Know Your Customer (KYC) Policy

Policy Statement & Scope

Universal Financial Associates Inc (“the Company”) is committed to complying with all applicable anti-money laundering (AML) and counter-
terrorism financing (CTF) laws and regulations. 

This Know Your Customer KYC Policy outlines the procedures and measures that the Company will implement to identify and verify the identity of Company ́s customers, understand the nature of our customers’ activities, and assess the risks associated with these activities. This KYC Policy applies to all employees, departments, and business units of the Company involved in customer interactions, customer onboarding, and ongoing customer due diligence.

Objectives

  • To ensure compliance with all applicable KYC, AML, and CTF laws and regulations.

  • To prevent the Company being used for money laundering, terrorist financing, and other illicit activities.

  • To protect the integrity and reputation of the Company.

  • To establish a systematic approach for identifying, verifying, and monitoring customers.

KYC Procedures

Customer Identification:
Universal Financial Associates Inc will collect and verify information to establish the identity of Company ́s customers before establishing a business relationship or conducting transactions. This includes obtaining:
  • Full legal name
  • Date of birth (for individuals)
  • Nationality or citizenship
  • Residential or business address
  • Identification number (e.g., Social Security Number, Tax Identification Number)
  • Valid government-issued identification (e.g., passport, driver’s license)
Customer Verification:
The information provided by the customer will be verified using reliable and independent sources. This may include:
  • Verification of identification documents
  • Cross-checking against public records or databases
  • Utilizing third-party verification services
Enhanced Due Diligence (EDD):
For higher-risk customers, the Company will conduct enhanced due diligence. This may include:
  • Obtaining additional information on the customer’s business activities and source of funds
  • Conducting more frequent and detailed reviews of the customer’s transactions
  • Monitoring the business relationship on an ongoing basis

Risk Assessment

Customer Risk Profiling:
Customers will be assigned a risk profile based on various factors, including:
  • The type of customer and their business activities
  • The geographic location of the customer and their transactions
  • The nature and purpose of the business relationship
  • The customer’s transaction patterns and history
Ongoing Monitoring:
he Company will continuously monitor customer transactions to identify and report any unusual or suspicious activities. This includes:
  • Regularly reviewing and updating customer information
  • Monitoring transaction patterns for inconsistencies with the customer’s known profile
  • Investigating any significant changes in the customer’s behavior or transaction activity

Reporting and Record-Keeping

Reporting Suspicious Activities:

Employees are required to report any suspicious activities or transactions to the designated Compliance Officer. The Compliance Officer will investigate and, if necessary, report to the appropriate authorities, such as the Financial Crimes Enforcement Network (FinCEN). 

Record-Keeping:
The Company will maintain accurate and complete records of all KYC documentation and due diligence activities. These records will be kept for a minimum of five years following the termination of the business relationship or the completion of the transaction. Records to be maintained include:
  • Customer identification and verification documents
  • Risk assessment and due diligence records
  • Transaction records and monitoring reports
  • Reports of suspicious activities

Training and Awareness

Employee Training:
Universal Financial Associates Inc will provide regular training to employees on KYC, AML, and CTF requirements. Training will cover:
  • The legal and regulatory framework for KYC, AML, and CTF
  • Procedures for customer identification and verification
  • Methods for identifying and reporting suspicious activities
  • The importance of ongoing monitoring and risk assessment
Awareness Programs:

Awareness programs will be conducted to ensure that employees understand the significance of KYC and their role in preventing money laundering and terrorist financing.

Compliance and Review

Compliance Officer:

The Compliance Officer is responsible for implementing and overseeing the KYC policy, ensuring compliance with relevant laws and regulations, and acting as the primary point of contact for regulatory inquiries. 

Policy Review:
This policy will be reviewed annually or more frequently if required by regulatory changes or business needs. Updates to the policy will be communicated to all relevant employees and stakeholders.