Private Holding KYC

KYC stand for policies to 'Know Your Customers.' In today's world, it has become increasingly important, especially for the banks and various financial institutions to identify and prevent money laundering, terrorist activities, identity theft and financial fraud. At Private Holdings, we have no tolerance policy for any type of fraud. We adopt all possible preventive measures to control these types of fraudulent activities. We will document any such activity and will immediately close down all related accounts. We are authorized to confiscate all funds in those accounts which we find fraud.

Fraud Prevention

To prevent fraud or theft, Private Holdings use a wide range of security and fraud control measures. Private Holdings ensure to protect the integrity of all the sensitive data like your personal account information and the transactions that you perform through your account. To secure your account and electronic transactions, we need some of your information which includes your preferred method for deposit.

For the KYC Policy, we may define a customer as:

• An individual or an entity with an account or/and business relationships with Private Holdings on behalf of whom we maintain the account (that is the beneficiary owner).
• Any beneficiaries of the transactions that professional intermediaries perform such as Private Holdings stockholders, solicitors, accountants and others as law permits.
• Any individual or entity linked with any financial transaction may pose a significant threat to the reputation or any threats to Private Holdings such as the issuance of high-value demand draft or wire transfer in the form of a single transaction amount.

The KYC policy of Private Holdings comprises of the following eight essential components:
1. Procedures for customer identification
2. Transactions monitoring
3. Training program
4. Management of risk
5. Record keeping
6. Internal control system
7. KYC guidelines evaluations through internal inspection and audit system
8. Responsibilities/duties and accountability

Private Holdings has put in place an effective program with suitable established procedures, and we ensure its effective implementation. Our program covers proper management of controls, systems and oversight, duties segregation, training and other matters related to it. The responsibility is allocated explicitly inside the company to ensure effective implementation of the company's procedures and policies. The risks to the profile of Private Holding’s customers determine the nature and scope of due diligence. The internal audit and compliance procedures of Private Holdings play a vital role in the evaluation and adherence to the policies and procedures of KYC. The function of compliance gives an independent assessment of Private Holdings procedures and processes, including regulatory and legal requirements. It ensures adequate staffing of audit machinery with the right individuals who have knowledge of such procedures and policies. Our internal inspectors perform checks and verify the KYC procedures application at the offices/branches and give their comments on any lapses in this.

The Private Holdings Proposed KYC Manual of Procedures is as follows:

Introduction

Attributes like name used, birth date and customer's residential address form the identity of the customer. Through this information, you can identify a legal or natural individual. To identify an original individual, we should obtain the birth date as a significant identifier for supporting the name. In case customer gives an international passport as its source of evidence, we keep a record of its identity, birth date, country of issuance and number preferably in the form of a passport scan to maintain a record. Once you establish a business relationship, open an account or makes a significant transaction with Private Holdings, the identity should be verifiable anytime.

The following person’s identity needs verification:
• Clients: the client must provide sufficient identity evidence to demonstrate his or her identity.
• The person who acts on behalf of someone else (like account managed through power of attorney) they should both provide sufficient evidence to support their identities.

There should be identification documents to verify all of the following information:
• The actual name of the person/ account holder whose name is registered with us for investment
• Any significant funds beneficial owner (25% and above) who invests and is not the actual holder of the account or the investor who is named
• The principal account controller(s) or those who have a business relationship
• And any involved intermediate parties (e.g. where the intermediary manages or owns the account)
• All the directors and signatories that show in the account who are not the primary controllers need to report and prove their identities with relevant evidence.
• In case several account holders have a single account, all of them should provide us with the identification evidence.
• Refusal or failure of providing satisfactory evidence by any or all applicants within a given period without sufficient grounds may cause a suspicion that the investor or depositor is likely to involve in money laundering.

Identifications Procedures

Private Holdings ensure that our customer is an actual individual or organization (corporate, legal or natural entity) by taking adequate evidence for identification. When we place the third party for identification or confirmation of the applicant's identity, the complete responsibility to obtain satisfactory evidence of identification is of Private Holdings. The primary purpose is to get evidence of that person, evidence that an individual of the same name lives at the given address and the applicant is actually that individual or that the owners of the company are possible to identify and are easily locatable at the given address.

