Know Your Customer / Know Your Business Policy

1. Introduction

Anton Payments, Inc. maintains comprehensive Know Your Customer (KYC) and Know Your Business (KYB) procedures to verify the identity of our customers, understand their business activities, and assess the risks they present. These procedures are essential components of our Anti-Money Laundering (AML) and fraud prevention programs.

This policy applies to all merchants, business customers, and individual users of our payment processing services.

2. Legal and Regulatory Requirements

Our KYC/KYB procedures are designed to comply with:

• Bank Secrecy Act (BSA) and USA PATRIOT Act requirements
• FinCEN Customer Due Diligence (CDD) Rule
• European Union Fourth and Fifth Anti-Money Laundering Directives
• UK Money Laundering Regulations
• State money transmitter licensing requirements
• Other applicable KYC/KYB requirements in jurisdictions where we operate

3. Know Your Customer (KYC) - Individual Customers

For individual customers, we collect and verify the following information:

3.1 Identity Verification

• Full Legal Name: As it appears on government-issued identification
• Date of Birth: To verify age and identity
• Residential Address: Current physical address
• Government-Issued ID: Driver's license, passport, or national ID card
• Tax Identification Number: SSN, EIN, or equivalent where required
• Contact Information: Email address and phone number

3.2 Verification Methods

We use multiple methods to verify customer identity, including:

• Document verification (ID scanning and validation)
• Biometric verification (facial recognition where available)
• Database checks (credit bureaus, identity verification services)
• Address verification (utility bills, bank statements)
• Liveness detection to prevent identity fraud

4. Know Your Business (KYB) - Business Customers

For business customers, we collect and verify comprehensive business information:

4.1 Business Information

• Legal Business Name: Registered name of the business
• Business Type: Corporation, LLC, partnership, sole proprietorship, etc.
• Registration Number: Business registration or incorporation number
• Tax Identification Number: EIN, VAT number, or equivalent
• Business Address: Registered business address
• Operating Address: Physical location where business operates
• Website and Business Description: Nature of business activities

4.2 Beneficial Ownership

We identify and verify beneficial owners (individuals who own or control 25% or more of the business), including:

• Name, date of birth, and address of each beneficial owner
• Percentage of ownership or control
• Government-issued identification
• Verification of identity using the same methods as individual customers

4.3 Authorized Representatives

We verify individuals authorized to act on behalf of the business, including:

• Authorized signatories and account administrators
• Identity verification for each authorized representative
• Documentation of authorization (corporate resolutions, power of attorney)

4.4 Business Documentation

We collect and verify business documentation, including:

• Certificate of incorporation or business registration
• Articles of incorporation or organization
• Operating agreement or bylaws
• Business licenses and permits (where applicable)
• Tax registration documents
• Bank account verification

5. Risk Assessment

We conduct risk assessments for all customers based on:

• Customer Type: Individual vs. business, business model, industry
• Geographic Risk: Country of operation, jurisdiction risk rating
• Transaction Risk: Expected transaction volumes, types, and patterns
• Product Risk: Types of payment services used
• Reputation Risk: Public information, adverse media, sanctions

Customers are categorized as low, medium, or high risk, which determines the level of due diligence applied.

6. Enhanced Due Diligence (EDD)

For higher-risk customers, we apply enhanced due diligence measures, including:

• Additional identity and business verification
• Source of funds verification
• Enhanced background checks and adverse media screening
• More frequent account reviews and monitoring
• Senior management approval
• Ongoing monitoring and periodic re-verification

7. Ongoing Monitoring

KYC/KYB is not a one-time process. We conduct ongoing monitoring of customer relationships, including:

• Periodic re-verification of customer information
• Monitoring for changes in customer profile or risk level
• Transaction monitoring for unusual or suspicious activity
• Updates to beneficial ownership information
• Review of business licenses and regulatory status

Re-verification is conducted at least annually for high-risk customers and as needed for others based on risk assessment.

8. Data Protection and Privacy

All KYC/KYB information is collected, processed, and stored in accordance with our Privacy Policy and applicable data protection laws, including GDPR and CCPA. We implement appropriate security measures to protect customer information.

9. Record Keeping

We maintain comprehensive records of all KYC/KYB activities, including:

• Customer identification and verification documents
• Risk assessments and due diligence reports
• Beneficial ownership information
• Verification results and supporting documentation
• Ongoing monitoring and review records

Records are retained in accordance with applicable legal requirements (typically 5-7 years after account closure).

10. Failure to Provide Information

If a customer fails to provide required KYC/KYB information or if we are unable to verify their identity or business information, we may:

• Request additional documentation or information
• Suspend account access until verification is complete
• Refuse to establish a business relationship
• Terminate an existing relationship if verification cannot be completed
• Report suspicious activity to appropriate authorities

11. Third-Party Service Providers

We may use third-party service providers to assist with KYC/KYB verification, including:

• Identity verification services
• Document verification providers
• Business information databases
• Credit bureaus and screening services
• Adverse media and sanctions screening providers

All third-party providers are subject to appropriate due diligence and contractual requirements to ensure data security and compliance.

12. Updates to This Policy

This KYC/KYB Policy is reviewed and updated regularly to reflect changes in laws, regulations, and industry best practices. Customers will be notified of material changes that affect them.

13. Contact

For questions about our KYC/KYB procedures or to provide updated information, please contact:

Anton Payments, Inc.
Compliance Department
Email: [email protected]
KYC Support: [email protected]