KYC Policy

Know Your Customer (KYC) Policy

Investir Pour Ton Avenir

1. Introduction

This Know Your Customer (KYC) Policy defines the principles and procedures implemented by Investir Pour Ton Avenir (hereinafter referred to as “the Company”) to identify and verify the identity of customers, beneficial owners, and related parties. The Policy is developed in accordance with relevant French laws and European Union directives to ensure compliance with regulatory obligations and to mitigate risks related to identity fraud, market abuse, and illicit financial activities.

2. Objective

The objective of this Policy is to:

• Ensure the accurate identification and verification of customers and their financial profiles.
• Establish the legitimacy of customers’ sources of funds.
• Safeguard the Company’s reputation and operations.
• Ensure compliance with regulatory requirements from the Autorité des Marchés Financiers (AMF), ACPR, and EU directives.

3. Scope

This Policy applies to all services offered by the Company and to all customer types, including natural persons, legal entities, trusts, and other legal arrangements. It is mandatory for all employees, officers, directors, and agents involved in customer onboarding and monitoring activities.

4. Legal and Regulatory Framework

This Policy adheres to:

• The French Monetary and Financial Code (Code Monétaire et Financier)
• EU Regulation 2015/847 and Directive (EU) 2018/843
• Guidelines from the Autorité des Marchés Financiers (AMF) and the Autorité de Contrôle Prudentiel et de Résolution (ACPR)
• Recommendations from the Financial Action Task Force (FATF)

5. Identification and Verification Procedures

5.1. Natural Persons: The Company collects and verifies the following information:

• Full legal name
• Date and place of birth
• Nationality
• Residential address
• Valid government-issued identification (passport, national ID card, residency permit)
• Proof of address (utility bill, tax statement, or bank statement less than 3 months old)

5.2. Legal Entities:

• Legal name and legal form
• Registration number and country of incorporation
• Registered office and business address
• Identity of directors, legal representatives, and ultimate beneficial owners (UBOs)
• Company registry extract and articles of incorporation

6. Risk-Based Customer Classification

The Company classifies customers based on their risk profiles, taking into account factors such as:

• Geographical risk (residency in high-risk jurisdictions)
• Nature of business activity
• Volume and frequency of transactions
• Involvement of politically exposed persons (PEPs)

Customers are categorized into low, medium, or high-risk profiles, and due diligence measures are adjusted accordingly.

7. Enhanced Due Diligence (EDD)

EDD is applied to high-risk customers and involves:

• Detailed investigation of the source of funds and wealth
• Ongoing monitoring of transactions and behavior
• Senior management approval for establishing or continuing the business relationship
• Additional documentation, including tax returns or audited financial statements

8. Ongoing Monitoring

Customer information is reviewed and updated regularly. Transactional behavior is monitored against expected activity profiles. Discrepancies, unusual patterns, or signs of misuse trigger further review.

9. Data Protection and Record Keeping

All customer data is processed in accordance with the General Data Protection Regulation (GDPR) and national data protection laws. Records of identity verification, documents, and communication are retained securely for a minimum period of five (5) years after the termination of the business relationship.

10. Training and Awareness

The Company conducts regular training programs for relevant staff to ensure understanding of KYC obligations, identification procedures, red flags, and regulatory changes.

11. Compliance Oversight

The KYC function operates independently within the compliance department and is subject to periodic internal and external audits. The Compliance Officer is responsible for oversight, escalation, and reporting to regulatory authorities when required.

12. Review and Amendments

This Policy is reviewed at least annually or upon changes in regulatory requirements or business structure. Updates are approved by senior management and communicated to all relevant employees.

Approved by:

Board of Directors, Investir Pour Ton Avenir