1. BACKGROUND

These Know Your Customer (“KYC”) Policy and Anti Money Laundering (“AML”) Measures (together referred to as the “Policy”) are established to facilitate the development of controls that will aid in the detection and prevention of money laundering using the services of CapproTech Ltd., a company duly registered in United Kingdom with registered address: 27, Old Gloucester Street, London, WC1N 3AX, United Kingdom (hereinafter referred as “CapproTech”), a funds management company with global client base and focused on creating a stable and long-term multi-level-marketing, which does not exclude anybody, doesn’t matter from which country, which level of society or from which financial background somebody comes. It is the intent of CapproTech to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.

2. OBJECTIVES OF THE POLICY

2.1 To lay down policy framework for abiding by the Know Your Customer Norms and Anti Money Laundering Measure as set out by appropriate authorities, based on the recommendations of the Financial Action Task Force (FATF) and the paper issued on Customer Due Diligence (CDD).
2.2 The objective of the Policy is to prevent CapproTech being used intentionally or unintentionally, by criminal elements for money laundering activities.
2.3 To enable the CapproTech to know/understand its customers and their financial dealings better, which in turn would help it to manage its risks prudently.
2.4 To lay down explicit criteria for acceptance of customers.
2.5 To establish procedures to verify the bona-fide identification of individual/corporate customers.
2.6 To establish processes and procedures to monitor high value transactions and/or transactions of suspicious nature.
2.7 To develop measures for conducting due diligence in respect of customers and reporting of such transactions.
2.8 To put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws/laid down procedures and regulatory guidelines.
2.9 To comply with applicable law and regulatory guidelines
2.10 To take necessary steps to ensure that the relevant staff are adequately informed and trained in KYC/AML procedures.
2.11 To manage the risk associated with dealing with customers who are potentially in contravention of KYC and AML norms.

3. SCOPE OF THE POLICY

This policy applies to any irregularity, or suspected irregularity, involving CapproTech’s customers, employees as well as shareholders, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and/or any other parties with a business relationship with CapproTech. Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the CapproTech.

4. KYC POLICY

There are four key elements to the KYC guidelines:

4.1 Customer Acceptance Policy;
4.2 Customer Identification Procedures;
4.3 Monitoring of Transactions; and 4.4 Risk Management CapproTech’s KYC policy regarding the four key elements in respect of the customers is given below.

5. CUSTOMER ACCEPTANCE POLICY (CAP)

CapproTech’s Customer Acceptance Policy, which lays down explicit criteria for acceptance of customers, ensures the following aspects of the customer relationship:
5.1 CapproTech’s customers/clients are mainly individuals and corporations to whom CapproTech provides financial management services. These are generally individual persons.
5.2 CapproTech shall not deal with anonymous or fictitious name(s) person having connections with terrorist’s organization(s).
5.3 It shall be ensured that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorist or terrorist organizations.
5.4 It would be necessary on the part of customer to furnish data/documents as prescribed in this policy. In case of non-submission of information or non-submission of documents as required, CapproTech may even suspend such customer account.
5.5 Customers shall be accepted after verifying their identity as laid down in customer identification procedures. Documentation requirements and other information shall be collected in respect of different categories of customers depending on perceived risk and keeping in mind the requirements of applicable laws.
5.6 The documentation requirements to be obtained from the customers would be reviewed by Compliance Officer from time to time based on emerging business needs and guidelines issued by regulatory authorities.

