Know Your Customer Policy

1. Introduction

SollCard is committed to maintaining the highest standards of customer identification and verification in accordance with applicable Know Your Customer (KYC) regulations. This policy outlines our comprehensive procedures for identifying, verifying, and monitoring our customers to prevent fraud, money laundering, and other illicit activities.

Our KYC procedures are designed to ensure compliance with international standards, including those set by the Financial Action Task Force (FATF), and applicable local regulations in all jurisdictions where we operate.

2. Purpose and Scope

This KYC Policy serves several critical purposes:

2.1 Regulatory Compliance

• Compliance with anti-money laundering (AML) regulations
• Adherence to counter-terrorist financing (CTF) requirements
• Meeting international KYC standards and best practices
• Fulfilling reporting obligations to regulatory authorities

2.2 Risk Management

• Identification and mitigation of customer-related risks
• Prevention of fraudulent account creation and usage
• Protection of legitimate customers and our platform
• Maintenance of the integrity of our services

2.3 Business Operations

• Ensuring appropriate service delivery to verified customers
• Maintaining accurate customer records and profiles
• Enabling effective customer support and communication
• Supporting business growth and expansion

3. Definitions

For the purposes of this KYC Policy, the following definitions apply:

• "Beneficial Owner" means the natural person who ultimately owns or controls a customer
• "CDD" means Customer Due Diligence
• "EDD" means Enhanced Due Diligence
• "KYC" means Know Your Customer
• "PEP" means Politically Exposed Person
• "Sanctions" means economic and trade sanctions imposed by governments
• "Source of Funds" means the origin of money or assets used in transactions
• "Source of Wealth" means the means by which a customer acquired their wealth

4. KYC Requirements

All customers must meet the following KYC requirements:

4.1 Mandatory Verification

• Complete identity verification process
• Provide valid government-issued identification
• Submit proof of residential address
• Complete source of funds verification

4.2 Documentation Standards

• All documents must be clear, legible, and unaltered
• Documents must be current and not expired
• Photocopies must be of high quality and complete
• Digital documents must be properly authenticated

4.3 Verification Timeline

• Initial verification must be completed before account activation
• Additional verification may be required for high-risk customers
• Periodic re-verification is required for ongoing compliance
• Immediate verification may be required for certain transactions

5. Identity Verification Procedures

Our identity verification process includes multiple layers of verification:

5.1 Primary Identity Documents

Customers must provide one of the following primary identity documents:

• Passport: Valid international passport with photo and signature
• Driver's License: Valid government-issued driver's license
• National ID Card: Government-issued national identification card
• Military ID: Valid military identification card (where applicable)

5.2 Document Verification Process

• Visual inspection for authenticity and tampering
• Cross-reference with government databases where available
• Biometric verification using advanced technology
• Third-party verification through trusted providers

5.3 Additional Verification Methods

• Knowledge-based authentication questions
• Biometric verification (facial recognition, fingerprint)
• Document verification through trusted third parties
• Video verification for high-risk customers

6. Address Verification

We verify customer addresses through multiple methods:

6.1 Acceptable Address Documents

• Utility Bills: Electricity, gas, water, or internet bills (within 3 months)
• Bank Statements: Official bank statements (within 3 months)
• Government Correspondence: Tax notices, social security letters
• Insurance Documents: Home, auto, or health insurance statements
• Rental Agreements: Signed lease or rental agreements

6.2 Address Verification Process

• Document authenticity verification
• Cross-reference with multiple sources
• Geolocation verification for digital services
• Physical address verification where necessary

6.3 Special Requirements

• P.O. Box addresses are not accepted as primary addresses
• Business addresses may be accepted for business customers
• International addresses require additional verification
• High-risk jurisdictions may have additional requirements

7. Source of Funds Verification

We verify the legitimacy of customer funds through comprehensive procedures:

7.1 Employment Verification

• Employment verification letters from employers
• Pay stubs and salary statements
• Tax returns and W-2 forms
• Professional license verification

7.2 Business Income Verification

• Business registration and incorporation documents
• Financial statements and tax returns
• Bank statements and transaction records
• Audited financial reports (for large businesses)

7.3 Investment and Asset Verification

• Investment account statements
• Property ownership documents
• Inheritance or gift documentation
• Cryptocurrency transaction history

7.4 Source of Wealth Documentation

• Detailed explanation of wealth accumulation
• Historical financial records
• Professional and business background
• Family wealth and inheritance documentation

8. Ongoing Monitoring

We continuously monitor customer accounts and activities:

8.1 Transaction Monitoring

• Real-time analysis of transaction patterns
• Automated alerts for unusual activities
• Regular review of account activity
• Risk-based monitoring frequency

8.2 Customer Profile Updates

• Regular review of customer information
• Updates to risk profiles based on activity
• Re-verification of high-risk customers
• Documentation of profile changes

8.3 Sanctions and Watchlist Screening

• Ongoing screening against sanctions lists
• PEP database monitoring
• Adverse media monitoring
• Regular updates to screening databases

9. Documentation Requirements

We maintain comprehensive documentation of all KYC processes:

9.1 Customer Files

• Complete customer identification records
• Verification documentation and evidence
• Risk assessment and profiling information
• Ongoing monitoring records and updates

9.2 Record Retention

• Customer records: 5 years after account closure
• Transaction records: 5 years from transaction date
• Verification documents: 5 years after last verification
• Monitoring records: 5 years from creation date

9.3 Documentation Standards

• All documents must be properly indexed and cataloged
• Digital copies must be high quality and searchable
• Access controls must be implemented and maintained
• Regular audits of documentation completeness

10. Data Protection and Privacy

We protect customer information in accordance with applicable privacy laws:

10.1 Data Security

• Encryption of all customer data at rest and in transit
• Secure storage and access controls
• Regular security audits and assessments
• Employee training on data protection

10.2 Privacy Rights

• Customers have the right to access their information
• Right to correction of inaccurate information
• Right to deletion under certain circumstances
• Right to data portability where applicable

10.3 Third-Party Sharing

• Limited sharing with authorized service providers
• Regulatory reporting as required by law
• No sale of customer information to third parties
• Transparent disclosure of data sharing practices

11. Contact Information

For questions about this KYC Policy or to request information about your verification status, please contact:

This KYC Policy is effective as of January 1, 2024, and was last updated on January 1, 2024.