Know Your Customer & Know Your Business Policy

1. Introduction

To comply with applicable laws, industry standards, and risk-management obligations, our company implements a formal Know Your Customer (KYC) & Know Your Business (KYB) program. This program is designed to verify the identity of all customers, prevent fraudulent activity, and ensure the lawful use of our services.

Identity verification is conducted through our authorized third-party provider, SumSub, which specializes in secure and compliant digital identity verification. KYC/KYB verification is also required by BVNK, ICG's payment processing partner, as a mandatory condition of using their platform for transactions. KYC/KYB verification is required for all new clients, existing clients using BVNK, returning clients, and clients taking over or changing ownership of an existing account.

2. Purpose of KYC and KYB

The objectives of our KYC/KYB program include:

✺ Confirming the identity of all customers
✺ Preventing fraud, identity theft, and unauthorized account use
✺ Complying with regulatory and contractual obligations
✺ Ensuring the integrity and security of our platform
✺ Supporting ongoing monitoring and risk assessment

Completion of KYC/KYB is mandatory for all customers seeking to access or continue using our services.

3. Verification Requirements

Customers are required to provide accurate and complete identity information, including:

✺ Full legal name
✺ A valid, government-issued photo identification document
✺ Any additional information reasonably requested to verify identity

Verification is performed exclusively through SumSub, which conducts document authentication, biometric checks, and fraud-prevention screening. We do not accept aliases, nicknames, or non-legal names for verification purposes.

3a. KYB Documentation Requirements

For Know Your Business verification (KYB), you may be required to provide the following:

✺ Business registration or incorporation documents
✺ Legal business name and registration number
✺ Registered business address
✺ Authorized representative information
✺ Beneficial ownership (UBO) information
✺ Ownership or company structure information
✺ Any additional supporting corporate documentation reasonably required to complete verification

Additional documentation may be requested where necessary to verify ownership, business legitimacy, or regulatory compliance.

Beneficial owners and authorized representatives may also be required to complete individual identity verification as part of the KYB process.

Businesses may also be screened against applicable sanctions, compliance watchlists, or other regulatory databases where required.

4. Verification Process

Upon receiving a secure KYC/KYB link, customers must complete the verification steps through SumSub's platform. SumSub will review the submitted information and determine whether the identity is:

✺ Approved
✺ Rejected
✺ Requires additional documentation

Customers will be notified if further information is needed. Accounts cannot proceed through onboarding or remain active without successful verification.

If verification is not completed, you may receive automated reminder emails or follow-up outreach from our team to help you finish the process.

5. Re‑Verification Requirements

To maintain compliance and ensure ongoing accuracy of customer information, we may require customers to complete periodic KYC/KYB re-verification. Re-verification typically occurs every six months, or sooner if:

✺ Regulatory requirements change
✺ Risk indicators are identified
✺ Account information is updated
✺ SumSub flags the account for review

Customers will receive a notification when re-verification is required.

6. Refusal or Failure to Complete

If a customer declines to complete KYC/KYB or fails to provide required information:

✺ Account activation cannot proceed and onboarding will be stopped until verification is complete. This includes signing of the Software Agreement, which cannot occur until KYC/KYB has been approved.
✺ Access to services may be denied
✺ Transactions may be delayed or cancelled
✺ The matter may be escalated to our Compliance team for review

KYC/KYB completion is a condition of service, and refusal may result in termination of the customer relationship.

If your verification does not go through automatically, our team will review your submission and reach out if any additional information is needed.

7. Prohibited Activities

The following are not permitted under any circumstances:

✺ Bypassing or skipping the KYC/KYB verification process
✺ Requesting exceptions through your sales representative
✺ Processing payments before verification is approved
✺ Activating your account before verification is complete
✺ Verbal agreements or promises from ICG staff do not constitute an exemption from verification requirements
✺ Providing false or misleading business information
✺ Submitting fraudulent or altered documentation

8. Data Protection & Privacy

All identity information is processed through SumSub's secure, encrypted infrastructure. We do not store identity documents outside of SumSub unless required by law or regulatory obligations. Customer data is handled in accordance with:

✺ Applicable privacy laws
✺ Our internal data-protection standards
✺ SumSub's certified security protocols

We do not sell, trade, or misuse customer identity information.

9. Accuracy of Information

Customers are responsible for ensuring that all information provided during the KYC/KYB process is accurate, complete, and up to date. Providing false, misleading, or fraudulent information is strictly prohibited and may result in:

✺ Immediate account suspension
✺ Termination of services
✺ Reporting to relevant authorities, where required

10. Regulatory Compliance

Our KYC/KYB program aligns with industry best practices and applicable regulatory frameworks governing identity verification, fraud prevention, and customer due diligence. We reserve the right to update this policy as regulations evolve.

11. Contact Information

Questions regarding KYC/KYB requirements, re-verification, or data handling should be directed to our support team. Please note that sales representatives are not authorized to grant exceptions, overrides, or waivers of verification requirements.