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Customer Onboarding and KYB Policy

Customer Onboarding and KYB Policy

Owned by Ushank Khanna
Last updated: Dec 18, 2024
3 min read

1. Purpose

Cloud Maven, Inc. is committed to compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. This Know Your Customer (KYC) and Know Your Business (KYB) policy establishes the procedures for verifying the identity of individual and corporate customers to prevent fraud, money laundering, and other illicit activities.

2. Scope

This policy applies to:

  • All customers, including individuals (KYC) and businesses (KYB)

  • Employees, agents, and contractors involved in customer onboarding and transaction monitoring

  • All products and services provided by Cloud Maven, Inc. Access to some products will require additional compliance checks and documentation.

3. Objectives

  • To verify the identity of businesses and their beneficial owners.

  • To identify and mitigate the risks of financial crimes. (We don’t facilitate financial transactions; hence, the risk is somewhat low.)

  • To comply with applicable legal and regulatory requirements

  • To promote transparency and trust

4. Know Your Business (KYB)

Before engaging with the prospect, please ensure the sales team performs the following activities before onboarding the clients. The sales team must collect the following information from the customer or prospect and update Salesforce CRM.

  1. Legal Name

  2. Incorporation Date and State

  3. Business Address

  4. Website

4.1 Business Verification

The system will automatically run the Secretary of State (SOS) and OFAC checks in Salesforce CRM on businesses and owners. If the customer subscribes to the consumer credit report, commercial/business reports, and plaid product. We must collect additional documents and perform the following checks -

  1. Document Collection(Required for go-live)-

    1. Certificate of incorporation

    2. Articles of association

    3. Business licenses and operating permits

  2. EIN Verification - In Salesforce CRM, users must run the EIN verification to ensure the business is valid and that the correct information has been provided to us.

  3. If the contract value exceeds USD 30,000.00, the billing team should run the experian business premier profile report.

4.2 Beneficial Ownership

Cloud Maven, Inc. will identify Ultimate Beneficial Owners (UBOs) who:

  • Own 25% or more of the company

  • Control the business through other means

Required information for UBOs includes:

  • Full name

  • Address

4.3 Risk Assessment

Businesses will be assessed based on:

  • Industry and business operations

  • Geographic risk (e.g., high-risk jurisdictions)

  • Ownership structure

  • Nature of transactions

4.4 Verification Process

  • Step 1: Verify business documents using SOS and EIN process( automatic)

  • Step 2: Identify and validate UBOs ( we will get the data from SOS and Article of incorporation)

  • Step 3: Conduct OFAC and Sanction checks on UBOs and business entity

  • Step 4: Assess risk level (from the business credit report)

  • Step 5: Approve or reject business onboarding (unless we have a OFAC match or Sanction record, we shouldn’t reject the business)

4.5 Ongoing Monitoring

  • Continuously monitor business transactions for irregularities

  • Update KYB documentation periodically or when significant changes occur

  • Report suspicious activities to relevant authorities

5. Responsibilities

  • Sales and Customer Support Team: Assists in document collection and verification.

  • Compliance Team: Oversees implementation of KYC and KYB processes, conducts periodic audits, and reports suspicious activities.

  • Management: Ensures proper training and enforcement of KYC and KYB policies.

6. Record-Keeping

  • All KYB and KYC data will be retained for at least 1 year after the customer relationship ends.

  • Records will be securely stored and accessible only to authorized personnel.

7. Reporting

Suspicious activities will be reported to:

  • Financial Crimes Enforcement Network (FinCEN) or relevant regulatory bodies

  • Internal compliance officers for further investigation

8. Review and Updates

This policy will be reviewed annually or as required to ensure compliance with legal and regulatory changes.

9. Compliance Statement

By adhering to this KYC and KYB policy, Cloud Maven, Inc. aims to maintain a secure, transparent, and compliant environment for all customers and business partners.