Know Your Customer (KYC) Policy

Document Information

Policy Title: Know Your Customer (KYC) Policy. Policy Number: VBS-POL-005. Version: 1.0. Document Classification: Public. Document Status: Active. Effective Date: 01 July 2026. Publication Date: 26 June 2026. Approval Date: 26 June 2026. Next Review Date: 01 July 2027. Approved By: Board of Directors. Policy Owner: Compliance & Customer Due Diligence Department.

1. Purpose

SENTINEL PEAK BANK ("the Bank") is committed to maintaining a secure and compliant banking environment by implementing robust Know Your Customer (KYC) procedures. This policy establishes the standards for identifying, verifying, and understanding our customers to prevent identity fraud, money laundering, terrorist financing, financial crime, and other unlawful activities while ensuring compliance with applicable laws and regulatory requirements.

2. Scope

This policy applies to individual customers, joint account holders, business entities, corporate customers, partnerships, trusts and foundations, non-profit organizations, beneficial owners, authorized signatories, directors and shareholders, existing and prospective customers, and employees involved in customer onboarding. The policy applies to all products and services offered by SENTINEL PEAK BANK.

3. Objectives

The objectives of this policy are to verify the identity of every customer, understand the nature of customer relationships, assess customer risk, prevent identity theft and fraud, comply with AML and Counter-Terrorist Financing requirements, maintain accurate customer records, and protect customers and the Bank from financial crime.

4. KYC Principles

SENTINEL PEAK BANK operates under the following KYC principles: Customer Identification, Customer Verification, Risk-Based Assessment, Beneficial Ownership Verification, Ongoing Due Diligence, Continuous Monitoring, Record Maintenance, and Regulatory Compliance.

5. Customer Identification Requirements

Before establishing any banking relationship, customers must provide sufficient information to establish their identity. For individual customers this includes full legal name, date of birth, nationality, residential address, mailing address where different, telephone number, email address, occupation, employer details where applicable, government-issued identification, and Tax Identification Number where required. Acceptable identification documents may include passport, national identity card, driver's licence, residence permit, and other officially recognized identification documents.

6. Business Customer Requirements

Businesses applying for banking services must provide Certificate of Incorporation, Business Registration Certificate, Articles of Association or equivalent constitutional documents, registered business address, principal place of business, tax registration information, business licences where applicable, nature of business activities, ownership structure, shareholding information, list of directors, authorized signatories, and beneficial ownership details. Additional documentation may be requested depending on the customer's risk profile.

7. Beneficial Ownership

Where the customer is a legal entity, the Bank will identify and verify the natural person or persons who ultimately own or control the organization. Information collected may include ownership percentage, voting rights, control structure, identification documents, and residential addresses. The Bank reserves the right to request additional evidence where ownership structures are complex.

8. Customer Risk Assessment

Each customer is assessed using a risk-based methodology. Risk factors include country of residence, occupation, industry sector, expected transaction activity, source of funds, source of wealth, Politically Exposed Person (PEP) status, geographic risk, product usage, and delivery channels. Customers may be classified as Low Risk, Medium Risk, or High Risk. The level of due diligence applied will correspond to the customer's assessed risk.

9. Enhanced Due Diligence (EDD)

Additional verification measures may be required for higher-risk customers. EDD may include senior management approval, independent verification of identity, verification of source of wealth, verification of source of funds, additional documentation, more frequent account reviews, and enhanced transaction monitoring. EDD is generally required for Politically Exposed Persons (PEPs), high-net-worth individuals, customers from high-risk jurisdictions, complex corporate structures, high-value transactions, and cash-intensive businesses.

10. Source of Funds and Source of Wealth

Where appropriate, customers may be asked to provide information demonstrating the legitimate origin of funds or wealth. Examples include salary statements, business income records, investment statements, property sale agreements, inheritance documentation, tax returns, and audited financial statements.

11. Ongoing Customer Due Diligence

Customer information must remain accurate throughout the relationship. The Bank may periodically request updated identification documents, contact information, employment details, business information, ownership structures, and financial information. Customers are expected to notify the Bank promptly of material changes to their information.

12. Transaction Monitoring

Customer transactions are monitored to identify activity inconsistent with the customer's known profile. Monitoring may identify large cash deposits, unusual transfers, rapid movement of funds, structuring transactions, unexpected international payments, activity involving sanctioned jurisdictions, and suspicious account behaviour. Where appropriate, additional information may be requested before transactions are processed.

13. Refusal or Termination of Services

The Bank reserves the right to decline applications, suspend services, or terminate customer relationships where identity cannot be satisfactorily verified, false or misleading information is provided, required documentation is not supplied, regulatory obligations cannot be fulfilled, financial crime risks are unacceptable, or applicable laws require refusal.

14. Customer Responsibilities

Customers are responsible for providing complete and accurate information, supplying requested documentation promptly, informing the Bank of changes to personal or business information, cooperating with periodic KYC reviews, and responding to compliance requests within reasonable timeframes. Failure to cooperate may result in service restrictions.

15. Data Protection

All personal information collected through KYC procedures will be handled in accordance with the Bank's Privacy Policy and applicable data protection laws. Customer information will be protected using appropriate technical, administrative, and organizational safeguards.

16. Record Retention

KYC records will be securely retained for the period required by applicable law and regulatory obligations. Records may include identification documents, verification records, risk assessments, account opening forms, due diligence reports, transaction history, and correspondence relating to KYC reviews.

17. Employee Responsibilities

Employees responsible for customer onboarding must follow approved KYC procedures, verify customer information, escalate suspicious matters, maintain confidentiality, complete mandatory compliance training, and cooperate with internal audits. Failure to comply with this policy may result in disciplinary action.

18. Policy Review

This policy shall be reviewed annually, following changes in applicable laws, following regulatory guidance, following material operational changes, and following significant compliance incidents.

19. Contact Information

Compliance & Customer Due Diligence Department, SENTINEL PEAK BANK. Email: compliance@sentinelpeakbank.com. Telephone: +000 000 000 000. Business Hours: Monday - Friday, 8:00 AM - 5:00 PM.

Revision History

Version 1.0. Effective Date: 01 July 2026. Summary of Changes: Initial Release. Approved By: Board of Directors.

Document Control

Policy Number: VBS-POL-005. Version: 1.0. Document Status: Active. Effective Date: 01 July 2026. Last Reviewed: 26 June 2026. Next Scheduled Review: 01 July 2027. Approved By: Board of Directors. Policy Owner: Compliance & Customer Due Diligence Department. Copyright 2026 SENTINEL PEAK BANK. All Rights Reserved.