Know Your Customer (KYC) Policy

1. Legal Basis and Policy Objectives

This KYC Policy is established in accordance with:

1. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended);
2. The Proceeds of Crime Act 2002;
3. The Terrorism Act 2000;
4. The Terrorism Act 2000;
5. International standards set by the Financial Action Task Force (FATF).

The purpose of this Policy is to verify the identity of clients and ultimate beneficial owners (UBOs), assess reputational and financial risk, and ensure the lawful origin of funds. It also aims to prevent fraud, terrorism financing, and misuse of digital privacy services.

2. Customer Identification

VALLORON LIMITED conducts thorough identity checks before and during the client relationship.

For individuals:

1. Full name, date of birth, nationality;
2. Verification of identity documents;
3. Screening against UK and international sanctions lists;
4. Politically Exposed Person (PEP) status check;
5. Assessment of income sources and digital risk profile.

For legal entities:

1. Verification of incorporation and registration documents;
2. Identification of ownership structure and UBOs;
3. Review of funding sources and business activities;
4. Confirmation of registration in the UK’s People with Significant Control (PSC) register.

3. Monitoring the Client Relationship and Business Purpose

3. Monitoring the Client Relationship and Business Purpose

1. Understanding the client’s intent (e.g., digital footprint reduction, secure communications, network protection)
2. Assessing expected service usage and data volumes;
3. Clarifying the origin of funds used for services;
4. Conducting periodic reviews of existing clients;
5. Re-evaluating client data upon changes in risk profile or ownership.

4. Ensuring the Reliability of Client Data

KYC is an ongoing process. VALLORON LIMITED ensures:

1. Regular updates of client records;
2. Continuous screening against sanctions lists (UK, EU, OFAC, UN);
3. Re-identification in case of material changes in client status or risk.

5. Data Protection

All personal data is processed in accordance with:

1. The UK General Data Protection Regulation (UK GDPR);
2. The Data Protection Act 2018;
3. Principles of confidentiality, integrity, and lawful processing.