Know Your Customer (KYC) Policy

1. Introduction

AuroraEx Limited ("AuroraEx," "we," "our," or "us") is committed to maintaining the highest standards of regulatory compliance and preventing financial crime. This Know Your Customer (KYC) Policy outlines our approach to customer identification, verification, and ongoing monitoring in accordance with applicable laws and regulations.

KYC procedures are a critical component of our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) program. They help us verify the identity of our clients, understand the nature of their activities, and assess money laundering and terrorist financing risks.

This policy applies to all clients who use our Services, including our website, mobile application, and trading platform. By using our Services, you agree to comply with our KYC procedures as described in this policy.

2. Regulatory Framework

Our KYC procedures are designed to comply with applicable laws and regulations, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations;
• The Bank Secrecy Act (BSA) and its implementing regulations;
• The USA PATRIOT Act;
• The European Union Anti-Money Laundering Directives;
• Local AML/CTF laws and regulations in the jurisdictions where we operate.

We regularly review and update our KYC procedures to ensure ongoing compliance with evolving regulatory requirements.

3. KYC Principles

Our KYC procedures are based on the following principles:

• Risk-Based Approach: We apply a risk-based approach to KYC, allocating resources based on the level of risk associated with different clients, products, services, and jurisdictions.
• Customer Acceptance: We establish clear criteria for customer acceptance, including the identification of high-risk clients who require enhanced due diligence.
• Customer Identification: We collect and verify the identity of our clients using reliable, independent source documents, data, or information.
• Ongoing Monitoring: We conduct ongoing monitoring of client relationships and transactions to ensure they are consistent with our knowledge of the client, their business, and risk profile.
• Record Keeping: We maintain records of all client identification information and transactions for a period specified by applicable laws and regulations.

4. Customer Identification and Verification

Before establishing a business relationship with any client, we require the following information and documents:

4.1 Individual Clients

For individual clients, we require:

• Personal Information: Full name, date of birth, nationality, residential address, contact information (email address and phone number).
• Identification Document: A valid government-issued photo identification document, such as a passport, national ID card, or driver's license.
• Proof of Address: A recent utility bill, bank statement, or official government correspondence (issued within the last 3 months) showing your name and address.
• Additional Information: Depending on your risk profile, we may request additional information, such as your occupation, source of funds, or source of wealth.

4.2 Legal Entity Clients

For legal entity clients, we require:

• Entity Information: Legal name, registration number, registered address, business address, contact information, nature of business, and corporate structure.
• Entity Documents: Certificate of incorporation, memorandum and articles of association, certificate of good standing, and other relevant corporate documents.
• Beneficial Ownership Information: Identification of all individuals who own, directly or indirectly, 25% or more of the entity, or who exercise control over the entity through other means.
• Director and Authorized Representative Information: Identification of all directors and authorized representatives of the entity.
• Individual Identification Documents: For beneficial owners, directors, and authorized representatives, the same identification documents as required for individual clients.
• Additional Information: Depending on the entity's risk profile, we may request additional information, such as financial statements, business plan, or source of funds.

5. Verification Process

We verify the identity of our clients through a combination of automated and manual processes:

• Document Verification: We verify the authenticity of identification documents using advanced document verification technology that checks for signs of tampering or forgery.
• Biometric Verification: We may use facial recognition technology to compare the photo in your identification document with a selfie or video that you provide.
• Address Verification: We verify your address using the proof of address document that you provide.
• Database Checks: We check your information against various databases, including sanctions lists, politically exposed persons (PEPs) lists, and adverse media databases.
• Manual Review: In some cases, our compliance team may conduct a manual review of your information and documents to ensure accuracy and completeness.

The verification process typically takes 1-3 business days, but may take longer in certain cases, such as for high-risk clients or if additional information is required.

6. Enhanced Due Diligence

We apply enhanced due diligence (EDD) measures for higher-risk clients, including:

6.1 Politically Exposed Persons (PEPs)

We identify whether a client or beneficial owner is a politically exposed person (PEP), defined as an individual who is or has been entrusted with a prominent public function, as well as their family members and close associates.

For PEPs, we apply enhanced due diligence measures, including:

• Obtaining senior management approval for establishing or continuing the business relationship;
• Taking reasonable measures to establish the source of wealth and source of funds;
• Conducting enhanced ongoing monitoring of the business relationship.

6.2 High-Risk Jurisdictions

We apply enhanced due diligence measures for clients from high-risk jurisdictions, including:

• Countries identified by the FATF as having strategic AML/CTF deficiencies;
• Countries subject to sanctions, embargoes, or similar measures;
• Countries identified as having significant levels of corruption or other criminal activity;
• Countries identified as providing funding or support for terrorist activities.

6.3 High-Risk Business Activities

We apply enhanced due diligence measures for clients engaged in high-risk business activities, including:

• Cash-intensive businesses;
• Money service businesses;
• Casinos and gambling operations;
• Arms dealers;
• Real estate transactions involving high-value properties;
• Dealers in precious metals, stones, or other high-value goods.

6.4 Complex Ownership Structures

We apply enhanced due diligence measures for clients with complex ownership structures, including:

• Multiple layers of ownership;
• Use of nominee shareholders or directors;
• Involvement of trusts, foundations, or similar legal arrangements;
• Ownership or control through offshore entities.

7. Ongoing Monitoring

We conduct ongoing monitoring of our client relationships to ensure that the transactions are consistent with our knowledge of the client, their business, and risk profile. This includes:

• Transaction Monitoring: We monitor client transactions for unusual or suspicious patterns that may indicate money laundering, terrorist financing, or other financial crimes.
• Periodic Reviews: We conduct periodic reviews of client information to ensure it remains accurate and up-to-date. The frequency of these reviews depends on the client's risk profile.
• Risk Reassessment: We reassess the client's risk profile based on changes in their information, transaction patterns, or other relevant factors.
• Sanctions Screening: We regularly screen our client database against updated sanctions lists to identify any matches.

If we detect any unusual or suspicious activity, we may request additional information or documentation from the client, or take other appropriate actions, including filing a suspicious activity report with the relevant authorities.

8. Client Obligations

As a client of AuroraEx, you have the following obligations:

• Provide accurate, current, and complete information during the account registration and KYC process;
• Submit clear and legible copies of all required documents;
• Respond promptly to any requests for additional information or documentation;
• Update your information if there are any changes to your personal details, contact information, or other relevant information;
• Comply with all applicable laws and regulations related to financial transactions.

Failure to comply with these obligations may result in delays in account opening, restrictions on account functionality, or termination of the business relationship.

9. Data Protection and Confidentiality

We are committed to protecting the privacy and confidentiality of our clients' information. All information and documents collected as part of our KYC procedures are handled in accordance with our Privacy Policy and applicable data protection laws.

We implement appropriate technical and organizational measures to protect your information against unauthorized access, loss, or damage. We only share your information with third parties as described in our Privacy Policy or as required by law.

We retain your information and documents for a period specified by applicable laws and regulations, after which they are securely deleted or anonymized.

10. Changes to This Policy

We may update this KYC Policy from time to time to reflect changes in regulatory requirements, our business practices, or other relevant factors. Any changes will become effective when we post the revised policy on our website or platform.

We encourage you to periodically review this policy to stay informed about our KYC procedures.

11. Contact Information

If you have any questions about this KYC Policy or our verification procedures, please contact us at:

AuroraEx Limited

Email: [email protected]