KYC/AML Policy

Offshorix is committed to maintaining compliance with the UK's Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations to prevent financial crime and protect our clients. This policy aligns with the standards provided by the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 and FCA guidelines.

1. Purpose and Scope

This policy applies to all clients, partners, and transactions associated with Offshorix. Our KYC/AML procedures are designed to:

• Verify the identity of our clients
• Understand the nature of their business activities
• Assess money laundering and terrorist financing risks
• Monitor transactions for suspicious activities
• Maintain accurate and up-to-date records

2. Customer Due Diligence (CDD)

2.1 Individual Clients

We require the following documentation for individual clients:

• Valid government-issued photo ID (passport, driving license)
• Proof of address (utility bill, bank statement, dated within 3 months)
• Source of funds declaration
• Additional documentation may be required based on risk assessment

2.2 Corporate Clients

For corporate entities, we require:

• Certificate of incorporation
• Memorandum and articles of association
• Register of directors and shareholders
• Corporate structure chart for complex organizations
• Ultimate Beneficial Owner (UBO) declaration
• Financial statements and business activity documentation

3. Risk Assessment

We conduct risk assessments based on:

• Geographic location and jurisdiction
• Business type and industry
• Transaction patterns and volumes
• Corporate structure complexity
• Political exposure (PEP screening)

4. Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to:

• High-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Complex corporate structures
• High-value transactions
• Unusual transaction patterns

5. Ongoing Monitoring

We maintain continuous monitoring of:

• Transaction patterns and behaviors
• Changes in client information or circumstances
• Periodic review of high-risk clients
• Suspicious activity reporting
• Regular update of client documentation

6. Record Keeping

We maintain records for a minimum of 5 years including:

• Client identification documents
• Transaction records
• Risk assessments
• Due diligence reports
• Correspondence and meeting notes

7. Staff Training

Our staff undergo regular training on:

• KYC/AML regulations and updates
• Identification of suspicious activities
• Customer due diligence procedures
• Record keeping requirements
• Reporting procedures

8. Reporting Procedures

We have established procedures for:

• Internal suspicious activity reporting
• External reporting to relevant authorities
• Confidential reporting channels
• Documentation of investigations
• Cooperation with law enforcement

9. Compliance Officer

Our designated Compliance Officer is responsible for:

• Overseeing KYC/AML program implementation
• Reviewing and updating policies
• Managing regulatory reporting
• Conducting internal audits
• Staff training coordination

10. Policy Updates

This policy is reviewed and updated:

• Annually at minimum
• When regulations change
• Following internal audits
• After significant incidents
• Based on risk assessment results