ICR KYC/KYB Policy

Summary

ICR is committed to maintaining the integrity of its registry by verifying the identity and legitimacy of participants through robust KYB/KYC procedures. We conduct independent sanctions and risk screening, promote transparency in ownership structures, and apply proportionate oversight to prevent misuse of the registry. These measures support accountability, market integrity, and alignment with international best practices.

Version	2.0
Date of version	6. March 2026

682KB

ICR KYC_KYB Policy v2.0.pdf

PDF

Open

Purpose

The purpose of this policy is to outline ICR’s commitment to:

• Verifying the identity and legitimacy of organizations and individuals using the ICR registry;

• Preventing misuse of the registry for fraud, sanctions evasion, misrepresentation, or market abuse;

• Protecting the integrity and credibility of ICCs;

• Supporting transparent governance aligned with international best practice.

For compliance implementation, ICR may rely on an independent third-party compliance partner, to conduct screening and integrity checks for automation and efficiency.

Scope

This policy applies to:

• Project proponents and developers;

• Instrument brokers and traders;

• Validation and verification bodies;

• Authorized representatives;

• ICR employees, contractors, board members, and interns involved in onboarding or monitoring;

• Third parties conducting screening or integrity checks on behalf of ICR.

It applies to all registry related activities including:

• Account opening;

• Project registration;

• Issuance of ICCs;

• Transfers within the registry;

• Retirement and cancellation of ICCs.

Principles

ICR applies a risk-based and proportionate identity verification framework based on the following principles:

Legitimacy Verification - ICR verifies that account holders are legally established entities operating for legitimate purposes.

Transparency - ICR requires disclosure of ownership and control structures sufficient to identify ultimate beneficial owners (UBOs).

Sanctions Compliance - ICR ensures that no sanctioned individual or entity may open or maintain an account.

Proportionality - The depth of review is proportionate to the nature of the entity, jurisdiction, and registry activity.

KYB Requirements for Verified Organizations

The following information is required:

• Full legal entity name;

• Registered address;

• Company registration number;

• Country of incorporation;

• Industry sector;

• Directors;

• UBOs (≥25% ownership or control);

• Authorized representatives.

ICR will:

• Verify legal existence;

• Screen the entity, directors, and UBOs;

• Assess FATF jurisdictional risk;

• Conduct adverse media checks.

Accounts will not be opened if:

• Sanctions list matches are confirmed;

• The entity is incorporated in a FATF blacklisted jurisdiction;

• Ownership transparency is insufficient.

KYC Requirements for Verified Individuals (Users)

For individual users and authorized representatives:

• Full legal name;

• Government issued identification;

• Proof of authority (if acting for an organization).

Individuals are screened against sanctions and relevant watchlists.

Sanctions & Risk Screening

ICR conducts sanctions and risk screening.

Politically Exposed Persons (PEP)

Politically Exposed Persons (PEPs) are individuals who may present higher integrity risk due to their political exposure.

If an account holder, UBO, director, or authorized representative is identified as a PEP, ICR may:

• Request additional information;

• Conduct further review;

• Apply enhanced monitoring where appropriate.

PEP status does not automatically prevent account approval but may result in additional checks.

Sanctions Screening

Account holders, UBOs, directors, and authorized representatives are screened against:

• UN sanctions lists;

• EU sanctions lists;

• UK sanctions lists;

• OFAC (US) sanctions lists.

Screening is performed:

• At onboarding;

• Periodically thereafter;

• When ownership or control changes.

If a confirmed sanctions match is identified account opening will be denied, or the account may be suspended pending review.

ICR does not permit sanctioned individuals or entities to participate in the registry.

Risk-Based Assessment

Risk factors may include:

• Jurisdiction of incorporation;

• Complex ownership structures;

• High-risk regions;

• Project location risk;

• Material ownership changes.

Where higher risk is identified, enhanced documentation may be requested.

Ongoing Monitoring

ICR conducts periodic re-screening of:

• Sanctions lists;

• PEP databases.

Updated documentation may be requested where material changes occur.

Data Protection & Confidentiality

KYB/KYC data:

• Is processed in accordance with GDPR;

• Is retained for a minimum of five (5) years after the most recent registry activity;

• Is stored securely with restricted access.

Data shared with third parties are governed by a data processing agreements ensuring confidentiality and data protection compliance.

Non-Compliance & Enforcement

If false, misleading, or incomplete information is provided:

ICR may:

• Suspend the account;

• Freeze registry activity;

• Deny issuance requests;

• Initiate account closure.

Specific investigative triggers will not be disclosed to avoid compromising screening processes.

Policy Review

This policy is reviewed annually or when:

• Sanctions frameworks change;

• FATF lists are updated;

• Screening processes require enhancement.

Appendix – Document History

Version	Date	Comment
1.0	21.11.2024	First version.
2.0	6.3.2026	Revisions and clarifications