Know Your Customer (KYC) Verification
The User identification and verification policies and procedures of the program are designed to:
Ensure adherence with the user identification and KYC policy of FI partners and various State, Federal and International regulators governing the provision of the services;
Ensure adherence with all compliance requirements of FI partners and State/Federal/International regulators;
Promote safe and secured business practices and minimize the risk of the services from being mis utilized for any fraud, money laundering and other illegal activities.
Help monitor and report suspicious activities.
The Platform requires the user to complete their KYC verification for any transaction of the user to be processed and paid out. Any user whose KYC verification is pending may also be allowed to complete other steps unless they are “Suspended”. However, transactions of such users shall not be processed unless the user is verified.
Transaction Limit and KYC Requirements
Our KYC processes are designed in line with the compliance policies of our FI partners including the requirements of the Banking Secrecy Act (BSA) and all other State, Federal and International Money Transfer Regulations. This requires collection of certain information from users during the registration and based on the amount and volume of transactions. Accordingly, we have devised a Tier based KYC program which governs the transaction limit and KYC requirements for each tier. The Tier based KYC system is included in your specification sheet.
At the time of registration, a user is always registered in Tier I of the CIP. A user may request for a tier upgrade which will then require them to provide information required for the particular tier in accordance with the CIP.
KYC Information
The KYC information required from a user shall depend on the CIP applicable for the service. During the signup process or at the time of Tier Upgrade, the user will be prompted to provide the information required for verification as per the applicable CIP for the service.
The KYC information provided by the user shall be verified to complete the KYC verification of a user.
Identification Documents (ID)
In accordance with the CIP of the service, a user may be required to provide a valid ID for the purpose of their KYC verification or Tier Upgrade. The user will be required to provide information such as the ID type, ID number, Expiry Date along with a copy of ID. The Customer Support Representative shall ensure that the ID provided by the user is:
an acceptable type of ID,
a valid ID;
according to ID Criteria outlined below
Acceptable ID Types
In the case of individual users, an acceptable type of ID is the following unexpired IDs issued by the US Government:
US Federal Government issued Passport
US Federal or State Government issued ID or
State Government issued Driver’s License
Examples for InValid ID
The ID has holes punched in it
The ID is stamped
ID Criteria
The ID copies uploaded by users are required to meet the following criteria:
Name on the ID should match the Name provided by the user during signup
Photo image of the ID should be taken on a flat surface
The ID should be uploaded only in .jpeg or .jpg format
Photo image of the ID should be in color
All four (4) corners of the ID should be visible in the uploaded copy
The uploaded copy should not have any shadow or lighting effects
All the details on the ID, for example, photo of the user, expiry date, etc. should be clearly visible
The uploaded copy or any part of it should be human and machine readable
Note: SMP should inform the users of the above ID criteria.
KYC Status
The KYC verification process is an automated process conducted on a real time basis. During this verification process, the user is placed under various KYC Statuses as described below:
Unverified Status
A user is placed in “Unverified” status until their KYC information has been submitted for verification.
Retry Status
A user is placed in “Retry” status when the user is not verified automatically in the first instance, however, the verification does not require any SMP review. The user will be required to enter the last 4 digits or full Social Security Number (SSN). If the user cannot be verified with the SSN, the user is then moved to “Review Pending” status.
Document Status
A user is placed in “Document” status when SMP review the document submitted by the user cannot be verified. In this case, the user will be notified via email that the user has been moved to “Document” Status. The Customer Support Representative shall ask the user to reupload the document in the required format. The ID may be uploaded by the user, SMP or SMP. After the new document is uploaded, verification usually takes upto two (2) business days, however, the verification may take longer depending upon the case.
Review Pending Status
A user is placed in “Review Pending” status in the following scenarios:
· If the user is not verified after “Retry” status.
· After user submits additional information or document requested in “Retry Requested”/ “Document Requested” status.
Under “Review Pending” status, the user will be placed under SMP review for KYC verification. The SMP shall inform the SMP regarding any further information and/or document that will be required to verify the user by placing the user under “Retry Requested” or “Document Requested” status. Upon review, the SMP may move a user in “Review Pending” status to other KYC statuses as they deem sufficient. However, a user cannot be moved back to “Unverified” status.
Retry Requested Status
A user is placed in “Retry Requested” status if the user is required to edit existing information or submit additional information based on SMP review. Once the user has edited/submitted required information, they will be moved to “Review Pending” status.
Please note that details such as email, State and phone number entered by the user at the time of signup cannot be edited by the user when they are in “Retry Requested” status.
Document Requested Status
A user is placed in “Document Requested” status if the user is required to submit additional document based on SMP review. Once the user has submitted the required document, they will be moved to “Review Pending” status. Documents that may be requested from the user include:
· Identification Document
· Proof of address
· Proof of income/source of funds
Suspended Status
A user in “Suspended” status is not allowed to conduct any activity in the system. A user may be placed in “Suspended” status for one or more of the following reasons:
The Platform identifies anything suspicious during the Verification process of the user;
Identification of any AML, fraud or compliance risk with the user (whether or not the user is a verified user);
Any discrepancy in the KYC documents and information provided by the user;
The SMP can move users to other KYC status as mentioned above except to a “Verified” status. SMP shall change KYC status of users or take other actions as per the KYC notes and next steps suggested in Annexure II. Inyo shall perform necessary verification on the users before placing them on “Verified” status.
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