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KYC/AML Policy

Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last updated: May, 31,2025

1. Introduction

1.1. Purpose of the Policy

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy ("Policy") outlines the principles, procedures, and controls implemented by Boursia AI (hereinafter referred to as "the Company," "we," "us," or "our") to prevent and detect money laundering (ML) and terrorist financing (TF) activities. This Policy demonstrates our unwavering commitment to complying with all applicable anti-money laundering and counter-terrorist financing laws, regulations, and best practices in the jurisdictions where we operate.

1.2. Scope of Application

This Policy applies to all employees, contractors, agents, and third-party service providers of the Company, as well as to all products, services, and operations offered by the Company. It covers all customer relationships, transactions, and interactions, regardless of the channel (online, mobile, etc.).

1.3. Commitment to Compliance

The Company is committed to maintaining the highest standards of ethical conduct and regulatory compliance. We recognize the critical role we play in combating financial crime and are dedicated to implementing a robust AML/KYC framework that is proportionate to the risks identified.

2. Definitions

To ensure clarity, the following key terms are defined:

  • Anti-Money Laundering (AML): A set of procedures, laws, and regulations designed to stop the practice of generating income through illegal actions.
  • Know Your Customer (KYC): The process of identifying and verifying the identity of clients. It involves understanding the nature of the client's activities and assessing the risks associated with them.
  • Money Laundering (ML): The process of disguising the origins of illegally obtained money so that it appears to have come from a legitimate source. Typically involves three stages: Placement, Layering, and Integration.
  • Terrorist Financing (TF): The provision or collection of funds, by any means, directly or indirectly, with the intention that they be used, or in the knowledge that they are to be used, in whole or in part, to carry out any terrorist act.
  • Politically Exposed Person (PEP): An individual who is or has been entrusted with a prominent public function, or a family member or close associate of such a person. This includes heads of state/government, senior politicians, judicial or military officials, senior executives of state-owned corporations, and important party officials.
  • Ultimate Beneficial Owner (UBO): The natural person(s) who ultimately owns or controls a customer and/or the natural person on whose behalf a transaction is being conducted.
  • Customer Due Diligence (CDD): The process of identifying and verifying the identity of a customer and understanding the nature of their business.
  • Enhanced Due Diligence (EDD): Additional measures taken for higher-risk customers to mitigate the increased risk of money laundering or terrorist financing.
  • Simplified Due Diligence (SDD): Reduced CDD measures applied to lower-risk customers.
  • Suspicious Transaction Report (STR): A report filed with the financial intelligence unit (FIU) or relevant regulatory authority when a financial institution suspects that a transaction may involve money laundering or terrorist financing.

3. Legal and Regulatory Framework

The Company adheres to the following key international and national AML/KYC laws and regulations:

  • Financial Action Task Force (FATF) Recommendations: We align our policies and procedures with the globally recognized standards set by the FATF, including its 40 Recommendations on AML and TF.
  • Sanctions Lists: Compliance with sanctions imposed by international bodies (UN, OFAC, EU) and national authorities.

The Company's AML/KYC framework will be regularly reviewed and updated to reflect any changes in these laws and regulations.

4. AML Policy Principles

The Company's AML Policy is built upon the following core principles:

4.1. Risk-Based Approach (RBA)

We adopt a risk-based approach to AML/KYC, which means that the intensity of our customer due diligence and ongoing monitoring efforts is proportionate to the money laundering and terrorist financing risks identified. This approach allows us to allocate resources effectively to areas of higher risk. Our RBA considers factors such as:

  • Customer type (e.g., individual, corporate, trust)
  • Geographic risk (e.g., high-risk jurisdictions)
  • Product/service risk (e.g., high-value transactions, complex products)
  • Delivery channel risk (e.g., non-face-to-face relationships)

4.2. Internal Controls

Robust internal controls are in place to ensure compliance with this Policy and relevant regulations. These include:

  • Clear roles and responsibilities for AML/KYC compliance.
  • Segregation of duties to prevent conflicts of interest.
  • Regular internal audits and independent reviews of the AML/KYC program.
  • A dedicated Compliance Officer (see Section 9.1).

4.3. Record Keeping

All records related to customer identification, transactions, and suspicious activity reports are maintained for a period of at least [e.g., five (5) years] after the business relationship ends or the transaction is completed, as required by applicable laws.

4.4. Reporting Obligations

The Company is committed to reporting suspicious activities to the relevant financial intelligence unit (FIU) or regulatory authority in accordance with legal requirements.

5. Know Your Customer (KYC) Policy

The KYC process is fundamental to our AML framework and involves several stages to identify and verify the identity of our customers and understand their financial activities.

5.1. Customer Due Diligence (CDD)

All new customers undergo a comprehensive CDD process before establishing a business relationship. This involves:

5.1.1. Identification and Verification of Individuals

  • Collection of Information: Full legal name, date of birth, nationality, residential address, unique identification number (Passport, national ID, Driver's licence), contact details.
  • Verification: Verification of identity using reliable, independent source documents, data, or information (Government-issued photo ID, proof of address like utility bills). For non-face-to-face relationships, additional measures are taken to mitigate the higher risk.

5.1.2. Identification and Verification of Legal Entities (Companies, Trusts, Partnerships)

  • Collection of Information: Legal name, registered address, principal place of business, tax identification number, legal form, governing law, names of directors/partners/trustees, and identification of the Ultimate Beneficial Owner (UBO).
  • Verification: Verification using official documents (e.g., certificate of incorporation, articles of association, partnership agreements, trust deeds), public registers, and reliable independent sources. Identification and verification of UBOs and individuals exercising control over the entity.

