KYC / AML policy

1. Purpose

This Know Your Customer (KYC) Policy outlines the procedures and principles adopted by Telecom Apps LLC to ensure compliance with international regulations and best practices for verifying the identity of clients and mitigating risks related to money laundering, terrorist financing (CFT), fraud, sanctions violations, and other illicit activities. This policy is tailored to our operations in the software development industry and reflects our commitment to ethical business practices.

2. Scope

This policy applies to all clients and users of Telecom Apps LLC's online platform accessible on the website https://kleos.io/. It encompasses procedures for client identification, verification, and ongoing monitoring to ensure compliance with applicable laws and regulations.

3. Regulatory Compliance

This policy is informed by international standards, including FATF (Financial Action Task Force) guidelines, the EU's AMLD (Anti-Money Laundering Directives), OFAC sanctions framework, UK Sanctions and Anti-Money Laundering Regulations and other applicable international compliance standards.

4. Client Identification and Verification

4.1. Collection of Information

The following information is collected from each client:

• Full name
• Date of birth
• Nationality
• Residential address
• Country of tax residence
• TIN (Tax Identification Number)
• Government-issued identification document (e.g., passport, national ID, driver's license)
• Company documents (extract from the registry, certificates of incorporation, proof of business address, shareholders agreement, UBOs, authorized representative information)

4.2. Verification Process

Client verification is conducted using SumSub (https://sumsub.com/), a third-party verification provider. SumSub ensures the authenticity of documents and matches client information against reliable data sources.

4.3. Exclusions

Telecom Apps LLC does not engage clients or partners listed in any international sanctions databases (IFAC SDN List; EU Sanctions List, UK HMT, UK Security Council List, PEP database or those identified as high-risk by SumSub's (https://sumsub.com/) risk assessment tools or by internal checks of clients corporate documents, performed by AMLCO (AML Compliance Officer).

5. Risk-Based Approach

Telecom Apps LLC employs a risk-based approach to KYC, which involves: assigning risk ratings to clients based on geographic location, activity patterns, and other risk factors. Applying enhanced due diligence (EDD) for clients flagged as medium or high risk.

6. Ongoing Monitoring

6.1. Transaction Monitoring

Telecom Apps LLC actively monitors transactions to identify suspicious behavior, abnormal payment patterns, unusual geographic behavior, attempts to bypass platform controls, potential sanctions exposure on the platform.

6.2. Periodic Reviews

Client information is reviewed continuously and updated regularly to ensure compliance with KYC requirements. AMLCO (AML Compliance Officer) is responsible for oversight of KYC procedures.

7. Data Privacy and Security

All client data collected during the KYC process is handled in compliance with applicable data protection laws, including GDPR. Telecom Apps LLC ensures the secure storage and transmission of client data through encrypted systems.

8. Reporting Obligations

Telecom Apps LLC is committed to filing Suspicious Activity Reports (SARs) with relevant authorities when required.

9. Employee Training

All employees involved in KYC and AML/CFT processes undergo regular training to stay updated on compliance requirements and best practices.

Telecom Apps LLC is an active member of https://www.int-comp.org/ and on a quarter basis runs training courses for its employees that are engaged with clients including ICA certification of such employees.

This is mandatory, that all client relations managers and sales managers will complete KYC / AML training before starting their jobs duties.

AMLCO (AML Compliance Officer) is responsible for annual checks of the employer's knowledge on AML / KYC and CFT policies and provides reports to the shareholders.

10. Policy Review and Updates

This policy is reviewed annually or when significant regulatory changes occur. Updates are communicated to all relevant stakeholders.

11. Contact Information

For questions related to this policy, please contact AML Compliance Officer:

Mindaugas Mirskij
compliance@kleos.io
United States, CA. Redwood City, 303 Twin Dolphin Drive
Suite 800