Know Your Customer (KYC) Policy

1. Purpose

Innoteq Engage Limited (“we”, “us”, “our” or “the Company”) is committed to implementing and maintaining robust procedures to verify the identity of our customers and understand the nature of our business relationships. This Know Your Customer (KYC) Policy outlines our approach to meeting the regulatory requirements set forth by the UK’s Anti-Money Laundering (AML) regulations, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

 

2. Scope

This KYC Policy applies to all employees, agents, contractors, and any parties involved in customer onboarding or ongoing customer relationship management. The policy covers customer verification procedures, due diligence, record-keeping, monitoring, and reporting.

 

3. Objectives

The primary objectives of our KYC policy are to:

• Ensure compliance with AML and anti-terrorist financing regulations.
• Identify and verify the identity of our customers.
• Prevent illegal activities such as money laundering, fraud, and terrorist financing.
• Manage risks associated with customers and business relationships.

 

4. KYC Procedures

 

4.1 Customer Identification Program (CIP)

The Customer Identification Program (CIP) is the first step in establishing a new business relationship. This process includes:

• Collecting basic information about the customer, including name, date of birth, address, and identification documents.
• Verifying the identity of the customer using government-issued documents or reliable independent sources.
• For corporate customers, verifying business information, including Company registration documents, director information, and beneficial ownership.

 

4.2 Customer Due Diligence (CDD)

Customer Due Diligence (CDD) is performed for all customers. This process involves:

• Identifying the customer and verifying their identity.
• Assessing the customer’s risk profile, including understanding the purpose and intended nature of the business relationship.
• For high-risk customers, applying Enhanced Due Diligence (EDD) as required (see Section 4.3).

 

4.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is conducted for customers or transactions that present a higher risk, including but not limited to:

• Politically Exposed Persons (PEPs).
• Customers from high-risk jurisdictions identified by the Financial Action Task Force (FATF).
• Customers involved in high-value or unusual transactions.

EDD procedures include collecting additional information, such as the source of funds and wealth, increased monitoring of customer activities, and more frequent reviews of the customer relationship.

 

4.4 Ongoing Monitoring

We conduct ongoing monitoring of customer relationships to identify any unusual or suspicious activity. This includes:

• Regularly updating customer information and reassessing risk profiles.
• Monitoring transactions to detect patterns or behaviours that deviate from expected activity.
• Investigating any discrepancies or potential red flags and taking appropriate action.

 

5. Record-Keeping

Innoteq Engage Limited maintains records of all customer identification, verification, and due diligence documentation, including:

• Copies of customer identification documents.
• Records of transactions and monitoring activities.
• Evidence of due diligence procedures performed.

All records are retained for at least five years after the termination of the business relationship or completion of a transaction, in accordance with UK regulations.

 

6. Reporting Obligations

 

6.1 Suspicious Activity Reporting (SAR)

If an employee suspects any unusual or suspicious activity related to money laundering, fraud, or terrorist financing, they must report it to their Line Manager or Supervisor immediately. They will assess the report and, if necessary, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

6.2 External Reporting

In cases where a SAR is submitted to the NCA, Innoteq Engage Limited will comply fully with the regulatory requirements, including any requests for additional information and/or updates from the NCA.

 

7. Risk Assessment

We conduct regular risk assessments to understand the potential exposure to money laundering and terrorist financing activities. Our risk assessment considers factors such as:

• Customer types (e.g., high-risk customers, PEPs).
• Geographic risk, based on FATF and HM Treasury high-risk jurisdiction lists.
• Types of products and services offered and associated risks.

The results of the risk assessment are used to enhance our policies and controls as necessary.

 

8. Training and Awareness

Innoteq Engage Limited provides regular training to all employees on AML and KYC requirements. Training includes:

• Recognising and reporting suspicious activities.
• Understanding customer due diligence and enhanced due diligence processes.
• Staying up to date with regulatory changes and best practices.

All employees must complete mandatory KYC and AML training as part of the onboarding process and participate in regular refresher sessions.

 

9. Review of Policy

This KYC Policy is reviewed annually or as required by regulatory changes, industry developments, or changes in the Company’s risk profile. All updates will be communicated to relevant staff, and additional training will be provided if necessary.

 

Contact Information

For questions regarding this policy, please contact direct them to our office at 515 Battersea Park Road, London, England, SW11 3BN or to our Legal Compliance Department at legal@innoteqengage.co.uk.

Last updated: 03/2025