Know Your Customer (KYC)

Know Your Customer Policy. This institution shall implement and maintain a risk-based Know Your Customer (KYC) program to verify the identity of all customers and to understand the nature and purpose of customer relationships in order to develop a customer risk profile. For individual customers, identity verification shall include the collection and verification of, at a minimum: full legal name, date of birth, residential address, and a government-issued identification number (such as a Social Security Number, passport number, or driver's license number). For entity customers, the institution shall obtain: legal name and form of organization, principal place of business, Employer Identification Number (EIN) or equivalent, and identification of all beneficial owners holding twenty-five percent (25%) or more ownership interest. Customer risk profiles shall be reviewed and updated periodically, or upon the occurrence of a triggering event such as unusual transaction activity, significant change in account behavior, or adverse media. High-risk customers shall be subject to Enhanced Due Diligence (EDD), which may include senior management approval, more frequent reviews, and additional documentation requirements.