RC Capital Solutions Limited - KYC Policy

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RC Capital Solutions Limited

KYC Policy

Risk-Based Approach

RC Capital Solutions Limited (“RCCS”) adopts and maintains a Risk-Based Approach (“RBA”) towards assessing and containing the money laundering and terrorist financing risks arising from any transactions it has with Clients. The guidelines are as follows:

Before entering into any transaction or proposed transaction, necessary checks shall be conducted in line with the RBA so as to ensure that the identity of the Clients does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations;

For the purpose of risk categorization of the Clients, the relevant information shall be obtained from the Clients at or before the time of entering into a transaction.

The risk categorization process for different types of Clients may take into account the background of the Clients, country of origin, sources of funds, volume of turnover or deposits, as well as social and financial background;

The outcome of the risk categorization process shall be decided based on the relevant information provided by the Clients at the time of commencement of business relationship;

Enhanced due diligence would be required for higher-risk Clients, especially those for whom the sources of funds are not clear, or for transactions of higher value and frequency, which shall be determined by RCCS at its sole and absolute discretion; and

RCCS must be able to satisfy the competent authorities that due diligence was observed based on the risk profile of the RCCS in compliance with the relevant legislations in place.

Customer Identification

The Customer Identification Program is to be carried out:

· before any financial transaction can be made; and

· when there is any doubt about the authenticity, veracity, or adequacy of the previously obtained Clients’ identification data.

RCCS:

· requires Clients to provide proof of identification and proof of residence; and

· does not under any circumstances permit any transaction to be made with incomplete identity and residence verification information.

When there shall be any suspicion of money laundering or terrorism financing activities, or where there shall be any doubt about the adequacy or veracity of previously obtained Clients’ identification data, the due diligence measures shall be reviewed, including verifying the identity of the Client again and obtaining information regarding the purpose and intended nature of the relationship with RCCS.

RCCS does not serve clients from certain regions that are deemed high-risk or unwelcoming from a legal or regulatory perspective, including Cuba, Iran, North Korea, Syria, and the United States of America.

Sanctions

RCCS does not open accounts or transact with individuals that are on prescribed sanctions lists. RCCS screens against United Nations, European Union, UK Treasury, US Office of Foreign Assets Control (OFAC), and other sanctions lists in all jurisdictions in which RCCS operates.

Politically Exposed Persons

RCCS does not open accounts or transact with individuals who are Politically Exposed Persons (PEPs), or their family members. RCCS screens all Clients against global PEP lists before they are allowed to establish a relationship with RCCS.

Required Information

RCCS accepts only natural persons as Clients, not legal entities. Upon registration, Clients go through an automated verification process where they submit:

· Full name;

· Date of birth;

· A unique photo of them holding their government-issued photo ID.

All submitted client information is manually reviewed. For clients who cannot be verified through automated means (geolocation, algorithmic face detection, sanctions list check), enhanced due diligence is requested as described below.

Government-issued ID

Verification of identity is required by obtaining a high-resolution, non-expired copy of the Client’s government-issued ID (passport, national identity card, or a driver’s license). The submitted imaged requirements include:

· Full color image. Black and white, watermarked, etc. are not accepted;

· Legible. All information on the ID must be completely clear and readable. RCCS does not accept IDs that are torn or worn out; and

· Background. The edges of the ID document must be clearly visible on a contrasting background.

Proof of residence

Verification of residence is required by obtaining a copy of an acceptable address proof document issued in the 3 months prior to establishing an account. The document must carry the Client’s name and address.

A valid proof of residence document can be:

· bank statement;

· debit or credit card statement;

· utility bill (water, electricity, gas, internet, phone);

· payroll statement or official salary document from employer;

· insurance statement;

· tax document; or

· residence certificate.

· Proof of residence documents must contain the Client’s name, address, and be dated less than 3 months ago.

Unique photo of Client

Further verification is requested from Clients by submitting a unique photo of themselves holding their government-issued ID as well as a unique handwritten note. In the photo, the Client must be visibly smiling. This allows RCCS to easily prove that the Client’s picture was not stolen or photoshopped, and is being used exclusively for RCCS.

The ID the Client holds in their hand:

· must be the same government-issued ID the Client submitted previously; and

· must be fully clear and readable.

· The note the Client holds in their hand:

· must be handwritten (not typed);

· must be in English;

· must contain today's date;

· must contain the sentence: For trading at wcex.com only; and

· must contain the Client’s signature.

Verification

Based on the risk, and to the extent reasonable and practicable, we ensure that we have a reasonable belief that we know the true identity of our customers by using risk- based procedures to verify and document the accuracy of the information we obtain about Clients. Our AML Compliance Officer analyzes the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer.

We may decide to use the following non-documentary methods of verifying identity:

Independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database or other source;

Checking references with other financial institutions;

Analyzing whether there is logical consistency between the identifying information provided, such as the Clients’ name, street address, postal code, and date of birth;

Utilizing complex device identification (such as “digital fingerprints” or IP geo- location checks); and obtaining a notarized or certified true copy of an individual’s birth certificate or government-issued ID for valid identification.

Various tools and independent checking options are also used in cases where doubt about identity or the reasons for a transaction are detected.

Richard Creed

Compliance Officer

RC Capital Solutions Limited