PontisGlobe

Know Your Customer (KYC) Policy

Last Updated: May 2026

1. Purpose & Scope

PontisGlobe is committed to operating as a fully compliant global payments platform. This KYC Policy establishes the standards and procedures we apply to verify the identity of all users — individuals and businesses — before they access our services. Our KYC programme is designed to:

  • Prevent the use of PontisGlobe for money laundering, terrorist financing, and other financial crimes
  • Comply with applicable AML/CTF laws across all jurisdictions in which we operate
  • Meet the requirements of the Financial Action Task Force (FATF) Recommendations
  • Protect the integrity and reputation of the PontisGlobe platform

2. Customer Identification Programme (CIP)

All users must complete our Customer Identification Programme (CIP) before accessing PontisGlobe services. No transaction may be initiated or funds held until CIP verification is complete.

For Individual Users — Required Documents

  • Government-issued photo identification: Passport, National Identity Card, or Driver's Licence
  • Proof of residential address (issued within the last 3 months): Utility bill, bank statement, or government-issued document
  • Date of birth confirmation
  • Facial biometric verification (selfie matched against photo ID)
  • Mobile number and email address verification

For Business Users (KYB — Know Your Business) — Required Documents

  • Certificate of incorporation or equivalent legal registration document
  • Memorandum and Articles of Association
  • Proof of registered business address
  • List of all directors and beneficial owners (ownership threshold: 10% or greater)
  • Government-issued ID and proof of address for each director and UBO
  • Authorised signatory documentation
  • Business financial statements or bank statements (for Enhanced Due Diligence)
  • Licence/regulatory approval documents (where applicable)

3. Risk-Based Approach

PontisGlobe applies a risk-based approach to KYC, calibrating the level of due diligence to the specific risk profile of each customer relationship. Customers are assigned to one of three risk categories:

Standard Risk

Applies to the majority of retail users. Completed via standard document submission and biometric verification. Access to all standard Platform features upon successful verification.

Medium Risk

Applies to users from jurisdictions with elevated risk ratings, users with complex ownership structures, or those engaging in higher transaction volumes. Requires additional documentation including source of funds declaration and, where applicable, source of wealth information.

High Risk / Enhanced Due Diligence (EDD)

Applies to Politically Exposed Persons (PEPs), customers from FATF high-risk jurisdictions, customers with complex beneficial ownership structures, and customers whose transaction patterns trigger risk monitoring alerts. EDD requires senior management approval, enhanced documentation, face-to-face or video KYC, and ongoing enhanced monitoring.

4. Politically Exposed Persons (PEPs)

PontisGlobe screens all users against PEP databases at onboarding and on an ongoing basis. A PEP is defined as an individual who holds or has held a prominent public function, including heads of state, senior government officials, senior judiciary, senior military officers, and senior executives of state-owned enterprises.

PEPs and their immediate family members and close associates are subject to Enhanced Due Diligence as a mandatory requirement. Senior management approval is required before any business relationship with a PEP is established or continued.

5. Sanctions Screening

All users are screened against applicable sanctions lists at onboarding and on an ongoing basis, including:

  • OFAC (US Office of Foreign Assets Control) SDN List
  • EU Consolidated Sanctions List
  • UN Security Council Sanctions List
  • HM Treasury (UK) Financial Sanctions Register
  • Applicable local sanctions lists in our operating jurisdictions

Any match against a sanctions list will result in immediate suspension of the account and notification to the relevant authorities in accordance with applicable law.

6. Ongoing Monitoring

KYC is not a one-time process. PontisGlobe conducts continuous monitoring of all customer relationships, including:

  • Periodic KYC refresh based on risk profile (Standard: 3 years | Medium: 2 years | High: 1 year)
  • Event-triggered KYC reviews (e.g., significant change in transaction behaviour, adverse media alerts)
  • Ongoing sanctions and PEP re-screening
  • Ongoing transaction monitoring for patterns inconsistent with the customer's profile

7. Transaction Limits & Verification Tiers

Access to higher transaction limits is subject to successful completion of the applicable verification tier:

  • Tier 1 (Basic Verification — Email + Phone): Limited functionality, restricted transaction limits
  • Tier 2 (Standard KYC — ID + Proof of Address): Full access to standard remittance and wallet features
  • Tier 3 (Enhanced KYC — Source of Funds + EDD): Access to elevated limits and business payment features

Specific transaction limits applicable to your account tier will be decided after your successful onboarding and KYC verification. For questions, contact contact@pontisglobe.com.

8. Refusal, Suspension & Account Closure

PontisGlobe reserves the right to:

  • Decline to onboard any applicant who does not satisfy our KYC requirements
  • Suspend any account where updated KYC documentation has not been provided within the required timeframe
  • Terminate any account where a user fails ongoing monitoring thresholds or is found to have provided false documentation
  • File a Suspicious Activity Report (SAR) or equivalent report with the relevant financial intelligence unit where required

PontisGlobe will not inform customers that a SAR has been filed, in compliance with applicable tipping-off prohibitions.

9. Data Protection & KYC Records

All KYC documents and verification records are stored securely and retained for a minimum of 5 years from the date of the last transaction or account closure, in accordance with applicable AML record-keeping requirements. Please refer to our Privacy Policy for full details of how KYC data is processed and protected.