Know Your Customer (KYC) Policy

Company Name: Starsky Global Inc.

Jurisdiction: United States

Effective Date: August 2022

1. Purpose

This Know Your Customer (KYC) Policy outlines the procedures Starsky Global Inc. uses to verify customer identities and assess risks, in accordance with U.S. regulations and FinCEN guidance.

2. Customer Onboarding & Identification

a. Retail Users

Full legal name

Date of birth

Nationality

Residential address

Government-issued photo ID (passport, driver's license, etc.)

Liveness check (face match with ID)

b. Business Entities

Entity name

Country of incorporation

Certificate of incorporation

Authorized signatory KYC

Business address

Ownership structure (UBO information)

3. Risk-Based Approach

KYC procedures are tiered based on user risk profile:

Low-risk users: Standard ID verification

High-risk users (PEPs, high-volume traders, etc.): Enhanced Due Diligence (EDD)

4. Enhanced Due Diligence (EDD)

EDD is triggered when:

Large transactions are initiated

Users are from high-risk jurisdictions

Users are flagged by sanctions/PEP lists

EDD measures may include:

Additional identity verification

Proof of source of funds or wealth

Manual compliance review

5. Sanctions and Screening

Starsky Global screens all users against:

OFAC SDN List

UN, EU, UK sanctions lists

PEP databases and law enforcement watchlists

Users from sanctioned regions are blocked.

6. Ongoing KYC & Re-verification

Periodic re-verification of user data is conducted

Users must update any changes in legal identity or residency

Inactive or suspicious accounts may be suspended pending review

7. Data Storage and Protection

All user identity records are securely stored for at least 5 years and are encrypted in accordance with best practices and applicable data protection laws.

8. User Consent

Users must agree to our Terms of Service and Privacy Policy, and give informed consent to KYC procedures before accessing any financial functionality.

9. Policy Review

The KYC policy is reviewed annually, or earlier if prompted by regulation or operational change.

Authorized by:

Starsky Global Inc.

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