5.1.3. Purpose and Nature of Business Relationship

We will collect information on the purpose and intended nature of the business relationship to ensure it is consistent with the customer's profile and expected activity.

5.2. Enhanced Due Diligence (EDD)

EDD measures are applied to customers identified as high-risk, including but not limited to:

  • Politically Exposed Persons (PEPs): Comprehensive background checks, source of wealth/funds verification, and senior management approval for establishing and continuing the business relationship.
  • Customers from High-Risk Jurisdictions: As identified by FATF or other credible sources.
  • Customers involved in High-Risk Activities: Such as cash-intensive businesses, certain charities, or sectors prone to ML/TF.
  • Complex or Opaque Structures: Entities with complex ownership structures that obscure the UBO.
  • Unusual or Large Transactions: Transactions that appear inconsistent with the customer's known legitimate activities.

EDD measures may include:

  • Obtaining additional identification information.
  • Verifying the source of funds and source of wealth.
  • Obtaining senior management approval for the business relationship.
  • Increased ongoing monitoring of the business relationship.

5.3. Simplified Due Diligence (SDD)

SDD measures may be applied to customers identified as low-risk, where the risk of money laundering or terrorist financing is minimal. This is determined based on a thorough risk assessment. Examples may include:

  • Publicly listed companies subject to regulatory disclosure requirements.
  • Government agencies or public bodies.

SDD does not mean no due diligence; it means the extent of CDD is reduced based on the assessed low risk.

5.4. Ongoing Monitoring

The Company conducts ongoing monitoring of business relationships to ensure that transactions are consistent with our knowledge of the customer, their business, and risk profile. This includes:

  • Transaction Monitoring: Monitoring transactions for unusual patterns, amounts, or types that deviate from expected activity.
  • Periodic Reviews: Regularly reviewing customer information and documentation to ensure it remains current and relevant, especially for higher-risk customers.
  • Ad-hoc Reviews: Reviewing customer profiles and activities when significant changes occur (e.g., changes in ownership, significant increase in transaction volume, negative media reports).

6. Reporting Obligations

6.1. Suspicious Transaction Reports (STRs)

Any employee who suspects that a transaction or activity may be related to money laundering or terrorist financing must immediately report their suspicions to the Company's Compliance Officer. The Compliance Officer will investigate the suspicion and, if warranted, file an STR with the Regulatory Authority in accordance with legal requirements.

6.2. Prohibition of Tipping-Off

Employees are strictly prohibited from "tipping-off" customers or third parties that an STR has been, or may be, filed. This is a criminal offense in many jurisdictions.

7. Training

All relevant employees receive regular and comprehensive training on AML/KYC policies and procedures. This training covers:

  • The latest ML/TF trends and typologies.
  • The Company's internal AML/KYC policies and procedures.
  • Legal and regulatory requirements.
  • How to identify and report suspicious activities.
  • The importance of data protection and privacy in AML/KYC.

Training is provided upon hiring and periodically thereafter, at least annually, or whenever there are significant changes to laws, regulations, or the Company's policies.

8. Record Keeping

The Company maintains comprehensive records of all AML/KYC-related activities, including:

  • Customer identification and verification documents.
  • Records of all transactions.
  • Records of risk assessments and due diligence performed.
  • Internal suspicious activity reports and STRs filed.
  • Training records.
  • Audit reports.

These records are stored securely and are accessible to authorized personnel for a minimum period of ten (10) years after the termination of the business relationship or the completion of the transaction, as mandated by applicable laws.

9. Internal Controls and Audit

9.1. Compliance Officer

The Company has appointed a designated Compliance Officer responsible for overseeing the implementation and effectiveness of the AML/KYC program. The Compliance Officer's responsibilities include:

  • Developing and updating the AML/KYC Policy and procedures.
  • Monitoring compliance with AML/KYC laws and regulations.
  • Receiving and investigating internal suspicious activity reports.
  • Filing STRs with the relevant authorities.
  • Providing AML/KYC training to employees.
  • Acting as the primary point of contact for regulatory bodies concerning AML/KYC matters.

9.2. Internal Audit

The AML/KYC program is subject to regular independent internal audits to assess its effectiveness, identify deficiencies, and recommend improvements. The audit findings and recommendations are reported to senior management and the Board of Directors.

10. Sanctions Compliance

The Company is committed to complying with all applicable financial sanctions regimes imposed by international bodies (UN, OFAC, EU) and national authorities. This includes:

  • Screening customers and transactions against relevant sanctions lists (OFAC Specially Designated Nationals and Blocked Persons List).
  • Prohibiting business relationships and transactions with sanctioned individuals, entities, or jurisdictions.
  • Freezing assets and reporting blocked property as required by law.

11. Policy Review and Updates

This AML/KYC Policy will be reviewed and updated at least annually, or more frequently if there are significant changes in:

  • Applicable laws and regulations.
  • The Company's business activities or products.
  • Identified ML/TF risks.
  • Technological advancements relevant to AML/KYC.

Any amendments to this Policy will be approved by senior management and communicated to all relevant personnel.

Contact

For any questions regarding this Complaints Policy or to file a complaint, you can contact us via:

📧 Email: support@boursiacapital.com

For general inquiries please contact support@boursiacapital.com