Required “KYC” due diligence for all customers
The SPOTKEYS shall take reasonable measures to ascertain and verify the true identity of all customers who transact with the Company. Each business process shall design and implement specific due diligence standards and procedures that are appropriate given the nature of the respective businesses, customers and the associated risks. Such standards and procedures shall include, at a minimum, the following elements.
For the purpose of identifying and verifying the identity of customers at the time of commencement of an account-based transaction, SPOTKEYS may rely on a third party; subject to the conditions that. The company immediately obtains necessary information of such client due diligence carried out by the third party;
ii. The SPOTKEYS takes adequate steps to satisfy itself that copies of identification data and other relevant documentation relating to the client due diligence requirements will be made available from the third party upon request without delay;
iii. The SPOTKEYS is satisfied that such third party is regulated, supervised or monitored for, and has measures in place for compliance with client due diligence and record-keeping requirements in line with the requirements and obligations under the Act;
iv. The third party is not based in a country or jurisdiction assessed as high risk; and
v. The company is ultimately responsible for client due diligence and undertaking enhanced due diligence measures, as applicable.
Customer Identification Procedure
All the customers shall be identified by a unique identification code to identify customers, track the facilities availed, monitor financial transactions in a holistic manner and to have a better approach to risk profiling of customers.
Each business process shall implement procedures to obtain from each customer, prior to transacting, the following information as may be relevant, to that business:
1. Name – procedures require business processes to use reasonable efforts to ensure that the name recorded on the Company systems as the customer will be exactly the same as (and not merely similar to, or a variation of) the name that appears on any identifying documentation reviewed in connection with the loan;
2. For individuals – age / date of birth; For a person other than individual (such as corporation, partnership or trust) – date of incorporation;
3. Address including the documentary proof thereof;
i. For an individual, a residential or business street address;
ii. For a Person other than an individual (such as a corporation, partnership, or trust), the principal place of business, local office, or other physical location;
4. Telephone/Fax number/E-mail ID;
5. Identification number:
i. A taxpayer identification number; passport number and country of issuance; letter issued by Unique Identification Authority of the customer’s country or residence and bearing a photograph or similar safeguard. When opening an account for a person (other than an individual) that does not have an identification number, the business process must request alternative government-issued documentation certifying the existence of the business or enterprise.
The list of documents that can be accepted as proof of identity and address from customers across various products offered by the SPOTKEYS is stated above. These are appropriately covered in the credit policies of the respective businesses and communicated to the credit approving authorities.