Legal KYC Policy Form

LEGAL KYC POLICY FORM

This Legal KYC Policy Form is entered into as of Effective Date: by and between Company Name: with principal address: (\"Company\") and Authorized Representative Name: , Title: with address: (\"Representative\").

RECITALS

WHEREAS, the Company maintains an anti-money laundering and counter‑terrorist financing compliance program and requires standardized procedures for Know Your Customer (KYC) to verify the identity of customers, beneficial owners, and authorized representatives;

WHEREAS, the Representative is responsible for implementing, maintaining, and certifying adherence to the KYC procedures described herein across the scope of the Company's business operations; and

WHEREAS, the parties desire to document the Company's KYC policy, governance, recordkeeping obligations, and escalation pathways to ensure compliance with applicable laws and industry standards.

NOW, THEREFORE, in consideration of the mutual covenants contained in this Form and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties agree as follows.

1. DEFINITIONS

For purposes of this Policy, the following definitions apply: (a) \"Customer\" means any natural or legal person that establishes a business relationship or conducts a transaction with the Company; (b) \"Customer Due Diligence\" or \"CDD\" means the process of identifying and verifying the identity of a Customer and any beneficial owner; (c) \"Enhanced Due Diligence\" or \"EDD\" means additional measures applied to higher risk Customers or transactions; and (d) \"PEP\" means Politically Exposed Person. Terms not otherwise defined have the meanings commonly ascribed under applicable law.

2. SCOPE

This Policy applies to all business units, subsidiaries, branches, and third-party agents of the Company that engage with Customers. It governs identity verification, beneficial ownership identification, ongoing monitoring, record retention, suspicious activity reporting, employee training, and audit procedures.

Individuals Corporations Trusts and Estates Other:

3. CUSTOMER IDENTIFICATION PROGRAM

The Company shall implement a Customer Identification Program (CIP) that requires collection and verification of identifying information sufficient to form a reasonable belief regarding the true identity of each Customer. Identification measures shall include, at minimum, verification of name, date of birth (for individuals), address, and government-issued identification where applicable. Electronic verification methods may be used where they demonstrably achieve equivalent assurance.

Acceptable identification documentation and verification procedures shall be documented in implementing procedures maintained by the Compliance Officer and shall be proportionate to the assessed risk of the Customer and the nature of the product or service.

4. RISK ASSESSMENT AND RISK-BASED APPROACH

The Company adopts a risk-based approach to KYC. The Compliance Officer shall perform an initial risk assessment for each Customer considering factors including customer type, geographic risk, product or service risk, transaction value, and beneficial ownership complexity. The Company will apply CDD or EDD measures consistent with the level of assessed risk.

5. CUSTOMER DUE DILIGENCE (CDD)

CDD procedures shall require identification and verification of Customers and any beneficial owners holding a controlling interest or exercising significant influence. For legal entities, the Company shall collect documentation evidencing legal existence, ownership structure, and the identity of natural persons who ultimately own or control the entity. The Company shall document the rationale for acceptance of the Customer and the results of verification steps in the Customer file.

6. ENHANCED DUE DILIGENCE (EDD)

EDD shall be required when the Customer or transaction presents a higher risk, including but not limited to: Customers located in high‑risk jurisdictions, complex ownership structures, PEP status, or activities inconsistent with expected behavior. EDD measures shall include expanded verification of sources of funds, additional senior management approval, and heightened transaction monitoring.

7. RECORDKEEPING AND RETENTION

The Company shall retain records of identification, verification, transaction records, CDD/EDD assessments, and related supporting documentation for the period required by applicable law and by Company policy. Records shall be maintained in a manner that permits reconstruction of individual transactions and demonstrates compliance with this Policy.

8. REPORTING SUSPICIOUS ACTIVITY

Employees and agents are required to report promptly any activity that reasonably appears suspicious to the Compliance Officer. The Company shall maintain internal procedures for the receipt, assessment, escalation and, where required, reporting of suspicious activity to competent authorities. The Compliance Officer shall document all assessments and outcomes of reported activity.

9. TRAINING AND MONITORING

The Company shall provide periodic KYC and AML training to relevant personnel. Training shall cover identification of suspicious behavior, verification procedures, reporting obligations, and use of internal systems. The Company shall monitor compliance with this Policy through ongoing reviews and periodic audits.

10. DATA PRIVACY AND CONFIDENTIALITY

The Company shall collect and retain Customer information only as necessary to meet KYC obligations and shall protect the confidentiality of such information. Access to Customer information shall be restricted to authorized personnel on a need-to-know basis and handled in accordance with applicable data protection laws and the Company’s privacy policies.

11. AUDITS AND COMPLIANCE REVIEWS

The Company will conduct periodic internal and external audits of KYC processes, including testing of controls and recordkeeping. Findings shall be documented, remediated within defined timelines, and reported to senior management and the board or its delegate, as appropriate.

12. GOVERNANCE

The Compliance Officer is responsible for maintenance and oversight of this Policy, including updates to reflect changes in law, business practices, or risk. Major changes to the Policy require approval by senior management and, where applicable, the board of directors or its delegate.

13. NOTICES

All notices, requests, consents and other communications required or permitted under this Policy must be in writing and delivered to the addresses set forth in the introductory paragraph or to such other address as a party may designate by notice in accordance with this section. Delivery by electronic mail may be used for internal notices but shall not substitute for formal notice where a legal filing is required.

14. AMENDMENTS; WAIVER

Any amendment to this Policy must be in writing and signed by duly authorized representatives of both parties. No failure or delay by a party in exercising any right under this Policy shall operate as a waiver of that right, and no single or partial exercise of any right shall preclude any other or further exercise of that right.

15. SEVERABILITY

If any provision of this Policy is held to be invalid, illegal or unenforceable for any reason, such provision shall be severed and the remaining provisions shall continue in full force and effect to the maximum extent permitted by law.

16. GOVERNING LAW; ENTIRE AGREEMENT

This Policy shall be governed by and construed in accordance with the laws of the jurisdiction specified here: , without regard to conflicts of law principles. This Policy constitutes the entire agreement between the parties with respect to its subject matter and supersedes all prior agreements and understandings, whether written or oral, relating thereto.

17. COUNTERPARTS

This Policy may be executed in one or more counterparts, each of which will be deemed an original and all of which together will constitute one and the same instrument. Facsimile or electronically transmitted signatures shall be binding for all purposes.

CERTIFICATION

The undersigned certify that they are authorized to execute this Policy on behalf of the party for which they sign, and that the information provided in this Form is accurate to the best of their knowledge. The Representative certifies that the Company has implemented the procedures described herein and shall maintain records demonstrating such implementation.

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