KYC/KYB Policy

1. Overview

Easner, Inc. ("Easner," "we," "us," or "our") is committed to maintaining the highest standards of compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations. As a technology platform facilitating financial services through licensed partners, we conduct comprehensive KYC (Know Your Customer) and KYB (Know Your Business) verification on all users to ensure regulatory compliance, prevent fraud, and protect our platform and users.

This policy outlines our KYC/KYB procedures, the information we collect, how we use it, and your rights regarding the verification process. For more information about how we handle your personal data, please review our Privacy Policy.

2. What is KYC/KYB?

KYC (Know Your Customer) refers to the process of verifying the identity of individual users to ensure they are who they claim to be. KYB (Know Your Business) refers to the process of verifying business entities and their beneficial owners.

These verification processes are required by law in most jurisdictions where we operate and are essential for:

• Preventing money laundering and terrorist financing
• Complying with regulatory requirements in multiple jurisdictions
• Protecting our platform and users from fraud and financial crime
• Ensuring the integrity of our financial services network
• Meeting the compliance standards of our licensed financial service partners

3. When We Conduct KYC/KYB

We conduct KYC/KYB verification in the following circumstances:

• Account Registration: All users must complete identity verification when creating an account
• Before First Transaction: Users must complete verification before their first money transfer
• Periodic Reviews: We may conduct periodic re-verification to ensure information remains current and accurate
• Risk-Based Triggers: Additional verification may be required based on transaction patterns, amounts, or risk indicators
• Regulatory Requirements: When required by law or regulatory authorities in specific jurisdictions
• Partner Requirements: When our licensed financial service partners require additional verification for specific corridors or services

4. Information We Collect for KYC/KYB

For Individual Users (KYC):

• Full legal name (as it appears on government-issued identification)
• Date of birth
• Residential address
• Government-issued photo identification (passport, national ID card, driver's license)
• Proof of address (utility bill, bank statement, or similar document dated within the last 3 months)
• Phone number and email address
• Additional information as required by specific jurisdictions or transaction types

For Business Users (KYB):

• Business legal name and registration number
• Business address and jurisdiction of incorporation
• Business registration documents and certificates
• Information about beneficial owners (individuals who own or control 25% or more of the business)
• Authorized signatories and their identification documents
• Business bank account information
• Nature of business and source of funds

5. Document Requirements

Accepted Identity Documents:

• Valid passport (preferred)
• National ID card
• Driver's license
• Other government-issued photo identification as accepted in your jurisdiction

Accepted Address Verification Documents:

• Utility bill (electricity, water, gas, internet) dated within the last 3 months
• Bank statement dated within the last 3 months
• Government-issued tax document
• Rental agreement or lease document
• Other official documents as accepted in your jurisdiction

Document Requirements:

• Documents must be clear, legible, and in color
• All four corners of the document must be visible
• Documents must be valid and not expired (for identity documents)
• Documents must be in English or accompanied by a certified translation
• Documents must match the information provided in your account

6. Verification Process

Our verification process typically involves the following steps:

1. Document Submission: You upload your identity and address verification documents through our secure platform
2. Automated Checks: Our system performs initial automated verification checks on document authenticity and data extraction
3. Manual Review: Our compliance team reviews your submission to ensure all requirements are met
4. Additional Checks: We may conduct additional checks including sanctions screening, PEP (Politically Exposed Person) screening, and adverse media checks
5. Approval or Request for Additional Information: You will be notified of the verification status. If additional information is required, you will receive specific instructions

Verification Timeline: Most verifications are completed within 1-3 business days. Complex cases or requests for additional information may take longer. You will be notified of any delays.

7. How We Use KYC/KYB Information

We use the information collected during KYC/KYB verification to:

• Verify your identity and prevent identity fraud
• Comply with legal and regulatory requirements including AML, KYC, and sanctions screening
• Assess and manage risk on our platform
• Prevent money laundering, terrorist financing, and other financial crimes
• Share with licensed financial service partners as necessary for transaction processing
• Respond to requests from regulatory authorities and law enforcement
• Maintain accurate records as required by financial services regulations

For detailed information about how we handle your personal data, please review our Privacy Policy.

8. Data Retention

We retain KYC/KYB information and documents in accordance with applicable legal and regulatory requirements. Retention periods vary by jurisdiction but typically range from 5 to 7 years after the closure of your account or the last transaction, as required by financial services regulations. In some jurisdictions, we may be required to retain certain information for longer periods. We securely store all KYC/KYB documents and information using industry-standard encryption and security measures.

9. Verification Status and Consequences

Approved: Your account is verified and you can use all Easner services subject to transaction limits and other terms.

Pending: Your verification is under review. You may have limited access to services until verification is complete.

Rejected: Your verification was not approved. Common reasons include:

• Documents are unclear, expired, or invalid
• Information provided does not match the documents
• Documents do not meet our requirements
• Additional information is required but not provided
• Regulatory or compliance concerns identified during review

If your verification is rejected, you will receive specific feedback and may be able to resubmit with corrected or additional information. We reserve the right to refuse service if verification cannot be completed satisfactorily.

10. Your Rights and Responsibilities

Your Responsibilities:

• Provide accurate, complete, and up-to-date information
• Submit clear, valid, and authentic documents
• Notify us immediately of any changes to your information
• Cooperate with our verification process and respond promptly to requests for additional information
• Understand that providing false or misleading information may result in account closure and legal action

Your Rights:

• Access your verification information and status
• Request correction of inaccurate information (subject to regulatory requirements)
• Understand why verification was rejected and how to correct it
• File a complaint if you believe your verification was handled incorrectly

11. Sharing with Partners and Authorities

We may share your KYC/KYB information with:

• Licensed Financial Service Partners: We share necessary verification information with our licensed partners who facilitate transactions, as required for regulatory compliance
• Regulatory Authorities: We may be required to share information with financial regulators, law enforcement, and other government authorities as required by law
• Service Providers: We may use third-party service providers to assist with verification, screening, and compliance checks, all of whom are bound by strict confidentiality agreements

All sharing is conducted in accordance with applicable data protection laws and our Privacy Policy.

12. Security and Confidentiality

We implement industry-standard security measures to protect your KYC/KYB information, including encryption in transit and at rest, secure document storage, access controls, and regular security audits. All information is handled in strict confidence and accessed only by authorized personnel with a legitimate business need. Our compliance team is trained in data protection and confidentiality requirements.

13. Changes to This Policy

We may update this KYC/KYB Policy from time to time to reflect changes in regulations, our practices, or our services. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about our KYC/KYB procedures, need assistance with verification, or wish to update your information, please contact us at: