Know Your Customer (KYC) and Know Your Business (KYB) Policy

Last Updated: March 26, 2025

1. Introduction

Qtech Middle East Ltd ("the Company," "we," "us," or "our") is committed to implementing robust Know Your Customer (KYC) and Know Your Business (KYB) procedures as part of our overall Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) framework. This policy outlines our approach to customer due diligence and is designed to comply with global regulatory standards governing cryptocurrency CFD trading platforms.

2. Purpose and Scope

The purpose of this KYC/KYB Policy is to:

Establish systematic procedures for customer identification and verification
Prevent identity theft, financial fraud, money laundering, and terrorist financing
Comply with relevant regulatory requirements in jurisdictions where we operate
Protect the Company and our clients from financial crime risks
Maintain the integrity of the global financial system

This policy applies to all clients, including individuals and business entities, who seek to establish a business relationship with the Company or conduct transactions through our platform.

3. Risk-Based Approach

The Company employs a risk-based approach to KYC/KYB procedures, which involves:

Risk classification of clients based on specific risk factors
Application of standard or enhanced due diligence measures according to the risk classification
Ongoing monitoring commensurate with the level of risk
Regular reassessment of client risk profiles

3.1 Risk Factors

Risk factors considered in our assessment include but are not limited to:

Geographic factors: Country of residence, citizenship, incorporation, or operations
Client factors: Political exposure, adverse media, complex ownership structures
Product/service factors: High-value transactions, high leverage trading
Channel factors: Non-face-to-face onboarding, third-party introductions
Behavioral factors: Transaction patterns, account usage

3.2 Risk Categories

Based on our risk assessment, clients are categorized as:

Risk Level	Description	Due Diligence Level	Review Frequency
Low	Clients with standard risk profiles and low transaction volumes	Standard Due Diligence (SDD)	Every 24 months
Medium	Clients with some elevated risk factors	Standard Due Diligence with additional verification	Every 12 months
High	Clients with significant risk factors (e.g., PEPs, high-risk jurisdictions)	Enhanced Due Diligence (EDD)	Every 6 months
Prohibited	Clients from sanctioned countries or with confirmed adverse information	Relationship declined or terminated	N/A

4. Know Your Customer (KYC) Procedures for Individuals

4.1 Standard Due Diligence Requirements

All individual clients must provide the following:

Personal Information: Full name, date of birth, nationality, residential address, contact details
Identification Document: Government-issued photo ID (passport, national ID card, or driver's license)
Proof of Address: Recent utility bill, bank statement, or government correspondence (issued within the last 3 months)
Source of Funds Declaration: Information about the origin of trading funds
Financial Information: Employment status, occupation, annual income range, estimated net worth

4.2 Enhanced Due Diligence Requirements

For high-risk clients, additional requirements may include:

Secondary ID Verification: Additional government-issued identification
Enhanced Source of Funds Documentation: Bank statements, investment certificates, inheritance documentation, etc.
Source of Wealth Documentation: Evidence explaining the client's overall wealth
Tax Residency Information: Tax identification numbers and jurisdictions
Video Verification: Live video call to confirm identity
Additional Declarations: Regarding business activities, purpose of trading, and expected transaction patterns

4.3 Politically Exposed Persons (PEPs)

For clients identified as PEPs, we require:

Senior management approval for establishing or continuing the business relationship
Comprehensive understanding of the source of wealth and source of funds
Enhanced ongoing monitoring of the business relationship
Regular review of PEP status and risk assessment

5. Know Your Business (KYB) Procedures for Legal Entities

5.1 Standard Due Diligence Requirements

All business clients must provide:

Entity Information: Legal name, registration number, date of incorporation, registered address, business address, contact details, tax identification number
Registration Documents: Certificate of incorporation, articles of association, or equivalent
Corporate Structure: Organizational chart showing ownership structure
Beneficial Ownership Information: Identity of all individuals who own or control 10% or more of the entity
Management Information: Identity of directors, senior managers, and authorized signatories
Business Activity: Nature of business, industry sector, geographic scope of operations
Financial Information: Recent financial statements, annual reports

5.2 Enhanced Due Diligence for Legal Entities

For high-risk business clients, additional requirements may include:

Enhanced Corporate Documentation: Detailed business plans, licenses, permits
Third-Party Verification: Independent verification of business reputation
Bank References: References from primary banking partners
Transaction Profiles: Detailed expectations of trading activities
Enhanced Verification of Beneficial Owners and Controllers
Site Visits or Video Conferencing: To verify the existence and operations of the business

6. Verification Process

6.1 Document Verification

All submitted documents undergo rigorous verification checks, including:

Verification of authenticity and validity of identification documents
Cross-checking of information across multiple documents
Verification against sanctions lists, PEP databases, and adverse media
Use of advanced document verification technology to detect forgeries or alterations

6.2 Electronic Verification

The Company employs electronic verification methods, including:

Biometric verification (facial recognition)
Digital ID verification against governmental and commercial databases
IP address analysis and geolocation verification
Digital footprint analysis

7. Ongoing Due Diligence

The Company conducts ongoing due diligence throughout the business relationship, including:

Periodic review and update of KYC/KYB information based on risk level
Transaction monitoring to detect unusual or suspicious activities
Screening against updated sanctions and PEP lists
Review of risk categorization based on transaction patterns and account behavior
Additional verification when significant changes occur (e.g., address change, major transactions)

8. Record Keeping

The Company maintains all KYC/KYB records for a minimum of five years after the termination of the business relationship, including:

All identification documents and verification results
Risk assessments and categorizations
Records of approval decisions and rationales
Transaction histories and monitoring results
All correspondence related to due diligence

9. Data Protection and Privacy

The Company is committed to protecting client information and complies with applicable data protection regulations. Personal information collected for KYC/KYB purposes will:

Be processed lawfully, fairly, and transparently
Be collected only for the specified, explicit, and legitimate purposes outlined in this policy
Be adequate, relevant, and limited to what is necessary
Be kept accurate and up to date
Be stored securely and protected against unauthorized access
Be retained only for as long as necessary for legal and regulatory compliance

10. Employee Training and Responsibilities

All employees involved in client onboarding and monitoring receive comprehensive training on:

KYC/KYB procedures and requirements
Document verification techniques
Red flags and suspicious indicators
Regulatory requirements and updates
Internal reporting procedures

11. Policy Governance and Updates

This KYC/KYB Policy is:

Approved by the Company's Board of Directors
Reviewed at least annually or more frequently if required by regulatory changes
Updated to reflect changes in regulatory requirements, industry standards, or the Company's risk assessment
Subject to regular independent audits to ensure effectiveness and compliance

Contact Information

For any questions regarding our KYC/KYB Policy or procedures, please contact our Compliance Department at:

Email: info@qtrade.tech

Address: Sheikh Mohammed Bin Zayed Road, Rak, UAE

This policy is effective as of March 26, 2025, and supersedes any previous versions.