1. CUSTOMER IDENTIFICATION PROCEDURE
In case a transaction is spotted by our risk scoring system as suspicious, the transaction will be put on hold, and we will collect the following information from the customers, if applicable, from any person, entity, or organization:
- the full name;
- date of birth (for an individual);
- the address, which will be residential and business street address (for an individual) or a principal place of business, local office, or other physical location (for a person other than an individual);
- for an individual, a valid government-issued identification, evidencing nationality or residence and bearing a photograph or a similar safeguard, such as a driver’s license or passport; and for a person other than an individual, documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement or a trust instrument.
1.2 Customers Who Provide Misleading Information
After providing the information, the customer must ensure that the information is true, complete, and timely updated. If there are any grounds for believing that any of the information customer provided is incorrect, false, outdated, or incomplete, we reserve the right to send the customer a notice to demand correction and, as the case may be, blacklist the existing account and terminate all or part of the services we provide for the said customer.
1.3 Verifying Information
Based on the risk, and to the extent reasonable and practicable, we will proceed with the verification to the extent that we have collected all information needed in order to know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers.
We will verify the information within a reasonable time, depending on the nature of the account and risk level of transactions. We may refuse to complete a transaction before we have verified the information, or in some instances, when we need more time, we may, pending verification, suspend transactions under suspicion.
1.4 Lack of Verification
When we cannot form a reasonable belief that we know the true identity of a customer, we will request additional information.
1.5 Notice to Customers