1. Introduction
AXK Omni Inc. ("AXK Omni," "we," "our," or "us") is committed to preventing financial crime and ensuring compliance with applicable laws and regulations. This Know Your Customer (KYC) Policy outlines our approach to customer identification, verification, and ongoing monitoring to mitigate risks associated with money laundering, terrorist financing, fraud, and other illegal activities.
This policy applies to all customers who use AXK Omni's services and forms an integral part of our broader Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance program.
2. Purpose of KYC
The purpose of our KYC procedures is to:
- Verify the identity of our customers
- Understand the nature of our customers' activities to ensure they are consistent with our knowledge of them
- Identify and mitigate risks associated with money laundering, terrorist financing, fraud, sanctions violations, and other illegal activities
- Meet regulatory requirements in the jurisdictions where we operate
- Protect the integrity of AXK Omni's financial ecosystem
- Maintain trust with our customers, partners, and regulators
By implementing robust KYC procedures, we aim to create a secure environment for all users while ensuring compliance with relevant laws and regulations.
3. Legal Framework
Our KYC policy is designed to comply with various laws and regulations, including but not limited to:
- The Financial Action Task Force (FATF) Recommendations
- The Bank Secrecy Act (BSA) in the United States
- The European Union's Anti-Money Laundering Directives (AMLD)
- The UK Money Laundering Regulations
- The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requirements
- Singapore's Monetary Authority of Singapore (MAS) regulations
- Local AML/CTF laws in countries where we operate
We continuously monitor changes in legal and regulatory requirements to ensure our KYC procedures remain compliant with applicable laws in all jurisdictions where AXK Omni operates.
4. KYC Requirements
Our KYC process consists of the following key components:
4.1 Customer Identification Program (CIP)
We collect the following information to establish the identity of our customers:
For Individual Customers:
- Full legal name
- Date of birth
- Residential address
- Nationality/citizenship
- Government-issued identification number (e.g., passport number, national ID number, driver's license number)
- Contact information (email address and phone number)
For Business Customers:
- Legal business name
- Registration/incorporation number
- Legal form and status
- Registered address and principal place of business
- Nature of business and purpose of the account
- Beneficial ownership information (for owners with 25% or more ownership)
- Information on directors, authorized signatories, and controllers
- Contact information
4.2 Customer Due Diligence (CDD)
As part of our due diligence process, we assess the potential risks associated with each customer relationship. This includes:
- Verifying the information provided by customers
- Understanding the purpose and intended nature of the business relationship
- Assessing the customer's risk profile
- Determining the appropriate level of due diligence required
5. Identity Verification
To verify the identity of our customers, we employ a combination of methods, which may include:
5.1 Document Verification
We verify customer identity through reliable, independent source documents, such as:
- Government-issued photo identification (passport, national ID card, driver's license)
- Proof of address (utility bill, bank statement, official government correspondence)
- For businesses: certificate of incorporation, business registration, articles of association, board resolutions, etc.
5.2 Digital Identity Verification
We utilize advanced technology solutions to facilitate a secure and efficient verification process:
- Biometric verification (facial recognition, fingerprint scanning where available)
- Document authenticity checks using AI-powered verification technology
- Liveness detection to prevent spoofing attempts
- Digital signature verification
5.3 Database Checks
We cross-reference customer information against various databases:
- Sanctions lists (including OFAC, UN, EU, HMT)
- Politically Exposed Persons (PEP) lists
- Adverse media/negative news databases
- Other relevant watchlists and databases
5.4 Additional Verification Methods
Depending on the risk assessment and jurisdictional requirements, we may employ additional verification methods:
- Video identification interviews
- Knowledge-based authentication (KBA)
- Bank account verification
- Phone verification
The verification process must be completed before a customer can fully access our services. In cases where complete verification cannot be achieved, we may restrict or deny service access.
6. Ongoing Monitoring
Our KYC obligations do not end after the initial verification process. We conduct ongoing monitoring of customer accounts and transactions to ensure they remain consistent with our understanding of the customer's profile and risk assessment.
6.1 Transaction Monitoring
We employ automated systems to monitor transactions for unusual or suspicious activities, including:
- Transactions above certain thresholds
- Unusual transaction patterns or frequencies
- Transactions with high-risk countries or regions
- Rapid movements of funds
- Structured transactions designed to avoid reporting thresholds
6.2 Periodic KYC Reviews
We conduct periodic reviews of customer information to ensure it remains current and accurate. The frequency of these reviews is determined by the customer's risk profile:
- High-risk customers: Reviewed at least annually
- Medium-risk customers: Reviewed every 2 years
- Low-risk customers: Reviewed every 3 years
6.3 Trigger-Based Reviews
In addition to periodic reviews, we conduct KYC reviews when certain events occur:
- Significant changes in transaction patterns
- Changes in customer information (address, name, etc.)
