Know Your Customer (KYC) Policy

1. Policy Overview

OZAMAPAY's Know Your Customer (KYC) Policy is designed to establish and maintain standards for identifying and verifying the identity of customers, beneficial owners, and other relevant parties. Our KYC procedures comply with international best practices, regulations in Haiti, the United States, and other jurisdictions where we operate. The objective is to prevent fraud, money laundering, terrorist financing, and other financial crimes while maintaining a secure platform for legitimate users.

2. Verification Fees

Identity verification (KYC) is required to access OZAMAPAY services. A fee of ~3,375 HTG applies.

3. KYC Process Overview

Our KYC process consists of three main phases:

• Customer Identification Program (CIP): Collecting and verifying customer identity
• Customer Due Diligence (CDD): Understanding customer background and transaction patterns
• Ongoing Monitoring: Continuous verification and monitoring of customer activities

4. Information Collection

During account opening, we collect the following information from all customers:

5. Identity Verification

We verify customer identity through a combination of methods:

• Document authentication using advanced image recognition technology
• Verification against national ID databases
• Biometric verification (facial recognition) where available
• Third-party verification services
• Manual review by compliance officers for high-risk cases

6. Beneficial Owner Identification

For business accounts, we identify and verify beneficial owners (individuals who directly or indirectly own 25% or more of the entity). This includes:

• Verification of company registration documents
• Identification of all beneficial owners
• Verification of beneficial owner identities
• Confirmation of beneficial ownership percentages
• Assessment of business legitimacy

7. Risk Assessment

We assign a risk level to each customer based on multiple factors:

• Geographic location and country risk
• Customer occupation and industry
• Source of funds legitimacy
• Transaction patterns and expected activity
• Beneficial owner information and PEP status
• Historical compliance with KYC requirements

8. Enhanced Due Diligence (EDD)

High-risk customers undergo Enhanced Due Diligence, which may include:

• Detailed source of wealth verification
• Business structure analysis
• Financial statement review
• Reference verification
• Enhanced ongoing transaction monitoring
• Politically Exposed Person (PEP) screening
• Adverse media screening

9. Ongoing Monitoring

We continuously monitor all customer accounts for suspicious activity:

• Real-time transaction monitoring
• Anomaly detection algorithms
• Behavioral pattern analysis
• Periodic customer information updates
• Re-screening against watchlists
• Annual compliance review

10. Record Retention

All KYC documents, verification records, and customer information are retained for a minimum of five (5) years after account closure or relationship termination, as required by law. Records are stored securely and protected from unauthorized access.

11. Account Activation

Accounts are only activated after successful completion of KYC verification. Customers may face account restrictions or suspension if:

• KYC verification cannot be completed
• Documents provided are fraudulent or invalid
• Customer is on sanctions or restricted lists
• Risk assessment indicates unacceptable risk level
• Customer refuses to provide required information

12. Privacy and Data Protection

All personal information collected during the KYC process is handled with strict confidentiality. We comply with data protection regulations and only use information for KYC, AML, and fraud prevention purposes. Customer data is protected with advanced encryption and security measures.