AML/KYC Policy

Introduction

UCI has in place an Anti-Money Laundering / Counter-Terrorist Financing Policy and a Know Your Customer Policy (collectively the "AML Policies"). Policies are revisited periodically and amended based on prevailing industry standards and international regulations designed to facilitate the prevention of illicit activity, including money laundering and terrorist financing. All senior management and employees of UCI are required to acknowledge and be familiar with the Policies. This document covers AML Policies regarding UCI's broker (non-exchange) services, which is UCI's primary business.

Money Laundering Risks

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds. The proceeds appear to have derived from legitimate origins or constitute legal assets. Terrorist financing is an attempt to conceal either the source of the funds or their intended use, which could be for criminal purposes..


The risk of money laundering or terrorist financing on UCI is extremely low

UCI does not engage in any exchange transactions between currencies, whether in crypto or fiat. UCI uses third party crypto transaction monitoring and source of funds software to track and tag funds deposited into its platform. Such control makes it extremely unattractive for potential attempts to move illicit funds. All client funds are converted into FIAT currency, and deposited into UCI bank account and remains under the control of UCI. UCI requires KYC identification documents from all clients before any transaction takes place. KYC is an extra measure of risk reduction and compliance.


AML/KYC Policies Framework

The purpose of policies is to:

  • Prevent UCI from being used intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities;
  • Enable UCI to know and understand its customers, contributors and other contacts UCI has financial dealings with (collectively "clients"), their financial background, and source of funds better. In turn, this helps to manage risks prudently;
  • Put in place appropriate controls for detection and reporting of suspicious activities under applicable laws, procedures and regulatory guidelines;
  • Equip employees and contractors of UCI with the necessary training and measures to deal with matters concerning KYC/AML procedures and reporting obligations.

Policies will be reviewed and updated regularly. Reviews will ensure that appropriate procedures and internal controls are in place to account for both changes in regulations and changes in our business.


Risk-Based Approach

UCI 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 RBA checks shall be conducted. Checks ensure that the client's identity does not match with any person of known criminal background or with banned entities such as individual terrorists or terrorist organizations;
  • For risk categorization relevant information shall be obtained from the clients before entering into a transaction;
  • The risk categorization process for different types of clients may take into account the client's background, country of origin, source of funds, the volume of turnover or deposits, as well as social and financial background;
  • The outcome of the risk categorization process shall be based on the relevant information provided by the client at the commencement of a business relationship;
  • For higher-risk clients, especially those for whom the source of funds is unclear, or for transactions of higher value and frequency, enhanced due diligence would be required. Such due diligence shall be at the sole discretion of UCI;
  • UCI must be able to satisfy the authorities that due diligence was observed based on UCI's risk profile and by adherence to relevant legislation.

Customer Identification

The Customer Identification Program is to be carried out:

  • before any financial transaction can be made;
  • when there is any doubt about the authenticity, veracity, or adequacy of the previously obtained clients' identification data

UCI:

  • requires clients to provide proof of identification and proof of residence;
  • does not under any circumstances permit any transaction to be made with incomplete identity and residency verification information.

When there is suspicion of money laundering or terrorism financing activities, or where there is any doubt about the adequacy or veracity of previously obtained clients' identification data, due diligence measures shall be reviewed. This includes verifying the client identity again and obtaining information regarding the intended nature of the relationship with UCI. UCI does not serve clients from regions that are deemed to be high-risk or unwelcoming from a legal or regulatory perspective. Regions include Cuba, Iran, North Korea, Syria, and the United States of America.

Sanctions

UCI does not open accounts or transact with individuals who appear on prescribed sanctions lists. UCI screens against United Nations, European Union, UK Treasury, US Office of Foreign Assets Control (OFAC), and other sanction lists in jurisdictions where UCI operates.



Politically Exposed Persons

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


Required Information

UCI accepts only natural persons as clients, and 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 corporate Documents.
  • Letter of good standing.

