KYC/KYB Compliance Policy v1.0

Introduction

This policy delineates ICR's commitment to adhere to international and national regulations regarding KYB/KYC. It applies to all ICR operations and personnel.

Compliance Obligations

ICR will comply with all relevant KYB/KYC laws and regulations imposed by various international and national bodies.

Risk Assessment and Management

Regular risk assessments to identify and mitigate potential risks related to customer and business relationships in ICR operations.

Due Diligence and Customer Identification

• Implementing comprehensive customer due diligence KYC/KYB procedures, including the identification and verification of customers and beneficial owners.

• Assessing customer risk profiles.

• Applying enhanced due diligence for high-risk customers.

Monitoring and Reporting

Ongoing monitoring of customer relationships and activities to maintain compliance with KYB/KYC standards.

Sanctions Compliance

• Ensuring no engagement with individuals or entities from sanctioned countries or those on sanction lists.

• Regular screening against updated sanction lists to ensure compliance.

Employee Training and Capacity Building

• Regular training for employees on KYB/KYC compliance, focusing on recognizing and addressing risks in customer relationships.

Internal Controls and Audits

• Implementing internal controls to ensure adherence to KYB/KYC policies.

• Regular internal audits to assess the effectiveness of KYB/KYC measures.

Reporting and Escalation Procedures

• Reporting on non-compliance or issues within KYB/KYC procedure.

• Appointing a Compliance Officer responsible for overseeing KYB/KYC compliance.

Policy Review and Updates

Regularly review and update the policy to align with evolving legal and regulatory requirements relating to KYB/KYC.

Legal and Regulatory Cooperation

Commitment to cooperating with legal and regulatory bodies in matters related to KYB/KYC.

Whistleblower Protection

Ensuring protection for employees who report violations or concerns related to KYB/KYC practices in good faith.