvements.

3.9 Client Obligations

Clients are required to:

Provide accurate, complete, and up-to-date information at all times
Notify the Company of any changes to personal, corporate, or beneficial ownership information
Comply with all requests for documentation to maintain their account and comply with regulations

Non-compliance may result in:

Refusal to establish an account
Suspension or termination of Services
Reporting to regulatory authorities if suspicious activity is detected

3.10 Additional Information

If a required document is unavailable in the prescribed form, the Compliance Officer may accept an equivalent document.
Clients with multiple accounts, or changes in corporate structure or ownership, must provide updated documentation promptly to ensure continued compliance.
Clients are encouraged to proactively maintain accurate and verifiable records to avoid delays or service restrictions.