Neshes Global Know Your Customer (KYC) Policy

1. Introduction

Neshes Global, as a multinational organization, is committed to maintaining the highest standards of compliance to prevent money laundering, terrorist financing, and other illicit activities. This Know Your Customer (KYC) Policy establishes a robust framework for identifying and verifying customers, assessing their risk profiles, and ensuring compliance with global regulatory requirements, including those of the Office of Foreign Assets Control (OFAC), the UK Financial Conduct Authority (FCA), and European Union (EU) sanctions regimes. This policy applies to all Neshes Global entities, subsidiaries, employees, contractors, and third-party partners worldwide.
 

2. Purpose

The objectives of this KYC Policy are to:

• Verify the identity of customers and their beneficial owners to prevent illicit activities.

• Assess and manage customer-related risks in alignment with AML/CTF and sanctions regulations.

• Ensure compliance with OFAC, FCA, EU, and other applicable local and international laws.

• Protect Neshes Global’s reputation, operations, and stakeholders from financial crime risks.
   

3. Scope

This policy applies globally to:

• All Neshes Global business units, subsidiaries, and affiliates.

• All customers, including individuals, corporate entities, trusts, and other legal structures.

• All products, services, and transactions, including cross-border activities.

• All employees, contractors, and third-party partners involved in customer onboarding and relationship management.
   

4. Legal and Regulatory Framework

Neshes Global’s KYC processes comply with the following regulatory frameworks:

• OFAC Regulations: Screening against the Specially Designated Nationals (SDN) List, Sectoral Sanctions Identifications (SSI) List, and other restricted parties lists.

• FCA Regulations: UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) and FCA Handbook requirements.

• EU Regulations: EU Anti-Money Laundering Directives (e.g., 5AMLD, 6AMLD) and EU sanctions lists.

• International Standards: Financial Action Task Force (FATF) recommendations, including customer due diligence (CDD) requirements.

• Local Laws: Jurisdiction-specific KYC and AML/CTF regulations in all countries where Neshes Global operates.
   

5. Governance and Oversight
 

5.1 Board of Directors

The Neshes Global Board of Directors is responsible for:

• Approving the KYC Policy and ensuring alignment with global regulatory standards.

• Overseeing the establishment of an effective KYC compliance framework.

• Reviewing periodic reports on KYC compliance and customer risk profiles.
   

5.2 Global AML/CTF Committee

The Global AML/CTF Committee, chaired by the Money Laundering Reporting Officer (MLRO), oversees:

• Development and implementation of KYC policies and procedures.

• Coordination with regional compliance teams to ensure consistent KYC standards.

• Monitoring KYC performance and addressing emerging risks.
   

5.3 Money Laundering Reporting Officer (MLRO)

The MLRO is responsible for:

• Overseeing the execution of KYC processes across Neshes Global.

• Ensuring compliance with regulatory KYC requirements.

• Escalating and investigating KYC-related issues, including sanctions matches or suspicious activities.
   

6. Customer Due Diligence (CDD)

Neshes Global implements a risk-based CDD process to verify customer identities and assess their risk profiles. CDD measures are applied at onboarding, during periodic reviews, and upon trigger events (e.g., changes in customer behavior or sanctions status).
 

6.1 Standard CDD

Standard CDD is applied to all customers and includes:

• Identification and Verification:

  • For individuals: Collecting and verifying full name, date of birth, address, and government-issued identification (e.g., passport, national ID, driver’s license).

  • For corporate entities: Collecting and verifying legal name, registration number, registered address, and incorporation documents.

• Beneficial Ownership: Identifying and verifying ultimate beneficial owners (UBOs) with a controlling interest (e.g., 25% or more ownership, as per FATF standards).

• Purpose and Nature: Documenting the purpose and intended nature of the business relationship or transaction.

• Source of Funds/Wealth: Obtaining information on the source of funds or wealth for significant transactions.
   