- Suspicious activity detection
- Changes in services or products used
- Updates to applicable regulations
During these reviews, customers may be required to provide updated information and documentation to maintain access to our services.
7. Risk Assessment
We employ a risk-based approach to our KYC procedures, allocating resources more efficiently by focusing enhanced due diligence on higher-risk customers.
7.1 Risk Factors
Our risk assessment considers various factors, including:
- Customer risk: Type of customer, profession/business, PEP status, adverse media
- Geographic risk: Country of residence, citizenship, place of business, transaction destinations
- Product/service risk: Type of service used, transaction volumes and values
- Channel risk: How the customer interacts with our services
- Behavioral risk: Transaction patterns, frequency of use
7.2 Risk Categories
Based on our assessment, customers are categorized into risk levels:
- Low risk: Standard KYC procedures apply
- Medium risk: Additional verification steps may be required
- High risk: Enhanced due diligence is mandatory
Risk assessments are reviewed and updated periodically to reflect changes in customer behavior, market conditions, and regulatory requirements.
8. Enhanced Due Diligence (EDD)
For customers identified as high-risk, we apply Enhanced Due Diligence measures, which may include:
- More extensive documentation requirements
- Verification of the source of funds and wealth
- More frequent and detailed transaction monitoring
- Senior management approval for establishing or continuing the business relationship
- Detailed analysis of complex corporate structures and beneficial ownership
- More frequent KYC reviews
8.1 Politically Exposed Persons (PEPs)
We apply EDD measures to customers who are identified as PEPs, which include:
- Current or former senior political figures
- Senior executives of state-owned corporations
- Senior officials of major political parties
- Senior military officers
- Immediate family members of the above
- Close associates of the above
8.2 High-Risk Jurisdictions
Enhanced scrutiny is applied to customers from countries identified as:
- Subject to sanctions, embargoes, or similar measures
- Identified by FATF as non-cooperative in the fight against money laundering and terrorist financing
- Known to have significant levels of corruption, illicit financial activity, or terrorism
- Countries with weak AML/CTF regulations
8.3 Complex Structures
Business entities with complex ownership structures or those registered in offshore jurisdictions are subject to additional scrutiny, including:
- Comprehensive understanding of the ownership and control structure
- Identification of all beneficial owners
- Verification of the business purpose and rationale for the complex structure
- Detailed understanding of the source of funds
9. Data Storage & Protection
We are committed to protecting the personal information we collect during the KYC process:
9.1 Secure Storage
All customer information and documentation are stored securely:
- Data is encrypted both in transit and at rest
- Access to KYC information is restricted to authorized personnel only
- Multi-factor authentication is required for accessing KYC systems
- Regular security audits and assessments are conducted
9.2 Retention Period
We retain KYC information for as long as required by applicable laws and regulations, typically:
- For the duration of the business relationship with the customer
- For a period of at least five years after the termination of the business relationship
- Longer periods may apply based on specific regulatory requirements or legal proceedings
9.3 Data Privacy
Our handling of KYC information complies with applicable data protection laws, including:
- The General Data Protection Regulation (GDPR) in the European Union
- The California Consumer Privacy Act (CCPA)
- Other applicable privacy laws in the jurisdictions where we operate
For more information on how we handle personal data, please refer to our Privacy Policy.
10. Compliance Team
Our KYC program is managed by a dedicated compliance team responsible for:
- Developing and updating KYC policies and procedures
- Overseeing the implementation of KYC processes
- Training staff on KYC requirements and procedures
- Monitoring compliance with KYC policies
- Reviewing and approving high-risk customers
- Investigating suspicious activities
- Filing regulatory reports as required
- Keeping abreast of regulatory changes and updating processes accordingly
10.1 Staff Training
All employees involved in the KYC process receive comprehensive training:
- Initial training upon joining the company
- Regular refresher training
- Updates on regulatory changes and emerging risks
- Specialized training for handling high-risk customers
10.2 Compliance Officer
We have appointed a designated Compliance Officer who has:
- Sufficient authority and independence
- Direct access to senior management
- Resources to effectively discharge their responsibilities
- Expertise in AML/CTF and KYC matters
11. Policy Updates
We review and update our KYC Policy periodically to ensure it remains effective and compliant with regulatory requirements. Factors that may trigger a policy update include:
- Changes in applicable laws and regulations
- New industry best practices
- Internal risk assessments
- Feedback from audits and regulatory examinations
- Changes in our products, services, or customer base
Customers will be notified of significant changes to our KYC requirements that may affect them. The most current version of this policy is available on our website.
