Know Your Customer (KYC) Policy

STARTUP SMART DEVELOPMENT LTD, registered in Hamchaku, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros, operating under the international financial license with registration number 15559, trading under the brand name Perfect Money, is committed to complying with all applicable laws and regulations regarding the Know Your Customer (KYC) procedure. This policy is designed to establish client identification procedures and assess their risks.

Objective

1.1 Ensuring compliance with laws and regulations regarding client identification and verification.
1.2 Establishing procedures for collecting, verifying, and storing client information.
1.3 Preventing the use of the company's products and services for illegal purposes.
1.4 Ensuring a high level of trust and security for clients and partners.

Scope

2.1 This policy applies to all new and existing clients of Perfect Money. It applies to all company employees responsible for attracting, servicing, and monitoring clients, as well as any operations conducted through the Perfect Money platform.

Client Identification

3.1 Individuals:

• Clients must provide a valid passport or other identification document with a photo.
• A document confirming the residential address (e.g., utility bill or bank statement) is also required.

3.2 Legal Entities:

• Company Director must provide a valid passport or other identification document with a photo and a document confirming the residential address (e.g., utility bill or bank statement).
• The company must provide registration documents, including the charter and certificate of registration.
• Information on beneficial owners and individuals with control over the company.

Verification and Authentication

4.1 Verification Procedures:

• All provided documents are checked for authenticity.
• Independent and reliable sources are used to verify the client's identity and address.
• Additional checks through specialized databases are conducted if necessary.

4.2 Updating Information:

• Clients are required to regularly update the provided information.
• In case of changes in personal data or residential address, the client must notify the company as soon as possible.

4.3 Additional Checks:

• High-risk clients are subject to more thorough checks.
• Regular monitoring of client activity is conducted to identify suspicious actions.

Risk Assessment

5.1 Client Categorization:

• All clients are classified into low, medium, and high-risk categories.
• Assessment criteria include the client's origin, jurisdiction, geographic location, type of services, and behavioral characteristics.

5.2 High-Risk Level:

• Clients from high-risk jurisdictions are subject to more thorough checks.
• Public figures (PEP) and clients holding high positions in government bodies are considered.

5.3 Continuous Monitoring:

• High-risk clients are continuously monitored for their transactions and activity.
• All suspicious actions are immediately documented and reported to the responsible person.

Monitoring and Reporting

6.1 Continuous Monitoring:

• All client transactions are continuously monitored to identify suspicious activity.
• Automated systems are used to analyze and identify transaction anomalies.

6.2 Reporting Suspicious Activity:

• All suspicious transactions and actions must be immediately reported to the responsible KYC officer.
• The responsible person evaluates the information and, if necessary, reports the suspicious activity to the relevant authorities.

6.3 Documentation:

• All monitoring and reporting actions are documented and stored for the period established by law.
• Records include information about the client, a description of the suspicious activity, and the actions taken.

Training and Awareness

7.1 Training Program:

• All employees working with clients must undergo training on KYC procedures.
• Training includes familiarization with current regulatory requirements, methods for identifying suspicious activity, and practical cases.

7.2 Raising Awareness:

• Regular information sessions are held to raise employee awareness of the importance of KYC policy compliance.
• Employees are informed about new risks and methods to combat them.

7.3 Training Effectiveness Evaluation:

• The effectiveness of the training program is evaluated through testing and employee surveys.
• Results are used to improve the training program and adapt to new requirements.

Internal Checks and Audit

8.1 Planned Checks:

• Internal checks are conducted regularly to assess the effectiveness of KYC measures.
• Checks include assessing compliance with policies, procedures, and documentation requirements.

8.2 Audit:

• Independent internal audits are conducted to verify KYC policy compliance and identify potential weaknesses.
• Audit results are presented to the board of directors and used to improve processes and procedures.

8.3 Reporting:

• The results of checks and audits are documented and stored for the period established by law.
• All reports and recommendations for improvement are immediately reviewed and implemented by the company's management.

Compliance with Regulatory Requirements

9.1. Legislative Compliance:

• Perfect Money commits to complying with all applicable laws and regulations in the jurisdictions where it operates.
• Regular legal consultations and policy updates are conducted to ensure compliance with new requirements.

9.2 Interaction with Other Financial Institutions:

• The company cooperates with other financial institutions to exchange information and experience in the KYC field if necessary.
• Joint actions and information exchange are aimed at improving methods and procedures for client identification.

Documentation and Record Keeping

10.1 Record Keeping:

• The company keeps detailed records of all client identification (KYC) procedures, risk assessments, and transaction monitoring.

10.2. Confidentiality:

• All information collected in the KYC policy compliance process is considered confidential and protected from unauthorized access.
• Only authorized employees responsible for KYC requirements have access to the information.

10.3 Electronic Documentation:

• The company uses modern systems for storing and managing electronic documentation.
• All electronic records are protected using advanced encryption and access control technologies.

Conclusion

The KYC policy of Perfect Money aims to ensure compliance with the legislative requirements of the Union of Comoros, protect the company from risks, and maintain a high level of trust from clients and partners. All employees must strictly comply with this policy and actively participate in its implementation.