6.2 Enhanced Due Diligence (EDD)

EDD is applied to high-risk customers, including:

• Politically Exposed Persons (PEPs), their family members, or close associates.

• Customers from high-risk jurisdictions (e.g., FATF grey/black lists, OFAC/EU-sanctioned countries).

• Customers involved in high-value or complex transactions.

• Customers with adverse media or reputational risks. EDD measures include:

• Additional verification of identity, source of funds, and source of wealth.

• Obtaining senior management approval for establishing or continuing relationships.

• Enhanced monitoring of transactions and periodic reviews (e.g., every 6 months for high-risk customers).

• Reviewing public records, adverse media, or third-party databases for additional risk indicators.
   

6.3 Simplified Due Diligence (SDD)

SDD may be applied to low-risk customers, such as:

• Regulated financial institutions subject to equivalent AML/CTF standards.

• Government entities or public bodies.

• Listed companies subject to robust disclosure requirements. SDD is only applied where risk assessments justify reduced measures and is subject to regulatory approval.
   

6.4 Ongoing Monitoring

Neshes Global conducts ongoing monitoring to:

• Ensure customer information remains accurate and up-to-date.

• Detect changes in customer behavior or risk profiles (e.g., sudden increases in transaction volume).

• Identify transactions inconsistent with the customer’s known profile or business purpose.

• Periodic reviews are conducted based on risk levels (e.g., annually for low-risk customers, semi-annually for high-risk customers).
   

7. Sanctions Screening

Neshes Global screens all customers and their beneficial owners against sanctions lists to ensure compliance with OFAC, FCA, and EU requirements:

• Screening Scope:

  • OFAC SDN List, SSI List, and other restricted parties lists.

  • EU Consolidated List of Sanctions.

  • UK Sanctions List (HM Treasury).

  • Other relevant national and international sanctions lists.

• Screening Frequency:

  • At onboarding, before establishing a business relationship.

  • During periodic reviews (e.g., annually or upon sanctions list updates).

  • In real-time for transactions, where applicable.

• Escalation: Any sanctions matches are escalated to the MLRO for investigation. Neshes Global prohibits relationships or transactions with sanctioned individuals, entities, or jurisdictions.
   

8. Risk-Based Approach

Neshes Global adopts a risk-based approach to KYC, tailored to its global operations:

• Risk Assessment: Conducting enterprise-wide and jurisdiction-specific risk assessments to evaluate customer-related risks based on:

  • Customer type (e.g., individuals, corporates, PEPs).

  • Geographic location (e.g., high-risk jurisdictions).

  • Products, services, or delivery channels (e.g., online vs. in-person).

  • Transaction complexity or value.

• Risk Categorization: Classifying customers as low, medium, or high risk and applying appropriate CDD measures.

• Risk Mitigation: Implementing controls such as enhanced screening, transaction monitoring, or senior management oversight for high-risk customers.

• Periodic Review: Updating risk assessments at least annually or upon significant changes (e.g., new regulatory requirements, business expansion).
   

9. Transaction Monitoring and KYC Integration

KYC processes are integrated with Neshes Global’s transaction monitoring systems to:

• Verify that transactions align with the customer’s risk profile and business purpose.

• Flag unusual or suspicious activities, such as:

  • Transactions with no apparent economic or lawful purpose.

  • Rapid or frequent fund movements without clear justification.

  • Transactions involving high-risk jurisdictions or sanctioned entities.

• Escalate flagged transactions to the AML Compliance Team and MLRO for investigation.
   

10. Suspicious Activity Reporting

If KYC processes identify suspicious activities, Neshes Global follows its AML/CTF Policy for reporting:

• Suspicious Activity Reports (SARs) are filed with the relevant authorities (e.g., UK NCA, U.S. FinCEN, EU FIUs) in accordance with local regulations.

• Employees are required to report suspicions to the MLRO immediately via secure internal channels.
   

