The Future of

Peer to Peer Lending

Know Your Customer (KYC) & Anti Money Laundering (AML)

The Deal Limited

Customer Approval & Due Diligence Procedures

Background

This document describes the process, workflows and tools for reviewing new account applications in order to determine whether an application should be approved or declined. The process for approving applications is in compliance with The Deal Limited’s (“The Deal”) AML/CFT Policy. It details Know Your Customer (“KYC”) and Customer Due Diligence (“CDD”) requirements that must be completed when onboarding a new customer.

As documented in the AML/CFT Policy, The Deal Limited conducts a risk assessment on The Deal’s AML/CFT risks taking into consideration customer, product, interface and geographical risks. The Deal will apply full KYC for all clients at onboarding and apply additional DD requirements at various stages and thresholds. This approach is supported by the European Supervisory Authorities (“ESA”) guidelines on the application of Simplified Due Diligence (“SDD”) and Enhanced Due Diligence (“EDD”) under a risk-based approach.

Customer Due Diligence means the following: -

  • Identifying all customers and verifying their identity
  • Identifying all beneficial owners, where applicable
  • Obtaining information on the purpose and the intended nature of the business relationship
  • Conducting ongoing monitoring to ensure transactions are consistent with the intended business relationship
  • Retain records of these checks and update them when there are changes

Non- compliance with CDD

If the required CDD cannot be completed in line with this documented procedure, The Deal will be unable to enter into or continue with the business relationship with the customer. If funds have been received by the customer, the customer’s account should be suspended and the MLRO should be notified immediately using the Unusual Activity Report (“UAR”) as set out in the Suspicious Activity Report (“SAR”) process document.

Acceptable ID (but not limited to): -

ID

  • Current signed Passport
  • Government issued ID card

 

The Deal Limited  

 

Anti-Money Laundering & Combating Financing of Terrorism Policy

 

 

Statement of Policy

 

The Deal Limited (“The Deal”) is fully committed to ensure that their product offering is not used for the purposes of financial crime including money laundering, financing of terror, evading of sanctions or otherwise facilitating criminal activity. It is The Deal’s policy to ensure full compliance with: -

 

  • Proceeds of Crime Act 2015
  • Terrorism Act
  • The Terrorism (United Nations Measures) (Overseas Territories) Order 2001
  • The Al-Qaida and Taliban (United Nations Measures) (Overseas Territories) 2002
  • Order under the Export Control Act 2005
  • UN Security Council Resolutions – UNSCR 1373/1267/1333/1390

 

This Anti-Money Laundering & Combating Terrorist Financing Policy (the “Policy”) sets out The Deal’s Anti-Money Laundering and Combating Financing of Terrorism (“AML/CFT”) roles and responsibilities.