KYC and AML policy

1. Introduction

Know Your Customer (KYC) and anti-money laundering (AML) procedures exist to make sure financial services are not used for crime. They also include counter-terrorist financing (CTF) controls. We carry them out because UK law requires it and because they protect honest clients from fraud and account theft.

The rules that shape this policy are the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the UK sanctions regime.

2. What is KYC?

KYC is the process of identifying a client and confirming that the details given are true. In practice it means matching your name, date of birth and address to documents issued by a trusted authority, and checking that the person using the account is the person on those documents.

3. What are AML controls?

AML covers everything we do to prevent and detect money laundering after a client has been verified. It includes assessing the risk each client presents, monitoring activity for unusual patterns, keeping records and reporting suspicions to the National Crime Agency when the law requires it.

4. Why identity checks are required

Verification does four jobs at once. It stops fraudsters opening accounts with stolen details, it protects your account if someone later tries to take it over, it keeps us compliant with the rules above, and it reduces the financial risk that illegal activity poses to every client of the platform.

5. Documents we use

We only ask for what we actually use:

• Proof of identity: a valid passport, a UK photocard driving licence or a national identity card.
• Proof of address: a bank statement or utility bill dated within the last three months, showing your name and current address.
• Liveness check: a short selfie or video taken in the app, compared with the photo on your ID.

Mobile phone contracts, screenshots of statements and documents that have been edited or cropped are not accepted. Documents should show all four corners, be in colour and be in focus, and a clear photograph taken in good light is normally enough.

6. The verification process

1. Register. You create an account with your name, email address and mobile number.
2. Submit. You upload your documents and complete the liveness check from your phone or computer.
3. Automatic check. Software reads the documents, tests that they are genuine and compares the face to your selfie.
4. Manual review. If the software cannot decide, a trained member of the onboarding team looks at the case.
5. Result. You are told by email and in the dashboard whether you are verified or what is still needed.

7. Enhanced due diligence

Some situations carry a higher risk, for example a large deposit relative to the stated income, a link to a high-risk country, or a political connection. In those cases we apply enhanced due diligence (EDD). That may mean asking where your funds come from, requesting a payslip, a tax return or a sale agreement, and seeking senior sign-off before the account can continue. Being asked for more information does not mean you have done anything wrong: it is a routine part of the process for some profiles, and the request will explain what we need and why.

8. How long verification takes

Most clients are verified automatically within a few minutes. When a manual review is needed, it is normally completed within two business days. Enhanced due diligence can take longer, depending on how quickly the extra documents arrive and how complex the source of funds is. Your manager can tell you what is outstanding at any point. Withdrawals are not released until verification is complete, so it is sensible to do the checks soon after you register rather than waiting until you want to take money out.

9. Reasons a check may be rejected or paused

• The document is expired, damaged, unreadable or not an accepted type.
• The name or address on the document does not match the details on the account.
• We suspect a document has been altered or forged.
• The liveness check does not match the photo, or was not completed.
• Requested information, such as the source of funds, has not been provided.
• A sanctions or fraud screening returns a match that cannot be cleared.

You can submit corrected documents at any time. If we have to close an account for compliance reasons, we are sometimes legally prevented from explaining why.

10. Monitoring of activity

After verification, deposits, withdrawals and trading patterns are screened automatically for signs of money laundering, such as funds moving in and out with no trading in between. If something looks unusual, we may ask questions, limit certain features or hold a payment while we look into it. We may be legally forbidden from telling you if a report has been made, and doing so ourselves would be an offence. Monitoring is carried out by software first, with trained staff reviewing the alerts, so a single odd payment does not by itself lead to action against an account.

11. Your responsibilities

You must give accurate, current and genuine information and documents, and tell us promptly if your name, address or circumstances change. Providing false information or using someone else's identity can lead to account closure, funds being frozen and, in serious cases, a report to law enforcement.

12. Storage and protection of data

Identity documents and check results are stored in encrypted form with restricted access. The law requires us to keep identification records for five years after our relationship with you ends. How we handle that data in general is described in our Privacy Policy.

13. Who receives your KYC data

We share KYC information only where necessary, with identity verification providers who run the document and liveness checks for us, IT service suppliers under contract, other companies in our group, and regulators, the National Crime Agency or other public authorities when the law requires it. Each supplier is bound by a data protection agreement, may only use the data to carry out the check we asked for, and is subject to the same security standards as our own systems. We do not sell KYC data and we do not share it for marketing.

14. Compliance with the rules

We follow the requirements that relate to our business, including the Money Laundering Regulations 2017, the cryptoasset transfer information rules sometimes called the Travel Rule, which require certain details about the sender and recipient to travel with a transfer, financial sanctions administered through HM Treasury and OFSI, and UK GDPR for the personal data involved. We review our risk assessment and procedures regularly and train our staff accordingly.

15. Contact

If you have a question about verification, write to [email protected] with "KYC" in the subject line and the Client Support and Compliance team will reply within one working hour during support hours.