All submitted client information is reviewed manually. For clients who cannot be verified through automated means including geolocation, algorithmic face detection or 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 colour image. Black and white photos or watermarked images are not accepted
  • • Legible. All information on the ID must be clear and readable. UCI does not accept IDs that are torn or worn out
  • • Background: 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 three 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 cannot be older than three months.


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 smiling. This allows UCI to easily prove that the client's picture was not stolen or photo shopped, and is being used exclusively for UCI.

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 investing at uci.global only
  • must contain the Client’s signature

Verification

Based on the degree of risk and to the extent of reasonable and practicable, we ensure that we know the true identity of our customers. We use risk-based procedures to verify and document the accuracy of the information we receive about clients. Our AML Compliance Officer analyses the information we obtain to determine whether it 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 geolocation checks); and
  • Obtaining a notarized or certified true copy of an individual’s birth certificate or government-issued ID for valid identification

Internal controls

UCI implements and maintains internal controls. These controls ensure that UCI operations comply with AML legal requirements. Controls also include submission of essential reports on time.


Compliance Officer

  • The Compliance Officer is the person, duly authorized by UCI, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of UCI’s anti-money laundering and counter-terrorist financing, including but not limited to: Collecting Clients’ identification information;
  • Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations
  • Monitoring transactions and investigating any significant deviations from normal activity;
  • Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs
  • Updating risk assessment regularly
  • Providing law enforcement with information as required under the applicable laws and regulations. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing, and other illegal activity

Monitoring and Reporting

UCI diligently monitors transactions for suspicious activity. Unusual transactions are carefully reviewed to determine if they make no apparent sense or appear to be for an unlawful purpose. When such suspicious activity is detected, the Compliance Officer will determine whether filing with any law enforcement authority is necessary.


Suspicious activity can include more than just suspected money laundering attempts. As a result of suspicious activity, UCI may wish to report to a law enforcement authority, even if no money is lost as a result of the suspicious activity.


The Compliance Officer initially decides whether a transaction is potentially suspicious. Once the Compliance Officer has finished his review of the transaction details, they decide whether the transaction meets the definition of suspicious. The CO decides whether any filings with law enforcement authorities are required.


"Suspicious Transaction" means a transaction or attempted transaction to a person acting in good faith:

  • gives rise to a reasonable ground of suspicion that it may involve proceeds of criminal or other illicit activity, regardless of the value involved
  • appears to be made in circumstances of unusual or unjustified complexity;
  • appears to have no economic rationale or bona fide purpose; and
  • gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism

Ongoing monitoring is an essential element of effective implementation. UCI diligently monitors transactions for suspicious transactions and other suspicious activity


Record-keeping

Our AML Compliance Officer is responsible for ensuring that AML records are maintained properly.


We document our verification, including all identifying information provided by a client, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We keep records containing a description of any document that we relied on to verify a client's identity. We note the type of document, any identification number listed in the document, the place and date of issuance and the expiration date. Concerning non-documentary verification, we retain documents that describe the methods and the results of any measures we took to verify the identity of a client.


We also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We retain records of all identification information for seven years after the account has been closed, or as long as reasonably necessary to comply with applicable regulations. We retain records about verification of the customer's identity for seven years after the record is made, or for as long as is reasonably necessary to comply with applicable regulations.


Training

All new employees receive anti-money laundering training as part of the mandatory new-hire training program. All applicable employees are also required to complete AML and KYC training annually. Participation in additional targeted training programs is compulsory for all employees with day-to-day AML and KYC responsibilities.


Our training includes, at a minimum: (1) How to identify red flags and signs of money laundering that arise during the course of the employees' duties; (2) What to do once the risk is identified including how, when and to whom to escalate unusual customer activity or other red flags (3) Employee roles in UCI's compliance efforts and how to perform them; (4) UCI's record retention policy; and (5) tDisciplinary consequences including civil and criminal penalties for non-compliance


Our operations are regularly reviewed to check whether certain employees require specialized additional training. Written procedures are updated to reflect any such changes