11. Record Keeping

Neshes Global maintains comprehensive KYC records in compliance with regulatory requirements:

• Retention Period: Records are retained for a minimum of five years (or longer if required by local laws), including:

  • Customer identification and verification documents.

  • Beneficial ownership information.

  • Sanctions screening results.

  • Correspondence related to CDD/EDD processes.

• Data Security: Records are stored securely, with access restricted to authorized personnel, in compliance with data protection laws (e.g., GDPR in the EU).
   

12. Training and Awareness

Neshes Global provides mandatory KYC training to all employees and relevant third parties:

• Content: Training covers:

  • KYC procedures and regulatory requirements (OFAC, FCA, EU, etc.).

  • Identifying and verifying customers and beneficial owners.

  • Recognizing high-risk customers and red flags.

  • Sanctions screening and reporting obligations.

• Frequency: Training is conducted at onboarding, annually, and upon significant policy or regulatory updates.

• Tailored Training: Specialized training for roles involved in customer onboarding, compliance, or client relationship management.

• Awareness Campaigns: Regular communications to reinforce KYC responsibilities and vigilance.
   

13. Third-Party and Vendor Management

Neshes Global ensures that third-party partners and vendors involved in customer-facing activities comply with KYC requirements:

• Due Diligence: Conducting risk-based due diligence on third parties before onboarding.

• Contractual Obligations: Including KYC compliance clauses in contracts.

• Monitoring: Ongoing oversight to ensure third parties adhere to Neshes Global’s KYC standards.
   

14. Internal Audit and Independent Review

Neshes Global conducts regular audits to ensure KYC compliance:

• Internal Audit: The Internal Audit Team assesses KYC processes, reporting findings to the Global AML/CTF Committee and Board.

• Independent Review: An external auditor conducts periodic reviews (at least biennially) to verify compliance with regulatory and internal standards.

• Remediation: Identified deficiencies are addressed promptly, with action plans tracked to completion.
   

15. Cross-Border Compliance

As a multinational organization, Neshes Global ensures consistent KYC compliance across jurisdictions:

• Global Standards: Applying the highest KYC standards across all operations, even where local requirements are less stringent.

• Local Adaptation: Tailoring KYC procedures to comply with jurisdiction-specific laws while maintaining global consistency.

• Information Sharing: Facilitating secure data sharing between global and regional teams, in compliance with data protection regulations.
   

16. Monitoring and Policy Review

This KYC Policy is reviewed at least annually or upon significant changes, including:

• Updates to OFAC, FCA, EU, or local regulations.

• Changes in Neshes Global’s business operations, customer base, or risk profile.

• Emerging financial crime or sanctions risks. The MLRO, in collaboration with the Global AML/CTF Committee, oversees the review process, with final approval by the Board of Directors.
   

17. Consequences of Non-Compliance

Non-compliance with this KYC Policy may result in:

• Disciplinary action, including warnings, suspension, or termination.

• Legal or regulatory penalties for Neshes Global and/or individuals.

• Reputational damage and loss of stakeholder trust.
   

18. Whistleblowing and Reporting

Neshes Global encourages reporting of suspected KYC violations through:

• Internal Channels: Confidential reporting to the MLRO or Compliance Team via secure platforms.

• Whistleblowing Hotline: An anonymous hotline for reporting concerns, accessible globally.

• Non-Retaliation: Neshes Global prohibits retaliation against individuals reporting in good faith.
   

19. Contact Information 
For questions, concerns, or to report suspicious activities, contact:Global Money Laundering Reporting Officer
Email: info@nehsesglobal.com
Address: 1 Canada Square, London E14 5AA, United Kingdom
Phone: +44 (0) 20 1234 5678.20.
 

20. Approval and Effective Date

This KYC Policy has been approved by the Neshes Global Board of Directors and is effective as of May 29, 2025.

Neshes Global KYC Policy Version 1.0
Last Updated: May 29, 2025
Approved by: Neshes Global Board of Directors