KYC/AML policy

KYC/AML/KYT
policy

KYC/AML/KYT POLICY
LLC Financial Alliance
Effective Date: July 17, 2025

1. PURPOSE OF THE DOCUMENT
This Policy sets out the internal procedures and measures aimed at:

complying with the legislation of the Kyrgyz Republic and international AML/CFT standards;
preventing the use of the platform for money laundering, terrorist financing, and other unlawful activities;
fulfilling customer identification requirements (KYC);
monitoring transactions and sources of funds (KYT, SoF, SoW, SoA).

2. GENERAL PRINCIPLES
2.1. Financial Alliance LLC applies a Risk-Based Approach (RBA).
2.2. This Policy applies to all clients and all operations.
2.3. All employees undergo training and are required to follow this Policy.
3. CUSTOMER IDENTIFICATION (KYC)
3.1. The Client must provide:

Full name, date of birth, citizenship;
Passport or other government-issued identification document;
Residential and/or registration address;
Photo/video selfie for identity verification;
Contact details: phone number, email address.

3.2. Additionally, the Company may request:

Proof of address (utility bill, bank statement);
Proof of tax residency status, if required.

3.3. For corporate clients (KYB):

Incorporation documents;
Shareholder/participant registers;
Identification of ultimate beneficial owners (UBOs);
Licenses (where applicable).

4. SOURCE OF FUNDS AND WEALTH (SoF / SoW / SoA)
The Company may request:

Proof of source of funds (contracts, certificates, bank statements);
Explanation of accumulated wealth (sale of assets, inheritance, etc.);
Proof of asset origin (contracts, supporting documents);
Client statements or explanatory letters.

5. TRANSACTION MONITORING (KYT)
5.1. All transactions are subject to automated monitoring and screening based on:

Jurisdictions (sanctioned or offshore countries);
Transaction volumes and frequency;
Currencies and crypto assets used;
Client’s risk profile.

5.2. The Company uses external and/or internal software solutions (proprietary systems or third-party providers) to ensure risk assessment and compliance with standards.
5.3. Suspicious transactions are blocked and reported to the competent authorities, where required by law.
6. REFUSAL OF SERVICE
The Company reserves the right to refuse to open an account or to terminate services in the following cases:

suspicion of illegal activity;
refusal by the client to provide required information;
non-compliance with jurisdictional requirements.

7. DATA STORAGE AND REPORTING

All data is stored for at least 5 years after termination of the relationship.
All documentation is archived in accordance with the legislation of the Kyrgyz Republic.
Regulatory requests are fulfilled within statutory deadlines.

8. SUSPICIOUS SITUATIONS
Examples include:

Client avoids KYC or provides forged documents;
Unjustified transaction amounts;
Use of complex schemes or multiple layered transfers;
Mismatch between client profile and actual transactions.

9. UPDATES AND AUDIT

This Policy is reviewed at least once a year.
Responsible officers are appointed by order of management.
Regular audits are conducted to ensure compliance with internal procedures.

This Policy is mandatory for all employees, contractors, and clients of Financial Alliance LLC.

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