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Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance is mandatory for any token sale that accepts fiat currency or cryptocurrencies as consideration from investors. Before allowing any investor to participate in a token sale, the issuer must verify the investor's identity using reliable and independent documentation, screen the investor against international sanctions lists and PEP databases, assess the source and legitimacy of the investment funds, and obtain sufficient information to satisfy itself that the investment does not represent the proceeds of crime or terrorism financing.
Neptune Fiduciaries Group assists ICO and token sale issuers in designing and implementing comprehensive KYC and AML programmes appropriate to the scale, risk profile, and regulatory requirements of their offering. We assist in selecting appropriate technology providers for automated investor identity verification and screening, drafting AML and KYC policies and procedures to the standard required by the relevant financial regulator, training the compliance team, and establishing the ongoing transaction monitoring and suspicious activity reporting infrastructure needed after the token sale concludes.
Investor Identity Verification Requirements
We advise on the identity verification requirements applicable to your token sale, including document types acceptable as proof of identity, liveness check requirements, and enhanced due diligence requirements for higher risk investor categories.
PEP and Sanctions Screening
All token sale investors must be screened against international sanctions lists (OFAC, EU, UN) and politically exposed persons databases. We assist in selecting and implementing automated screening technology appropriate to the volume and risk profile of your investor base.
Source of Funds Assessment
For higher risk investors and larger investment amounts, source of wealth and source of funds documentation must be obtained and assessed. We advise on the risk-based thresholds and documentation standards appropriate to your ICO AML risk assessment.
AML Policy and Procedure Documentation
We draft comprehensive AML policies and procedures for the token sale covering customer onboarding, ongoing monitoring, suspicious activity reporting, record keeping, and staff training, meeting the documentary requirements of the relevant regulatory framework.
Get in Touch
Contact Neptune Fiduciaries Group via info@neptunecorporate.com or visit our Contact Us page.
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