In case, the clients or customers are foreigners who cannot physically present themselves to the Private Holdings local offices or headquarter, they should provide as evidence of the residence country's embassy, high commission or consulate certified or lawyer, senior bank officer or public notary signed copy of their national id card or an international passport. There should be 'certified copy/original seen' written on each identification documents certified copy.

The photographic identity evidence should also make a sound reproduction. When it is not possible to give photographic identity, the evidence copy needs to be certified as giving an applicant's likeness in good terms.

All private persons should provide the following information:
• The real full used name
• The permanent address of residence including the postcode
• The provided information should confirm that the provided name of the customer should also live at the given address.
• The person is the same as the information provided like utility bills.
• The previous address needs validation if the applicant recently relocated to some other address.

We can use the following documents to attest the information provided to us:
• Documents of personal identity
• Current international passport
• Immigration authorities issued a residence permit.
• Existing driving license
• Birth certification/ Sworn age declaration certificate
• Tax Clearance Certificate by Inland Revenue
• Home visit record
• Confirmation from the registered electoral that a particular individual of that name resides at the given address
• Recent utility bills (gas, internet, electricity, etc.)

Important Note: Use a physical municipality or physical electric bill instead of a mobile or telephone bill.
Suppose the person is not able to provide those documents or unable to deliver sufficient evidence as a supplementary or alternative. In that case, we may verify the information through other sources of data like Electoral Register's electronic search, accessing external or internal account database or electric public records search where available.

In addition to identity information documents, we must obtain other vital information to prevent money laundering. In case there is suspicion or doubt, the customers need to provide us with additional documents.

• The legal evidence that exists between the beneficial owner and signatories
• The invested or deposited funds sources and origins.
• The estimate of net worth
• Information about customer’s employment or occupation
• Reference from the bank which can be like the following:

Letter from Bank Example
To whom it may concern
Date: ………………….
REF number:
Mr. …. This letter is to confirm that (name), (full address) has a good standing with our bank, and he/she has been our bank’s client for the past … years.
Yours Sincerely
(Bank Officer’s Signature and Stamp)
You should understand that the amount of evidential information that we ask from the client varies from client to client, the type of activity in which you involve with Private Holdings and the risks involved.

There is a particular person's category that requires due diligence of a higher level.
• The residence of a country or having funds from the countries of origin have inadequate anti-money laundering standards or represent high corruption and crime risks (such as countries in Africa, Eastern Europe, Central America, and some Islamic countries. The lists of such countries are frequently updated and distributed on the internet – you can use the list at your own risk).
• Persons involved in sectors or business activities that have a susceptibility to money laundering
• Defence executives
• Corporations that are exposed politically
• Politicians
• Important officials of political parties and their close associates and families
Private Holdings should keep all information up-to-date and secure.

Monitoring

Private Holdings reserve the right to use special procedures as much as necessary to stay alert of any indications of the misuse of our services by an unusual or suspicious customer to detect any situations that can lead to the event of money laundering. We can implement these procedures through our automated system or rely on our staff's vigilance.
Several characteristics further justify our inspection, such as:
• The unusualness or usualness of the transaction (related to the frequency or size of the transaction)
• The transaction’s nature
• The transactions’ series nature
• The payment’s origin or geographic destination of the payment ( from or to the country of high-risk)
• The concerned parties (from or to a person listed on the list of sanctions) Every measure that Private Holdings take is compliant with the applicable guidelines that competent authorities issue.

Fraud Prevention
For Individual Clients

• Whenever clients use credit cards, do ask for both sides scan of the card and ensure that no one has altered or manipulated the scans.
• The last four credit card digits or CVV code present on the backside should not appear on the scans. This is also applicable for documentation of scans that are easy to manipulate by using graphic software like Photoshop.
• Ensure to pay attention and get consent for each transaction from the cardholder whose name is printed on the card. For instance, if the client uses the credit card of its spouse, remember receiving the personal consent of the spouse for the completing transaction and verify the identity of the spouse according to the above description to prevent any chargebacks. For Corporate Clients • The client either needs to provide us with an attesting certified by POA that signatory signs and binds the client or a corporate secretary's confirmation for the same.
• Or should provide the following declaration: I (name) guarantee and personally declare that the corporate entity entitles me to sign on its behalf, and I take full legal consequences liability at a personal level should you find this declaration inaccurate."

If you have any questions during the business course with us, you can get in touch with us anytime through phone or email.

