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This KYC, KYB, and AML Policy (hereinafter referred to as "the Policy") outlines the procedures and measures implemented by Sidglo, Inc. and its subsidiaries (hereinafter referred to as "the Company") to ensure compliance with regulatory requirements and mitigate risks associated with money laundering, terrorist financing, and other financial crimes. The Policy applies to all employees, agents, and third-party service providers engaged in financial activities on behalf of the Company.
Customer Identification: The Company will collect and verify customer identity information using reliable and independent sources before establishing a business relationship or conducting transactions.
This includes but is not limited to:
• Name
• Date of birth
• Address and proof of address (last 90 days)
• Identification documents (e.g., government-issued ID, passport)
Enhanced Due Diligence (EDD): Enhanced due diligence measures will be applied to high-risk customers, including politically exposed persons (PEPs) and customers from high-risk jurisdictions. This may involve additional verification steps and ongoing monitoring of the customer relationship.
Customer Risk Profiling: The Company will assess the risk associated with each customer based on factors such as their business activities, geographic location, and transaction history. This information will be used to determine the appropriate level of due diligence and monitoring.
Ongoing Monitoring: The Company will monitor customer transactions and account activity for unusual or suspicious behavior. Any discrepancies or red flags will be investigated promptly, and appropriate action will be taken in accordance with internal policies and regulatory requirements.
Business Verification: For corporate customers, the Company will conduct a thorough verification of the business entity, its ownership structure, and its beneficial owners. This may include obtaining corporate documents, such as articles of incorporation, business licenses, and partnership agreements.
Ultimate Beneficial Ownership (UBO): The Company will identify and verify the ultimate beneficial owners (UBOs) of corporate customers to understand the ownership and control structure of the business.
Business Risk Assessment: The Company will assess the risk associated with each business customer based on factors such as its industry, geographic location, and reputation. Enhanced due diligence measures will be applied to high-risk businesses.
Transaction Monitoring: The Company will implement systems and controls to monitor customer transactions for suspicious activity, including unusual patterns, large transactions, and transactions involving high-risk jurisdictions or individuals.
Suspicious Activity Reporting: Employees are required to report any suspicious activity or transactions to the designated AML compliance officer. Reports will be filed with the appropriate regulatory authorities as required by law.
AML Training: The Company will provide regular training to employees on AML regulations, policies, and procedures to ensure awareness and compliance.
Record Keeping: The Company will maintain accurate and up-to-date records of customer due diligence, transaction activity, and AML compliance efforts in accordance with regulatory requirements.
Compliance Officer: The Company will appoint a designated AML compliance officer responsible for overseeing and enforcing compliance with this Policy and applicable AML regulations.
Independent Audits: The Company will conduct regular independent audits of its AML program to assess its effectiveness and identify areas for improvement.
This Policy reflects the Company's commitment to preventing money laundering, terrorist financing, and other financial crimes by implementing robust KYC, KYB, and AML procedures. All employees are expected to adhere to this Policy and report any concerns or violations promptly.
Please direct comments or questions regarding this KYC, KYB, and AML Policy via e-mail to sg@sidglo.com
