Know Your Customer (KYC) Policy

1.0. Introduction

SPACETRADE TECHNOLOGIES LIMITED (‘Spacetrade’) Know Your Customer (KYC) Policy is designed to prevent fraudulent activities and ensure that all customers accessing our services are properly verified. This policy aims to safeguard SPACETRADE’s platform from illegal activities by verifying customer identities, assessing their risk levels, and maintaining accurate records. This policy complies with local and international KYC requirements, including regulations set by the Financial Action Task Force (FATF) and local authorities such as the Central Bank of Nigeria (CBN).

2.0. Purpose

The purpose of this KYC Policy is to:

• Establish a standardized process for customer identification and verification.
• Assess and manage customer risks effectively to prevent illegal activities on SPACETRADE’s platform.
• Ensure compliance with global and local KYC regulations, promoting transparency and security.

3.0. Scope

This policy applies to:

• All SPACETRADE customers, both new and existing.
• SPACETRADE employees involved in onboarding, customer service, and compliance.
• Any third-party service providers conducting KYC procedures on behalf of SPACETRADE.

4.0. Definitions

• Know Your Customer (KYC):A process to verify the identity of customers and assess their risk levels to prevent financial crimes.
• Customer Due Diligence (CDD):The procedures conducted to verify customer identities and evaluate their risk profiles.
• Enhanced Due Diligence (EDD):Additional verification measures applied to high-risk customers to mitigate potential risks.
• Politically Exposed Person (PEP):An individual with a prominent public role, who may pose a higher risk due to potential connections to corruption or bribery.

5.0. Customer Identification and Verification (CIV)

SPACETRADE implements a robust Customer Identification and Verification (CIV) process to authenticate customer identities effectively. This process includes:

• Collection of Personal Identifiable Information (PII):During account registration, customers must provide the following details:
  • Full name
  • Date of birth
  • Residential address
  • Nationality
  • Government-issued identification (e.g., passport, driver's license)
• Document Verification:Government-issued IDs and proof of address are verified against trusted databases to ensure authenticity. This includes cross-checking against local or international databases as appropriate.
• Face Verification and Liveness Check:Customers are required to undergo a liveness check via selfie or video to confirm they are the legitimate account holders and match their submitted ID.
• Additional Verification for Corporate Accounts:For corporate customers, KYC documentation includes registration details, proof of business address, and identification of authorized individuals and beneficial owners.

6.0. Customer Due Diligence (CDD)

SPACETRADE applies Customer Due Diligence (CDD) procedures to assess customer risk at onboarding and throughout the relationship.

• Standard CDD:All customers must undergo standard CDD, which involves collecting and verifying their PII. This information is used to assess the customer's initial risk level.
• Ongoing Monitoring:SPACETRADE performs continuous monitoring of customer accounts and transactions to identify any activity inconsistent with the customer's profile.
• Periodic Information Updates:Customers may be required to update their personal information periodically to ensure accuracy. This includes updating IDs, address verification, and other relevant details as needed.

7.0. Enhanced Due Diligence (EDD) for High-Risk Customers

SPACETRADE performs Enhanced Due Diligence (EDD) on customers deemed high-risk due to factors such as their geographic location, occupation, or PEP status.

• Additional Documentation:High-risk customers must provide additional documentation to verify their source of funds and source of wealth.
• More Frequent Monitoring:Transactions of high-risk customers are monitored more frequently and closely to detect potential risks.
• Approval Requirement:EDD customers must receive explicit approval from SPACETRADE's compliance team before account creation or significant transactions.
• Periodic Profile Review:EDD customers are reviewed regularly to assess if their risk status remains appropriate. This review considers transaction patterns and any changes in the customer's background or business activities.

8.0. Risk-Based Approach to Customer Classification

SPACETRADE adopts a risk-based approach to KYC compliance, categorizing customers into different risk levels to allocate compliance resources efficiently.

• Risk Assessment Criteria:Factors influencing risk assessment include:
  • Customer's geographic location, particularly if from high-risk jurisdictions.
  • Customer's industry or occupation, particularly for industries with higher AML risk.
  • Transaction behavior and frequency.
  • PEP status or links to high-risk individuals.
• Risk Scoring and Classification:Customers are assigned a risk score and categorized as low, medium, or high risk. This classification determines the level of due diligence required.
• Dynamic Risk Adjustments:Risk classifications are reviewed and adjusted as needed, based on new information or changes in customer behavior.

