Seaz & Co Realty Group is committed to complying with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. As part of this commitment, we have established a Know Your Customer (KYC) policy to identify, verify, and monitor all investors who engage with our real estate investment offerings. This policy is designed to mitigate risks related to money laundering, fraud, and terrorist financing while ensuring transparency and trust in our investor relationships.
1. Purpose of the KYC Policy
The purpose of this KYC policy is to:
- Ensure the verification of all investors engaging in transactions with Seaz & Co Realty Group.
- Establish procedures for identifying the risk profile of both individual and business investors.
- Maintain compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations.
- Monitor transactions and maintain appropriate records to ensure ongoing due diligence.
2. Scope of the KYC Policy
This policy applies to:
- All retail (individual) investors.
- All business investors (companies, partnerships, trusts, and other entities).
- All transactions carried out by investors, including initial investments, ongoing transactions, and withdrawals.
3. KYC Procedures
Seaz & Co Realty Group has established the following KYC procedures to verify the identity of all investors:
3.1 For Retail Investors (Individuals):
All individual investors must provide the following information and documents:
- Full Legal Name: As listed on a government-issued ID.
- Date of Birth: To ensure the investor meets the legal age requirements for contracts.
- Nationality and Residency Status: To determine compliance with international investment laws.
- Government-Issued ID: A valid passport, driver’s license, or national ID card.
- Proof of Address: Recent utility bills, bank statements, or government-issued documents confirming the investor’s address.
- Employment Information: Documentation such as a recent pay stub or employment contract.
- Bank Account Verification: Bank details, such as a recent bank statement, to confirm the source of funds for transactions.
3.2 For Business Investors (Entities):
All business investors must provide the following information and documents:
- Company Name and Registration Number: Proof of the company’s legal existence, such as Articles of Incorporation or Partnership Agreements.
- Proof of Address: Recent documents showing the registered business address.
- Business License: A valid business license or equivalent proof of authorization to operate.
- Ultimate Beneficial Owners (UBOs): Identification of individuals holding more than 25% ownership in the business.
- Director Identification: Verification of identity for company directors and authorized signatories.
- Financial Statements: Recent audited financials to verify the business’s financial standing.
- Tax Identification Number: To verify the entity’s tax compliance.
4. Risk-Based Approach
Seaz & Co Realty Group adopts a risk-based approach to KYC, applying enhanced due diligence to high-risk investors, while ensuring basic verification for low-risk investors. Investors are categorized based on their risk profile:
4.1 Low-Risk Investors:
- Domestic retail investors with simple financial profiles will undergo basic identity verification and proof of address checks.
4.2 High-Risk Investors:
- Foreign investors, businesses from high-risk jurisdictions, or politically exposed persons (PEPs) will undergo enhanced due diligence (EDD). This includes more in-depth background checks, monitoring of transactions, and source of wealth verification.
5. Source of Funds and Wealth Verification
Seaz & Co Realty Group requires all investors to demonstrate the legitimate source of their investment funds. This is essential to prevent money laundering and ensure compliance with AML regulations.
5.1 For Individuals:
- Source of Funds: Pay stubs, bank statements, tax returns, or investment portfolios to verify how the investment capital was accumulated.
5.2 For Businesses:
- Source of Funds: Audited financial statements, bank statements, and contracts to verify the business’s revenue streams.
6. Sanctions and Politically Exposed Persons (PEP) Screening
Seaz & Co Realty Group will screen all investors against:
- Sanction Lists: To ensure the investor is not on any international sanctions lists (e.g., OFAC, EU, UN).
- Politically Exposed Person (PEP) Lists: To identify individuals who may pose a higher risk of money laundering or corruption due to their political exposure.
Investors who are flagged through these screenings may be subject to enhanced due diligence.
7. Ongoing Monitoring and Enhanced Due Diligence
To maintain compliance with regulatory standards, Seaz & Co Realty Group conducts ongoing monitoring of investor transactions. This ensures that investor activity remains consistent with their risk profile and that any suspicious transactions are promptly investigated.
- Regular Transaction Monitoring: Any transaction that deviates from the established pattern will be flagged for review.
- Periodic Reviews: Investors classified as high-risk will be reviewed at least annually, with enhanced due diligence applied as necessary.
- Enhanced Due Diligence (EDD): Additional documentation may be requested from investors whose activities raise concerns or trigger alerts.
8. Record Keeping
Seaz & Co Realty Group will maintain complete and accurate records of all KYC documentation and verification processes for a minimum of five years after the end of the investor relationship, in accordance with regulatory requirements.
- Document Storage: All records will be securely stored in both physical and digital formats, with strict access controls.
- Audit Trail: A detailed audit trail of KYC actions and decisions will be maintained for regulatory review and internal compliance checks.
9. Use of Technology for KYC Automation
Seaz & Co Realty Group will leverage automated KYC platforms to streamline the verification process, including:
- Real-Time ID Verification: Automated systems to verify government-issued IDs.
- Sanction and PEP Screening: Automated tools to conduct regular checks against sanction lists and PEP databases.
- Secure Document Management: Technology solutions for storing and managing KYC documents with secure audit trails.
10. Regulatory Compliance and Reporting
Seaz & Co Realty Group is committed to full compliance with all local and international AML laws and regulations. This includes the submission of Suspicious Activity Reports (SARs) for any unusual or suspicious activity, as well as regular reporting of large transactions where required by law.
- Suspicious Activity Reporting (SARs): Any suspicious transactions or behavior will be reported to the relevant authorities in accordance with local regulations.
- Large Transaction Reporting: Transactions above the regulatory threshold will be reported as required.
11. Compliance Training
All relevant employees at Seaz & Co Realty Group will receive regular training on KYC procedures, AML compliance, and how to identify and report suspicious activity. This ensures that the team is equipped to enforce the KYC policy effectively and consistently.
Conclusion
Seaz & Co Realty Group’s KYC policy is designed to ensure compliance with all applicable AML and CTF regulations while fostering a transparent and secure environment for our investors. By implementing comprehensive KYC procedures and ongoing monitoring, we protect our business, investors, and stakeholders from financial crime and fraud.
This policy will be reviewed periodically to reflect changes in regulatory requirements and best practices.