6. CUSTOMER IDENTIFICATION PROCEDURE (CIP)

6.1 Customer identification means identifying the customer and verifying his/her identity by using reliable, independent source documents, data or information.
6.2 CapproTech shall obtain sufficient information necessary to verify the identity of each new customer, whether regular or occasional.
6.3 Customer Identification Procedure to be carried out at different stages: while carrying out a financial transaction (or), when there is a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data.
6.4 For customers that are natural persons, it would be necessary to verify the identity of the customer, his address/location and also his recent photograph, documents for verifying signature. The KYC documents for the verification of individual customers are Passport (for verifying identity) and last three months bank statement with bank’s seal and customer address (for verifying the address).
6.5 For customers that are legal persons or entities, it would be necessary to
(i) verify the legal status through proper and relevant documents
(ii) verify that any person purporting to act on behalf of the legal person/ entity is so authorized and identify and verify the identity of that person
(iii) understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person
(iv) to verify identity card, Board of Inland Revenue number or Value Added Tax Number (or US equivalent).
6.6 CapproTech shall periodically update customer identification data (including photographs) after the transaction is completed.

7. MONITORING OF TRANSACTIONS

7.1 Monitoring of transactions will be conducted taking into consideration the risk profile of the account. CapproTech shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified.
7.2 To ensure monitoring of CapproTech’s KYC Guidelines, the borrowers/lenders may be requested to resubmit their KYC documents as requested by CapproTech from time to time.
7.3 To ensure monitoring and reporting of all transactions and sharing of information as required under the law for KYC, any officer of the CapproTech duly authorized is designated as Principal Officer for KYC. By default, Managing Director (“MD”) is the Principal Officer for KYC.

8. RISK MANAGEMENT

8.1 CapproTech may expose to the following risks which arise out of Money Laundering activities and non-adherence of KYC standards.
a) Reputation Risk: Risk of loss due to severe impact in CapproTech’s reputation which requires the confidence of customers, investors, and the general marketplace.
b) Compliance Risk: Risk of loss due to failure of compliance with key regulators governing the business operations.
c) Operational Risk: Risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events.
d) Legal Risk: Risk of loss due to any legal action CapproTech or its staff may face due to failure to comply with the law.
8.2 CapproTech shall ensure that adequate measures are taken to cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility should be explicitly allocated for ensuring that CapproTech’s policies and procedures are implemented effectively.
8.3 CapproTech if required may categorize the customers according to the risk perceived to facilitate undertaking due diligence for the purpose of risk categorization.
8.4 For the purpose of effective implementation of KYC policy and AML Standards, the Principal Officer shall monitor transactions on need basis with IT support to meet the requirements of KYC policy and AML standards.
8.5 All transactions of suspicious nature shall be reported to Principal Officer as an when the transactions are found to be suspicious by the staff. The Principal Officer shall ensure that such reporting system is in place and shall monitor receipt of the reports.
8.6 The Principal Officer designated by CapproTech in this regard will have overall responsibility for maintaining oversight and coordinating with various functionaries in the implementation of this Policy.
8.7 Suitable checks and balances in this regard will be put in place at the time of introducing new products/procedures as also at the time of review of existing products/ procedures for overall risk and compliance management.

9. AML MEASURES

All necessary information in respect of transactions which takes place between customers and CapproTech has to be maintained properly, to permit reconstruction of individual transaction, including the following information:

a) the nature of the transaction;
b) the amount of transaction
c) the date on which the transaction was conducted; and
d) the parties to the transaction

10. MAINTENANCE AND PRESERVATION OF RECORD

10.1 CapproTech shall have a system for proper maintenance and preservation of information in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities.
10.2 CapproTech would maintain all transaction records for 10 years from the date of transactions between the customers and CapproTech.
10.3 CapproTech will also ensure that records pertaining to the identification of the customer and his/her address (e.g. copies of documents like passports, identity cards, tax numbers, utility bills etc.) obtained while opening the account and during the course of business relationship, are properly preserved for at least ten years after the business relationship is ended. The identification records and transaction data will be made available to the competent authorities upon request.

11. REPORTING

CapproTech shall be required to report information relating to suspicious transactions to the Financial Crimes Enforcement Network (“FinCEN”). A Suspicious Activity Report (SAR) is a document that financial institutions must file with the FinCEN following a suspected incident of money laundering or fraud.