9.0. Onboarding Process

The customer onboarding process at SPACETRADE is designed to ensure thorough KYC compliance from the outset.

• Document Collection and Verification:Customers must submit all necessary documents, which are verified before the account is activated.
• Risk Scoring and Approval:Each new customer undergoes an initial risk assessment. High-risk customers require further documentation and explicit approval before onboarding.
• Provisional Access:Customers may have provisional access to limited features while their identity verification is pending. Full access is granted only upon completion of the KYC process.

10.0. Ongoing Customer Monitoring and Transaction Review

SPACETRADE continuously monitors customer accounts and activities to identify and address unusual behavior. Ongoing monitoring procedures include:

• Behavioral Monitoring:Transactions are analyzed to ensure consistency with the customer's profile. Any significant deviations trigger additional review or EDD procedures.
• Screening Against Sanctions Lists:Customers are continuously screened against relevant sanctions lists, including OFAC, UN sanctions lists, and any regional or national watchlists.
• Regular Updates to Risk Profiles:Risk profiles are periodically updated based on ongoing transaction behavior, regulatory updates, and emerging risks.

11.0. Record-keeping and Data Retention

SPACETRADE maintains accurate records of all KYC processes to comply with regulatory standards and ensure data integrity.

• Data Retention Period:Customer identity and transaction records are retained for at least five years after the end of the customer relationship.
• Detailed Record Content:Retained records include customer identification documents, transaction history, risk assessments, and any additional due diligence performed.
• Secure Data Storage:Customer records are stored in an encrypted database with access restricted to authorized personnel, ensuring compliance with data protection laws.

12.0. Data Privacy and Protection

SPACETRADE values customer privacy and is committed to protecting personal information throughout the KYC process.

• Compliance with Data Privacy Laws:SPACETRADE complies with relevant data protection regulations, such as GDPR and local privacy laws.
• Data Encryption:All KYC data is encrypted and stored securely to prevent unauthorized access.
• Access Control:Only authorized personnel have access to sensitive customer data, ensuring confidentiality and data integrity.

13.0. Employee Training and Awareness

SPACETRADE provides regular training to ensure all employees understand and comply with KYC procedures.

• Mandatory Training:Employees involved in customer onboarding, compliance, and customer support receive mandatory KYC training upon hiring and annually thereafter.
• Role-Specific Training:Staff in compliance and risk management receive advanced training on high-risk customer verification and identifying suspicious activities.
• Ongoing Education:Training programs are updated regularly to incorporate regulatory changes, industry best practices, and emerging trends in KYC.

14.0. Monitoring and Reporting For Compliance

SPACETRADE’s Compliance Officer is responsible for overseeing KYC procedures and ensuring adherence to regulatory requirements.

• Compliance Reviews:Regular reviews and audits are conducted to ensure KYC processes remain effective and compliant with regulatory expectations.
• Reporting to Authorities:In cases of suspected fraudulent or illegal activities, SPACETRADE promptly reports to the relevant authorities, including the Nigerian Financial Intelligence Unit (NFIU) and other applicable regulatory bodies.

15.0. Penalties For Non-Compliance

Non-compliance with KYC procedures is taken seriously, with penalties enforced for employees, customers, or third-party service providers who violate these standards.

• Employee Penalties:Employees failing to comply with KYC standards may face disciplinary action, including termination of employment
• Customer Penalties:Customers providing false information or failing to meet KYC standards may have their accounts suspended or terminated.
• Third-Party Penalties:Service providers that fail to adhere to SPACETRADE’s KYC standards face termination of contract and possible legal action.

16.0. Policy Review and Updates

SPACETRADE reviews its KYC Policy regularly to keep pace with regulatory changes and evolving industry standards.

• Annual Review:The Compliance Officer conducts an annual review of the KYC Policy, incorporating audit findings, feedback, and regulatory updates.
• Immediate Amendments for New Regulations:Significant regulatory changes trigger immediate policy updates to ensure continued compliance.
• Stakeholder Communication:Policy updates are communicated to all relevant stakeholders, including employees, customers, and third-party partners.

17.0. Conclusion

SPACETRADE’s KYC Policy is integral to its commitment to maintaining a secure, compliant platform for cryptocurrency transactions. This policy upholds the principles of customer transparency, regulatory compliance, and robust risk management, helping SPACETRADE foster a safe environment for all users.