KYC Policy

(KYC) Policy?

Know Your Customer (KYC)

This KYC methodology applies to all new and existing customer associations and to all products and services offered by Sages Group (SG). KYC is an ongoing, risk-based approach to collecting appropriate information about our customers and their business and financial activities with the goal of identifying customer activity that conflicts with established facts and information.

SG is committed to discouraging the use of its products and services for illegal purposes. The KYC policy and supporting procedures are a key part of our program to prevent and detect money laundering, terrorist financing, fraud, and financial crime; to meet our legal and regulatory obligations; and to gather sufficient information to help determine appropriate products and services to meet our customers’ financial needs.

Clients Identity

While establishing a relationship with a customer, we will verify the identity of an individual or the existence of an entity within acceptable timeframes using appropriate identification methods. When a product or service is being developed, we will determine whether it will be used by or on behalf of a third party. Where required, details of the third party and their relationship with the customer will be obtained before establishing the relationship.

Clients Information

We will collect and record all relevant information concerning current and prospective customers including beneficial owners, intermediaries, and other related parties. We will determine the purpose and intended nature of each relationship. Where applicable, we will record the type, volume, and frequency of expected account activity and inquire into the source of incoming funds or assets. The level of such measures will be based on a risk-sensitive approach depending on the customer type, business relationship, product, and transactions involved.

SG Duty

The responsibility for verifying identity and recording, confirming, and updating customer information lies with the management of the business unit maintaining the relationship, products, or services. In exceptional cases, management may rely on another party, internal or external to SG, to perform parts of the KYC process on their behalf. In such cases, the reason for reliance should be documented, including procedures that provide reasonable assurance that the obligations have been properly carried out.

Where reliance is placed on an external party, agreements must clearly define responsibilities for collecting and monitoring customer information. The business unit maintaining the relationship must retain all information required under this policy.