12. CUSTOMER EDUCATION

12.1 CapproTech shall take adequate measures to educate the customer on the objectives of the KYC program, especially at the time of obtaining sensitive or personal information from the customers.
12.2 While dealing with customers, Staff in CapproTech shall take special care in obtaining required information from the customers.
12.3 Policy along with relevant forms shall be uploaded in CapproTech’s Website to educate the customer of the objectives of the KYC program.
12.4 CapproTech shall also take care to see that implementation of the KYC guidelines in respect of customer acceptance, identification etc. do not result in denial of services to genuine customers/general public.

13. EMPLOYEES TRAININGS

13.1 An ongoing employee training program shall be in place so that the members of the staff are adequately trained in KYC procedures. Training requirements should have different focuses for frontline staff, compliance staff and staff dealing with new customers.
13.2 It is crucial that all those concerned fully understand the rationale behind the KYC policies and implement them consistently and effectively.
13.3 Training module encompassing applicable money laundering laws and recent trends in money laundering activity as well as the bank’s policies and procedures to combat money laundering shall be provided to all the staff members of CapproTech periodically in phases.
13.4 Hiring of Employees: KYC norms/AML standards/CFT measures have been prescribed to ensure that criminals are not allowed to misuse the banking channels. Hence CapproTech shall put adequate screening mechanism in place as an integral part of its recruitment/hiring process of personnel.

14 POLICY UPDATES AND REVIEW

14.1 The modifications/updates to the Policy shall be initiated by CapproTech as per business requirements keeping in view the new guidelines on KYC/AML or based on feedback/inputs received from customer and staff.
14.2 The modifications/updates to the policy may also be initiated by Compliance Officer based on the analysis of transactions monitored in customer accounts/operational risk events. The same shall be put up for approval to the Board.
14.3 The Policy shall be reviewed annually or as and when considered necessary by the Board.

15. EMPLOYEE RESPONSIBILITIES

All employees of CapproTech have a responsibility to act honestly and to diligently follow the procedures and controls that have been implemented to mitigate fraud, theft and corruption. They must not bypass or avoid using those procedures or controls. They must immediately report identified weaknesses or loopholes in controls that could facilitate a fraud. They must also report immediately any incident of fraud, theft or corruption, whether it is suspected or actual, either to their line manager or by following the procedures laid down. This responsibility also applies to instances of customer misconduct which may come to the attention of staff.

16. CUSTOMER PROTECTION

16.1 CapproTech's Customer Due Diligence program collects certain identity details at sign-up while remaining relatively frictionless. Once certain thresholds are met, in compliance with relevant market regulation, CapproTech will subject users to additional KYC requirements for identity verification.
16.2 CapproTech conducts a global AML/CTF and Sanctions risk assessment consistent with Financial Action Task Force (FATF) guidance to identify, assess and understand the ML/TF risks CapproTech faces. This is consistent with a risk-based approach (RBA) which impacts global policy decision-making and implementation of program elements.
16.3 CapproTech screens accounts and transaction history on a nightly basis, covering the entire customer base. We cross-reference our information against a variety of lists from regulators, governments and more (OFAC's Specially Designated Nationals list, UN Security Council sanctions list, Commission de Surveillance du Secteur Financier in the EU, etc.)

17. CYBERCRIME

17.1 CapproTech is proactive about Cybercrime.
17.2 CapproTech engages/partners with law enforcement proactively and reactively to both help stop cybercrime while also catching the bad actors that have committed crimes and are under investigation.
17.3 CapproTech has proactively reached out to law enforcement to make them aware of this system and encourage them to reach out to us with any questions or concerns.
17.4 CapproTech collaborates with various teams across the company (compliance, legal, risk, information security, etc.) to better identify potential bad actors and make recommendations to law enforcement organizations.

