This includes, but is not limited to:

1. Establishing robust internal policies, procedures and controls that strive to combat any attempted use of XCHANGED for illegal or illicit purposes and to ensure our customers basic protections under consumer protection laws;
2. Complying with the reporting requirements by the Financial Crimes Enforcement Network (“FinCEN”);
3. Filing Suspicious Activity Reports (“SARs”);
4. Maintaining comprehensive records of orders and other transfers;
5. Designating an officer of XCHANGED as Chief Compliance Officer (“CCO”) who is responsible for the implementation and oversight of our BSA/AML Program;
6. Executing Know Your Customer (“KYC”) procedures on all customers;
7. Performing regular, independent audits of our BSA/AML Program;
8. Following record retention requirements; and
9. Implementing a formal and ongoing compliance training program for all new and existing employees.

What is eKYC?

1. Banks
2. Financial Institutions
3. Money Service Business
4. FI's situated abroad
5. Mobile Service Projdier and Telecom
6. Utility connections (Gas, water and electricity)
7. Apps that deal with financial transaction such as XCHANGED web remit software or android or IOS app

1. Consent Based
   eKYC is consent-based in the sense an individual can share data based on any approved authentication for verification. An individual that requires a service or utility must file for eKYC of his or her own accord and consent. This protects the individual’s right to privacy which is a fundamental right bestowed upon us by our constitution.
2. Paperless System
   eKYC is a paperless system that replaces the need for document management with paper-based documents. This enables a company, state or country to reduce their carbon footprints by going eco-friendly and using a cloud-based online system. Not only does going paperless save the planet, it also helps in reducing costs associated with normal KYC compliance.
3. Instantaneous
   The eKYC service is completely automated online. This means that KYC data can be transferred in real-time without the need for any manual intervention. The paper-based KYC process can take days up to weeks to get verified, but the eKYC process takes just a few minutes or hours to verify and issue.
4. Transparency Of Transactions Or Usage
   eKYC enables all records and data to be stored permanently online. Any misuse, illicit gain or illegal activity can be traced back to the individual or parties involved in such transactions or usage of services.
5. Regulator friendly
   All eKYC requests are recorded on the system and all submitted Personal Identity documents are secured for each customer for future use and reference as needed by law enforcement agencies.
6. Secure System
   A customer’s account, data and information are secure because the entire process is online. Identity theft, fraud, loan scams, money laundering, the flow of black money, etc. are all minimized with a secure online digital system of KYC.
7. Efficient Communication
   Effective information can be relayed in an efficient and timely manner. Generally, with any automated system, there is no need to constantly go back and forth because most details are published automatically, unlike having to fill in a KYC form manually.
8. ‘Free of Cost’ Process
   Usually, customers that opt to undergo eKYC aren’t required to pay any additional amount for doing so. A company or institution may have to undergo automation costs officers installing verification devices and systems which are beneficial in the long-run.

Individual customer — Prior to opening an account for an individual customer, we attempt to collect, verify, and authenticate the following information:

• Email address;
• Mobile phone number
• Full legal name
• Social Security Number ("SSN") or any comparable identification number issued by governament;
• Date of birth ("DOB")
• Proof of identity (e.g., driver’s license, passport or government-issued ID);
• Home address (not a mailing address or P.O. Box); and
• Additional information or documentation at the discretion of our Compliance Team.

• Institution legal name;
• Employer Identification Number (“EIN”) or any comparable identification number issued by government;
• Full legal name (of all account signatories and beneficial owners);
• Email address (of all account signatories);
• Mobile phone number (of all account signatories);
• Address (principal place of business and/or other physical location);
• Proof of legal existence (e.g., state certified articles of incorporation or certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable);
• Contract information of owners, principals, and executive management (as applicable);
• Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more, as well as all account signatories; and
• Identifying information for each entity beneficial owner that owns 10% or more (see individual customer information collected above for more details).
• If your institution successfully meets and completes our CIP requirements and neither it nor any of its owners, principals, executive, or managers appear on OFAC or any other governmental watchlist, we will provide you with account opening agreements electronically.