Anti-Money Laundering

Private Holdings has no tolerance for money laundering, and we support the fight against anyone involved in money-laundering. We follow the Joint Money Laundering Steering Group guidelines. The company is a Financial Action Task Force member. It is an intergovernmental body which combats terrorist financing and money laundering.

Private Holdings now has specific policies for deterring people from acts of money laundering. These include the following policies:

• Ensuring that clients have authentic identification proof while maintaining records of their identification
• Checking the names of the clients against a list of suspected or known terrorists to determine and verify the client's identity
• Informing clients that we may use their provided information to verify their identity following their money transactions closely
• Not receiving money orders, exchange house transfers, cash, Western Union transfers or transactions through third parties.

When funds are moved by an illegal or criminal activity across the financial system, it leads to money laundering. The process makes the money movement appears like the funds are coming through legitimate sources.

The money laundering activity follows these three stages:
• The person who does money laundering places cash or equivalents within the financial system.
• Then through a financial transaction series, the money launderer moves or transfers the money to other (or futures accounts). It is designed to hide the money origin (for instance, executing trades without or little financial risk or account balances transfer to some other accounts).
• Finally, the person reintroduces the funds into the financial system to make them appear like coming from legal sources (for example, futures accounts and then transferring the amount to some other bank account).

The money launders use the trading accounts as one of the sources to do money laundering of illegal funds or for hiding the real funds' ownership. Notably, the money launderer can use the trading account to carry out financial transactions that hide the actual origins of funds. As a preventive measure, the Private Holdings directs withdrawal of funds back to their original remittance source.
International Anti-Money Laundering department needs institutions that provide financial services to stay aware of the potential abuses of money laundering that may happen in the account of a customer. And it implements a program of compliance to detect, deter and report any potential dubious activity. We have implemented these guidelines to provide maximum protection to Private Holdings and our clients. You can contact our support if you have any questions or concerns regarding our guidelines.

What Is Meant By Money Laundering?
Money laundering refers to an act of hiding illegal money obtained through illicit sources so that they appear legitimate. Private Holdings adheres to stringent laws that render money laundering illegal for our company or our agents or employees to involve or engage in any such activities that relate to money laundering even if remotely. Our policies related to money-laundering provide increased protection to investor, client's security, and provide safe processes for payment.

Identification

The primary safeguard that we provide to our customers against money laundering is our sophisticated KYC (Know-Your-Customer) verification policy.

To ensure your compliance with the standard regulation of AML, you need to provide us with the following documents:
Identification proof: a clear back and front copy of your national verified ID card. It can be your driver's license or passport or your government-issued ID card.
Residence proof: the official document that authorities have issued during the last three months clearly states your name, address and date of birth as you have registered with Private Holdings. This can also include your utility bills (such as electricity, landline or water) or a bank statement.

Kindly ensure that your copy should include the following to ensure your complete security and privacy:
• The last four digits printed on your credit card should be visible.
• You can keep the last three digits on your card back concealed (CVV code)

Also, note that different countries have different regulatory requirements, and we may request other documents from you.

Monitoring

For us, third-party payments are not acceptable. You should make all deposits to your accounts with us with your real name and match the submitted KYC documents. Due to the application of regulatory AML policies, all funds that you withdraw should return to the precise source from where you received them. It means that we will return the funds deposited actually through the bank transfer to a similar account when you make a withdrawal request. Similarly, if you made the deposit through the credit card, we return your funds to that credit card when you make a withdrawal request. Under any circumstances, we never accept disburse cash or cash deposits when you make withdrawal requests.

Reporting

According to AML regulations, we should track and monitor any suspicious transactions made through our platform and report any suspicious activities to the law enforcement agencies. Private Holdings also reserve the right of denying any transfer anytime if we consider the transfer to have connections with money laundering or any criminal activity in any way. The law does not allow us to inform customers regarding the reports that we submit to the law enforcement institutions related to the suspicious activities.

The Financial Products offered by the company include Contracts for Difference (‘CFDs’) and other complex financial products. Trading CFDs carries a high level of risk since leverage can work both to your advantage and disadvantage. As a result, CFDs may not be suitable for all investors because it is possible to lose all of your invested capital. You should never invest money that you cannot afford to lose. Before trading in the complex financial products offered please ensure to understand the risks involved.

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