Know Your Customer (KYC) Policy
URIGHTCOMPANY FINANCE LIMITED
FINTRAC Registration Number: C100000462
1. Purpose
This policy outlines the processes and procedures used by URIGHTCOMPANY FINANCE LIMITED to verify the identity of its corporate clients and ensure compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC regulations, and international KYC standards.
2. Scope
Applies to all business clients of URIGHTCOMPANY FINANCE LIMITED and any party authorized to act on behalf of a business.
3. Client Identification Requirements (B2B)
Prior to establishing a business relationship, we must collect and verify the following information:
A. For the Legal Entity:
– Full legal name
– Business registration number and certificate
– Registered office address and operational address (if different)
– Nature and purpose of business relationship
– Description of business activities
– Source of funds
B. For the Beneficial Owners (25%+ ownership or control):
– Full name
– Date of birth
– Address
– Proof of identity (e.g., passport)
– Proof of address (e.g., utility bill)
C. For Authorized Representatives:
– ID verification (government-issued ID)
– Position within the company
– Authority documentation (e.g., board resolution, power of attorney)
4. Verification Methods
Independent government or public registry databases
Certified true copies of documents
Reliable electronic verification tools
Sanctions and PEP screening
5. Ongoing Due Diligence
KYC data is reviewed annually
Enhanced Due Diligence (EDD) applied in cases such as:
– Politically Exposed Persons (PEPs)
– High-risk jurisdictions
– Unusual transaction behavior
Monitoring includes analysis of changes in client structure, business model, or activities
6. Record Keeping
All KYC-related information is securely stored for a minimum of 5 years after the end of the business relationship. Records include:
– Copies of verification documents
– Risk assessments and profiles
– Communication logs
– Updated KYC forms
7. Sanctions and PEP Screening
All clients are screened against:
– UN, EU, OFAC, and Canadian sanctions lists
– Politically Exposed Persons (PEP) databases
Any matches are escalated to the Compliance Officer for review and potential reporting.
8. Client Risk Assessment
Each client is assigned a risk level (low, medium, high) based on:
– Country of registration
– Industry and business model
– Transaction volume
– Ownership structure
– History of suspicious activity
9. Training
All employees involved in onboarding or verification undergo:
– Initial KYC compliance training
– Annual refresher training
– Role-specific updates for relevant departments
10. Policy Review
This KYC Policy is reviewed annually or upon major regulatory or procedural changes.