Customer Identificication
CUSTOMER IDENTIFICATION AND VERIFICATION
Firms are required to have and follow reasonable procedures to verify the identity of their customers who open new accounts. These procedures must address the types of information the firm will collect from the customer and how it will verify the customer’s identity. These procedures must enable the firm to form a reasonable belief that it knows the true identity of its customers. In addition to the above, government regulations issued from time also require broker dealer firms to comply with Know Your Customer (KYC) regulations as below.
Before activating an account, and on an ongoing basis, we will check to ensure that a customer does not appear on any government’s Specifically Designated Nationals and Blocked Persons List (SON List), and is not from, or engaging in transactions with people or entities from, embargoed or sanctioned countries and regions.
RESTRICTED POLICY WITH REGARDS TO TRANSACTIONS WITH SANCTIONED COUNTRIES
The United Nations (UN), the European Union (EU) and the United States (US) have imposed restrictive measures ('sanctions') against certain countries with the aim of achieving a change in activities or policy. Other countries in which the firm operates may also have imposed their own restrictive measures.
Currently the UN, the EU and the U.S. have imposed restrictive measures against amongst others the following countries: Cuba, Iran, North Korea, Sudan, Syria, South Sudan.
We, at Altior Invest, will collect customer identification information from each customer who opens an account; utilize risk-based measures to verify the identity of each customer who opens an account; record customer identification information and the verification methods and results; provide notice to customers that we will seek identification information and compare customer identification information with government-provided lists of suspected terrorists, criminals or entities/individuals that are officially notified as prohibited.
REQUIRED CUSTOMER INFORMATION
Prior to activating an account, we will collect the following information for all new accounts: the full name of the account holder; date of birth; residential address, email address; an identification number, which will be a unique government/administrative authority issued identification number or one or more of the following:
A taxpayer or personal identification number, passport number and country of issuance,
Alien identification number or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard.
VERIFYING INFORMATION
Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers. In verifying customer identity, we will analyze any logical inconsistencies in the information we obtain. We will verify customer identity through documentary evidence, non-documentary evidence, or both. We will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, we will supplement the use of documentary evidence by using the non documentary means described below whenever possible. We may also use such non-documentary means, after using documentary evidence, if we are still uncertain about whether we know the true identity of the customer. In analyzing the verification information, we will consider whether there is a logical consistency among the identifying information provided, such as the customer’s name, street address, postal code, telephone number (if provided), date of birth, and identification number/document.
Appropriate documents for verifying the identity of customers include, but are not limited to, the following:
An unexpired government-issued identification evidencing nationality, residence, and bearing a photograph or similar safeguard, such as a driver’s license or passport or European Union National Identity Card.
A bank or credit card statement issued by the customer's bank (a statements issued by the institution: whether on paper, electronically in an email or in the form of an internal printout where it is clear it has been issued by such institution) less then three months old.
We understand that we are not required to take steps to determine whether the document that the customer has provided to us for identity verification has been validly issued and that we may rely on a government-issued identification as verification of a customer’s identity. If, however, we note that the document shows some obvious form of fraud, we must consider that factor in determining whether we can form a reasonable belief that we know the customer’s true identity. We will use the following non-documentary methods of verifying identity:
CONTACTING A CUSTOMER
Independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database, or other source;
Checking references with other institutions;
or
Obtaining a financial statement.
We will use non-documentary methods of verification in the following situations: (1) when the customer is unable to present an unexpired government-issued identification document with a photograph or other similar safeguard; (2) when the firm is unfamiliar with the documents the customer presents for identification verification; (3) when the customer and firm do not have face-to-face contact; and (4) when there are other circumstances that increase the risk that the firm will be unable to verify the true identity of the customer through documentary means.
We will verify the information within a reasonable time before or after the account is opened. Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information, or in some instances when we need more time, we shall, pending verification, restrict the types of transactions and deposits. If we find suspicious information that indicates possible money laundering or terrorist financing activity, we will, after internal consultation with the firm’s AML compliance officer, file a SAR in accordance with applicable law and regulation.
We recognize that the risk that we may not know the customer’s true identity may be heightened for certain types of accounts. We will identify customers that pose a heightened risk of not being properly identified. In such instances, we will take additional measures that may be used to obtain information about the identity of the individuals associated with the customer when standard documentary methods prove to be insufficient, such as obtaining information about individuals with authority or control over such account.
NOTICE TO CUSTOMERS
We will provide notice to customers that the firm is requesting information from them to verify their identities, as required by law in the case of there being a requirement for a customer to provide additional identifying information, over and above the information in our possession. Any such notices shall be provided officially, after an initial notification via standard means of communication including but not limited to: E-mail, Recorded Telephonic Calls, Regular Post or any other suitable method of communication that clearly and demonstrably establishes our recorded request for additional customer identity information.
CUSTOMERS WHO REFUSE TO PROVIDE INFORMATION
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our firm will not activate a new account and, after considering the risks involved, consider closing any existing account. In either case, our AML Compliance Officer will be notified so that we can determine whether we should report the situation to regulators and/or government agencies.
LACK OF VERIFICATION
When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (A) not activate an account; (B) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity; (C) close an account after attempts to verify customer’s identity fail; and (D) file a SAR in accordance with applicable law and regulation.
RECORDKEEPING
We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancy in the identifying information. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. We will maintain a record of all identification information for one year after the account has been closed. We will retain records made about verification of the customer’s identity for one year after the record is made.
I agree. Take me back to the previous page.