Version 1.0
Prepared by: @Lorraine Sebata
Approved by: @Feli Capron
Reviewed date: 2025-07-24
Next review date: 2026-07-24
This Know Your Client (KYC) Policy establishes the minimum standards for identifying and verifying the identity of clients, assessing their risk profiles, and monitoring their activities to prevent the company's services from being used for financial crime. It ensures compliance with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations.
This policy applies to all employees, agents, contractors, and third parties acting on behalf of Easyterms across all business lines, products, and services, covering all financial transactions, client relationships, and operational activities.
Easyterms is committed to establishing and verifying the true identity of all clients, including beneficial owners and facility holders. No anonymous, ciphered, or fictitious accounts will be opened.
A risk-based approach shall be adopted to identify, assess, manage, and mitigate KYC-related risks. Clients will be assigned a risk rating (high, medium, low, or extreme) based on their operational profile, activity, and other identified risk factors.
Robust Customer Due Diligence (CDD) procedures, including Enhanced Due Diligence (EDD) for higher-risk clients, will be implemented to understand the nature of the client's business and expected transaction patterns.
Client accounts and transactions will be continuously monitored to detect unusual or suspicious activities inconsistent with the client's known profile. Client information will be updated periodically to ensure its accuracy and relevance.
Special attention and enhanced due diligence will be applied to Politically Exposed Persons (PEPs) and their close family members.
All records related to client identification, verification, risk assessment, and ongoing monitoring will be retained for a minimum period of seven years after the business relationship ends.
Board of Directors / Senior Management: Overall responsibility for approving and overseeing the KYC policy and its integration into the AML/CTF program.
Money Laundering Reporting Officer (MLRO): Oversees the day-to-day implementation of KYC procedures and acts as the primary liaison with regulatory bodies regarding KYC matters.
Compliance Department: Develops, implements, and maintains KYC policies, procedures, and training programs.
All Employees: Responsible for understanding and adhering to this policy, conducting appropriate due diligence, and reporting any inconsistencies or suspicious findings to the MLRO.
This policy will be reviewed at least annually, or more frequently if there are significant changes in laws, regulations, business operations, or identified risks.