18. SANCTIONS POLICY

18.1 CapproTech is firmly committed to complying with all applicable economic sanctions laws that are legally binding upon CapproTech and its businesses. Any breach of sanctions may have a serious impact on our reputation, franchise, regulatory relationships and could impair the CapproTech’s ability to provide products and services to customers. The CapproTech has therefore established a sanctions policy that may be more stringent than what is permitted by law and regulation. The CapproTech adopts a policy of not entering into any transaction that either directly or indirectly involves or is for the benefit of any Sanctioned Parties, even where this would be legally permitted. For these purposes, Sanctioned Parties are defined as:
(a) parties that any one or more of the United Kingdom (UK), the European Union (EU), the United States (US) or the United Nations (UN) has listed as the target or subject of sanctions; or
(b) parties which are 50% or more owned (individually or in aggregate) by, or otherwise controlled by, any party described in (a) above; or
(c) parties which have been internally identified as presenting an unacceptable level of sanctions risk to the CapproTech.
18.2 CapproTech also prohibits and will not facilitate activity with certain governments or parties within certain geographies that are targeted under the sanctions programs of the UK, US, EU, or UN. CapproTech neither maintains a presence in these sanctioned geographies nor is it the target of these sanctions programs. As these are a direct consequence of international relations, CapproTech’s sanctions policy and specific prohibitions change from time to time. Current prohibitions include the following:
(a) Cuba: CapproTech does not undertake any transaction that has any US nexus (e.g. involving USD, US persons, US goods, etc), involving Cuba or any party in Cuba subject to limited exceptions where permitted by an applicable US regulation or OFAC licence and approved in strict accordance with CapproTech’s policy and procedures;
(b) Iran: CapproTech does not undertake any transaction involving Iran, any party in Iran, or the Government of Iran and its agencies and instrumentalities wherever located;
(c) North Korea: CapproTech does not undertake any transaction involving North Korea, any party in North Korea, or the Government of North Korea and its agencies and instrumentalities wherever located; except in very limited circumstances where permitted by an applicable UN, US, UK, and EU regulation or license and approved in strict accordance with the CapproTech’s policy and procedures;
(d) Syria: CapproTech does not undertake any transaction involving Syria, any party in Syria, or the Government of Syria and its agencies and instrumentalities wherever located, except in very limited circumstances where permitted by an applicable US, UK, and EU regulation or licence and approved in strict accordance with CapproTech’s policy and procedures;
(e) Crimea & Sevastopol: CapproTech does not undertake any transaction involving Crimea and Sevastopol or any party in Crimea and Sevastopol, except in very limited circumstances where permitted by an applicable US, UK, and EU regulation or licence and approved in strict accordance with CapproTech’s policy and procedures;
(f) Russia: The CapproTech does not undertake any transaction involving:
i. The Russian military, intelligence services, or related to defence equipment.
ii. Investments that directly and significantly enhances the ability of Russia to construct energy export pipeline projects; or the sale, lease, or provision of goods or services to Russia that directly and significantly facilitate the expansion, construction, or modernization of energy export pipelines by Russia.
iii. Any entity (including its subsidiaries) targeted by the US, UK, or EU for “Sectoral Sanctions” where the transaction falls within the scope of the specifically prohibited activity. This currently includes transactions involving such entities and
1. the direct or indirect provision, exportation, or re-exportation of goods and/or services, or technology in support of exploration or production for deep-water, arctic offshore, or shale projects.
2. debt or equity issued, made or provided on or after the date upon which the entity was targeted for the sanction.
(g) Venezuela: CapproTech does not undertake any transaction related to the provision of financing for and any other dealings involving the (a) Venezuelan military; or (b) the Venezuelan Government, including its property, or entities owned (50% or more) or controlled by the Venezuelan Government. These prohibitions also extend to all Venezuelan state-owned entities, including Petróleos de Venezuela S.A. and the Central Bank of Venezuela. CapproTech may, however, consider undertaking transactions that have been authorized and licensed by the U.S. Treasury’s Office of Foreign Assets Control.
18.3 CapproTech may change the prohibitions described here without notice at any time. For question related to this policy, contact CapproTech at: kyc@capprotech.com