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Policies

Browse our policies below.

🌐 KYC Policy

KYC Policy

1. Purpose and Scope

This policy outlines the Know Your Customer (KYC) procedures to comply with Czech laws, including Act No. 253/2008 Coll. on AML. It applies to all customers, employees, and third parties involved in customer onboarding and monitoring under the VSOP license.

2. Objectives

  • Prevent money laundering and terrorist financing.
  • Verify customer identities effectively.
  • Mitigate risks through due diligence and monitoring.
  • Ensure compliance with Czech AML regulations and GDPR.

3. Core KYC Procedures

3.1 Customer Identification

All customers must provide valid identification:

  • Individual Clients:
    • Full name, date of birth, address, and nationality.
    • Government-issued photo ID (e.g., passport, national ID).
    • Address proof (e.g., utility bill, bank statement, max 3 months old).
  • Non-Face-to-Face Verification:
    • Video verification or digital signatures.
    • Two-factor authentication where necessary.

3.2 Due Diligence Measures

  • Standard CDD:
    • Identify the client and verify their identity.
    • Establish the purpose of the relationship.
  • Enhanced Due Diligence (EDD) for High-Risk Customers:
    • Politically Exposed Persons (PEPs).
    • Customers from high-risk jurisdictions.
    • Unusual or high-value transactions.
    • Additional documentation (e.g., source of funds and wealth).

3.3 Risk-Based Approach (RBA)

  • Classify customers as low, medium, or high risk.
  • Automate risk scoring through approved tools.
  • Focus resources on high-risk profiles for closer scrutiny.

3.4 Ongoing Monitoring

  • Continuously review transactions to detect anomalies.
  • Flag and investigate unusual or suspicious activity.
  • Update customer profiles periodically or upon risk changes.

4. Reporting and Record-Keeping

4.1 Suspicious Activity Reporting

  • Flag suspicious transactions or behaviours internally.
  • Report confirmed suspicions to the Financial Analytical Office (FAU) promptly.

4.2 Record Retention

  • Maintain all customer and transaction records for at least 10 years.
  • Retain risk assessments, identification documents, and monitoring logs securely.

4.3 Data Protection

  • Comply with GDPR and Czech data protection laws.
  • Secure customer data using encryption and restricted access.

5. Training and Accountability

  • Regular training for employees on KYC, AML, and data protection compliance.
  • Clear escalation procedures for suspicious activity.
  • Accountability at all levels:
    • Compliance Officer: Ensures policy adherence and regulatory reporting.
    • Employees: Follow KYC procedures and escalate issues promptly.
    • Management: Allocate resources and oversee policy implementation.

6. Policy Governance

6.1 Non-Compliance Consequences

  • Revocation of VSOP license.
  • Regulatory fines or penalties.
  • Disciplinary actions for employees.

6.2 Policy Review

  • Annual policy review or updates based on regulatory changes.

7. Approval and Implementation

This policy is approved by Kem Finity’s board and effective as of 01/01/2025. All employees and partners must comply fully with the outlined procedures.

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