Version 1.0
Prepared by: @Lorraine Sebata
Approved by: @Feli Capron
Reviewed date: 2025-07-25
Next review date: 2026-07-24
This SOP details the step-by-step process for implementing the Know Your Client (KYC) Policy at Easyterms. It outlines procedures for client identification, verification, risk rating, and ongoing monitoring to ensure compliance with AML/CTF regulations and effective risk management.
This SOP applies to all employees, particularly Loan Officers, Credit Analysts, and any staff involved in client onboarding, relationship management, and transaction monitoring.
Loan Officer: Responsible for initial client inquiry, collection of KYC documentation, preliminary identity verification, and inputting client data into the system.
Credit Analyst: May assist in reviewing client information, especially for financial and business details, during the credit appraisal process.
Compliance Department/MLRO: Reviews and approves KYC documentation, determines client risk ratings, provides guidance on complex KYC cases, and oversees ongoing monitoring.
Branch Manager: Reviews and approves client onboarding within their delegated authority, ensuring adherence to KYC procedures.
5.1.1 Explain KYC requirements to prospective clients, including the need for identity verification and relevant documentation.
5.1.2 Provide the client with a list of required supporting documents for identity verification based on their type (natural person, corporate, partnership).
5.2.1 Receive completed application forms and all supporting KYC documents.
5.2.2 Conduct a preliminary review for completeness and legibility. Missing information should be requested from the client immediately.
5.2.3 Ensure that no anonymous, ciphered, or fictitiously named accounts are processed.
5.2.4 Create a client file (physical and/or digital) and assign a unique client ID.
5.2.5 Input initial client and KYC data into the Loan Management System (LMS) or dedicated KYC system.
5.3.1 All identification documents must be issued by a government entity (e.g., passport, national identity card).
5.3.2 Documents must be in good condition, legible, and current (expiry date not less than three months).
5.3.3 For face-to-face onboarding, any senior member of staff can certify ID documents. For non-face-to-face channels, ID must be notarized.
5.4.1 Collect and verify:
Visible photograph
Full legal name
Signature of holder
Date and place of birth
Nationality
Identification document number
Country of issuance
Expiry date (must be current)
Reference Address (verified by recent utility bill, lease agreement, home visit, or tax assessment)
Contact information (phone number, e-mail address)
Occupation/Profession and name of company of employment (if own business, type of business)
Financial reference (less than 6 months old)
Character reference (less than 6 months old)
Indication if a Public Figure (Politically Exposed Person - PEP)
Written confirmation that all credits to the account are and will be beneficially owned by the account holder, unless operated by an intermediary in a professional capacity
5.5.1 Collect and verify:
Original or certified Certificate of Incorporation or equivalent document
Certified Memorandum and Articles of Association/Constitutive Documents
Certificate of Good Standing (COGS)
Share Register/Copy of a letter or document indicating the composition of the shareholders (notarized by an attorney or certified by RORA)
Completed KYC form for all shareholders with more than 10% ownership
Register of Directors/Copy of a letter or document indicating the Directors (notarized by an Attorney or stamped by Registry)
Purpose of account
Description and nature of the business (date of commencement, products/services provided)
Completed KYC for each director (exceptions may apply for partners)
Location of principal place of business
Name and address of Registered Office and Agent, if applicable
Resolution of the Board of Directors appointing the directors
Certified copy of Resolutions of the Board of Directors authorizing the opening of any Account
Confirmation that the company is not in the process of dissolution (see COGS)
Powers of Attorney, if applicable
5.6.1 Collect and verify:
Verification of all partners and beneficial owners
A copy of the partnership agreement, if any, or agreement establishing the unincorporated business
The mandate from the partnership or beneficial owner authorizing the account opening and conferring authority on operators
Any documentary evidence required for the verification of the natural person operating the account
A description and nature of the business, including date of commencement, products/services, and location of principal place of business
Purpose of the account and potential parameters of the facility
Size of client facility
Balance ranges for deposits and client facility
Expected transaction volume of the facility
Written confirmation that all credits to the facility are and will be beneficially owned by the facility holder, unless operated by an intermediary in a professional capacity
Such documentary or other evidence as is reasonably capable of establishing the identity of a partner or beneficial owner
5.7.1 Exemptions apply for:
Financial institutions licensed by specified regulatory bodies (e.g., Central Bank of the Bahamas, Securities Commission of the Bahamas, etc.)
Financial institutions subject to AML/CTF obligations and supervision
Central or local government agencies or statutory bodies
Publicly traded companies listed on approved stock exchanges
5.8.1 The company may rely on verification performed by local or foreign financial institutions for individuals, corporate entities, or partnerships, provided they meet the company's KYC standards
5.9.1 For all facility establishments, verify the identity of the beneficial owner in accordance with the verification procedures for Natural Persons, Corporate Entities, or Partnerships
5.10.1 For accounts established via telephone, internet, or in writing, the company will verify the identity of the individual, corporate entity, or partnership
5.11.1 Determine the client's risk profile (Low, Medium, High, Extreme) using the "Risk Matrix Form" (Appendix 7). This forms the basis for ongoing monitoring.
5.11.2 Extreme Risk (Not Acceptable): Clients convicted of fraud, extortion, money laundering, tax evasion, bribery, corruption, or crimes against public/private equity. These clients are recorded in the "Unacceptable Client List".
5.11.3 High Risk Clients: Include:
Natural or corporate clients involved in activities listed in Appendix 1 "High Risk Activities"
Clients with significant activity in or with non-First Schedule countries (see Appendix 2 "First Schedule Countries")
Politically Exposed Persons (PEPs) and their close family members
Non-face-to-face onboarding (other than transfers from other Financial Institutions)
5.11.4 Medium Risk Clients: Include natural or corporate clients involved in activities such as: manufacturers of construction materials, regulated financial activities, car dealers, real estate brokers, travel agencies, hotels & motels, universities/schools, supermarkets, clothing/household stores, pharmacies, and restaurants.
5.11.5 Low Risk Clients: Include natural or corporate clients involved in activities such as: publicly listed companies, government institutions, and individuals/entities registered with a regulator (CBOB, SCB, CC, or their equivalent in a First Schedule country).
5.12.1 Formal approval to accept a new client will be provided by following the "Onboarding Standard Operating Procedures (SOP)".
5.12.2 Clients may be rejected during the approval process based on different factors, even after submitting an application.
5.13.1 Monitor every facility for the stated account purpose on a risk-based approach.
5.13.2 No further identity verification is needed unless there are material changes, such as a change in ownership or activity that raises suspicion of an identified risk.
5.13.3 Monitor for inconsistencies against the original stated account purpose of the facility in terms of:
Transaction type
Frequency
Amount
Geographical origin/destination
Facility signatories.
5.13.4 Update client documentation and profiles based on risk levels:
High Risk: Every 12 months
Medium Risk: Every 24 months
Low Risk: Every 36 months
5.14.1 All client KYC files, financial transactions, bank/portfolio statements, and other reconstructible information must be retained for a minimum of seven years after the business relationship ends.
Loan Application Form (see LMS)
Client Identification Documents
Proof of Address Documents
Risk Matrix Form (Appendix 7)
Onboarding Standard Operating Procedures (SOP)
"Unacceptable Client List"
Appendix 1 "High Risk Activities"
Appendix 2 "First Schedule Countries"
All relevant employees will receive mandatory training on this SOP and related policies annually or upon significant revisions.
This SOP will be reviewed annually by the Compliance and Operations Departments to ensure its continued effectiveness, compliance, and alignment with business objectives.