KYC / AML Policy
3.45 revised September 09 2024
1. Purpose
This Know Your Customer (KYC) Policy outlines the procedures and principles adopted by Telecom Apps LLC to ensure compliance with international regulations and best practices for verifying the identity of clients and mitigating risks related to money laundering, fraud, and other illicit activities. This policy is tailored to our operations in the software development industry and reflects our commitment to ethical business practices.
2. Scope
This policy applies to all clients and users of Telecom Apps LLC’s online platform accessible on the website https://thestape.com. It encompasses procedures for client identification, verification, and ongoing monitoring to ensure compliance with applicable laws and regulations.
3. Regulatory Compliance
This policy is informed by international standards, including FATF (Financial Action Task Force) guidelines, the EU’s AMLD (Anti-Money Laundering Directives), and other relevant regulations.
4. Client Identification and Verification
4.1. Collection of Information
The following information is collected from each client:
4.2. Verification Process
Client verification is conducted using SumSub https://sumsub.com/, a third-party verification provider. SumSub ensures the authenticity of documents and matches client information against reliable data sources.
4.3. Exclusions
Telecom Apps LLC does not engage clients or partners listed in any international sanctions databases or those identified as high-risk by SumSub’s https://sumsub.com/ risk assessment tools or by internal checks of clients corporate documents, performed by AMLCO (AML Compliance Officer)
The following information is collected from each client:
- Full name
- Date of birth
- Nationality
- Residential address
- Government-issued identification document (e.g., passport, national ID, driver’s license)
- Company documents (extract from the registry, certificates of incorporation, proof of business address, shareholders agreement, authorized representative information)
4.2. Verification Process
Client verification is conducted using SumSub https://sumsub.com/, a third-party verification provider. SumSub ensures the authenticity of documents and matches client information against reliable data sources.
4.3. Exclusions
Telecom Apps LLC does not engage clients or partners listed in any international sanctions databases or those identified as high-risk by SumSub’s https://sumsub.com/ risk assessment tools or by internal checks of clients corporate documents, performed by AMLCO (AML Compliance Officer)
5. Risk-Based Approach
Telecom Apps LLC employs a risk-based approach to KYC, which involves:
Assigning risk ratings to clients based on geographic location, activity patterns, and other risk factors.
Applying enhanced due diligence (EDD) for clients flagged as medium or high risk.
Assigning risk ratings to clients based on geographic location, activity patterns, and other risk factors.
Applying enhanced due diligence (EDD) for clients flagged as medium or high risk.
6. Ongoing Monitoring
6.1. Transaction Monitoring
Telecom Apps LLC actively monitors transactions on the platform to identify and report suspicious activity.
6.2. Periodic Reviews
Client information is reviewed annually and updated to ensure continued compliance with KYC requirements. AMLCO (AML Compliance Officer) is responsible for KYC requirements review.
Telecom Apps LLC actively monitors transactions on the platform to identify and report suspicious activity.
6.2. Periodic Reviews
Client information is reviewed annually and updated to ensure continued compliance with KYC requirements. AMLCO (AML Compliance Officer) is responsible for KYC requirements review.
7. Data Privacy and Security
All client data collected during the KYC process is handled in compliance with applicable data protection laws, including GDPR. Telecom Apps LLC. ensures the secure storage and transmission of client data through encrypted systems.
8. Reporting Obligations
All client data collected during the KYC process is handled in compliance with applicable data protection laws, including GDPR. Telecom Apps LLC. ensures the secure storage and transmission of client data through encrypted systems.
9. Employee Training
All employees involved in KYC and AML processes undergo regular training to stay updated on compliance requirements and best practices.
Telecom Apps LLC is an active member of https://www.int-comp.org/ and on a quarter basis runs training courses for its employees that are engaged with clients including ICA certification of such employees.
This is mandatory, that all client relations managers and sales managers will complete KYC / AML training before starting their jobs duties.
AMLCO (AML Compliance Officer) is responsible for annual checks of the employer's knowledge on AML / KYC policies and provides reports to the shareholders.
Telecom Apps LLC is an active member of https://www.int-comp.org/ and on a quarter basis runs training courses for its employees that are engaged with clients including ICA certification of such employees.
This is mandatory, that all client relations managers and sales managers will complete KYC / AML training before starting their jobs duties.
AMLCO (AML Compliance Officer) is responsible for annual checks of the employer's knowledge on AML / KYC policies and provides reports to the shareholders.
10. Policy Review and Updates
This policy is reviewed annually or when significant regulatory changes occur. Updates are communicated to all relevant stakeholders.
11. Contact Information
For questions related to this policy, please contact AML Compliance Officer:
Helen Bajik
ebazhina@thestape.com
United States, CA. Redwood City, 303 Twin Dolphin Drive
Suite 800
Helen Bajik
ebazhina@thestape.com
United States, CA. Redwood City, 303 Twin Dolphin Drive
Suite 800