KYC AML Policy
The objective of Revenue Capital’s KYC (Know Your Customer) procedures is to prevent the company from being used, intentionally or unintentionally, by criminal elements for money laundering and terrorist financing activities. KYC procedures also enable us to know our clients and their financial dealings better which in turn help us manage the risks prudently.
In full consideration of the international recommendations, the requirements of the National Bank of Georgia and the Financial Monitoring Service of Georgia, Revenue Capital has established internal KYC procedures to combat money laundering and terrorist financing.
Revenue Capital’s KYC Process serves to build a complete client’s KYC Profile. KYC Process is made up of Client Due Diligence (CDD) and related activities according to established procedures and client’s risk level.
Identification and verification of the client
CDD’s major part is identification and verification which involve:
the collection of specific information about the client, including its ownership and key principals (identification); and
gathering evidence from reliable sources that verifies the accuracy of the information collected (verification).
During the implementation of the preventive measures prescribed by the relevant laws, Revenue Capital studies the transaction prepared, concluded and/or executed within the framework of the business relationship in order to determine whether it corresponds to the information about the client known to it, the client's commercial or professional activity and the client's risk level, and, if necessary - the client's property, cash and the origin of the convertible virtual asset, as well as ensures that identification data and other information (document) obtained by implementing preventive measures are updated with appropriate periodicity.
The preventive measures prescribed by the relevant laws and our procedures are carried out in the following cases:
when establishing a business relationship;
when making a one-time transaction, if the amount of a single transaction or the total amount of related transactions exceeds 15,000 GEL or the equivalent of 15,000 GEL in foreign currency, and in the case of concluding a one-time transaction related to the service of a convertible virtual asset - 1,000 US dollars, 1,000 EUR or 3 000 GEL;
when there is one-time transfer of funds, if the amount of one-time transaction or the total amount of related transactions exceeds 3,000 GEL or the equivalent of 3,000 GEL in foreign currency;
when we are doubting the accuracy of the identification data obtained by the implementation of preventive measures defined in our procedures or their compliance with the requirements of the relevant laws in force;
when there is a suspicion of money laundering or terrorist financing.
Revenue Capital implements the preventive measures described in its KYC procedures in accordance with the client's risk level before concluding a one-time transaction and establishing a business relationship, as well as with appropriate periodicity - during the course of the business relationship and when the essential circumstances related to the client change.
Identification of a natural person and his/her representative consists in obtaining the following information:
first name/last name;
personal number (if exists);
date of birth;
place of birth - country (also city - if such data exists);
ID card and/or another citizenship document number, date of issue, issuing country, issuing body and validity period;
residing address; and
Information to be obtained for a natural person client legitimately residing in the Autonomous Republic of Abkhazia and Tskhinvali Region (former South Ossetia Autonomous District) are:
first name/last name;
date of birth;
place of birth – country (also city – if such data exists);
neutral certificate or neutral travel document number, date of issue, issuing country, issuing body and validity period (if such document exists);
Information to be obtained for a Georgian natural person Individual Entrepreneur client are:
all information defined above for the identification of natural persons;
taxpayer identification number;
registered address; and
date of registration.
Revenue Capital carries out the verification of a natural person on the basis of the following documents:
a passport, identity card or driver's license of a citizen of Georgia, or a certificate of a compatriot living abroad;
in case of a person living legitimately in the Autonomous Republic of Abkhazia and the Tskhinvali region (in the former South Ossetian Autonomous District) - a neutral identity card or a neutral travel document;
in case of a citizen of a foreign country – a residence certificate issued by the State Services Development Agency, a temporary identification certificate issued by the State Services Development Agency, a passport, another document permitted for crossing the customs border of Georgia based on an international agreement and/or by Georgian legislation, or a certificate of a compatriot living abroad;
in the case of a stateless person - a residence certificate issued by the State Services Development Agency, a temporary identification card or a travel passport issued by the State Services Development Agency;
in the case of an individual entrepreneur - a document provided for in subsection "a"-"d" hereof and an extract from the register of entrepreneurs and non-entrepreneurial legal entities of the National Public Registry Agency;
in the case of a person who has not reached the age of 14 - a document provided for in subsection "a"-"d" hereof or birth certificate.
Identification of a legal person and an organization unit without legal personality consists in obtaining the following information:
full legal name;
an excerpt from the relevant register specifying the rules of client representation;
registration number (if exists);
tax identification number/registration number/Tax ID;
data of persons representing the legal entity; and
registered and operating addresses - if mailing address is other than registered/operating one.
We obtain the following identification data of the person(s) with management and representative authority of the client legal entity (except a person acting on behalf of the client):
in case of a natural person - at least his/her name, surname and personal number (in the absence of such - date of birth or identity and/or citizenship document number) or all identification data for a natural person provided in the internal procedures;
in case of a legal entity – name and identification or registration number (if any). In the absence of an identification or registration number - one of the following: registration date, legal address, legal form, or address of physical location.
If client is a branch of a legal entity, shall be additionally obtained the identification data of the client's head enterprise (organization) and its management and representative authority(ies) provided above.
We verify the client legal entity and the person(s) with management and representative authority on the basis of the following document:
in case of a legal entity registered in Georgia - extract from the register of entrepreneurs and non-entrepreneurial legal entities of the National Public Registry Agency;
in case of a legal entity registered in another jurisdiction – an extract from the relevant register of legal entities and/or another document confirming the registration and existence of the legal entity issued by the registering authority.
In case of the existence of a trust or a legal structure similar to a trust, the preventive measures defined in our procedures will be implemented against the following persons or persons in an equivalent position:
issuer of representative authority;
guardian (if any);
another natural person who exercises effective ultimate control over the trust or a legal structure similar to a trust (if any).
When necessary, Revenue Capital obtains the following identification data for the purpose of identification of the beneficial owner:
name and surname;
date of birth;
personal number (if any); and
ID and/or citizenship document number in the absence of the personal number.
If certain cases, Revenue Capital may be entitled to additionally obtain other identification data of the beneficial owner, including:
place of birth (city, country);
ID and/or citizenship document number, date of issue, issuing country, issuing body and validity period of the document; and
address of registration and/or actual residence.
Screening is conducted as part of the CDD process to identify additional risk factors that may:
elevate a client’s Financial Crime Risk Rating (FCRR) to High (e.g. identification of a Politically Exposed Person (PEP));
prohibit or restrict entering into a business relationship with the client (e.g. the client is subject to international embargoes or sanctions regimes); or
influence the client’s acceptability to Revenue Capital (e.g. material adverse information).
The three types of screening required for a client, including its Ultimate Beneficial Owners (UBO) and key principals, are as follows:
PEP screening: to determine whether the client, or individuals connected to the client, meet the definition of a PEP;
Sanctions screening: to determine whether the client, or individuals or entities connected to the client are subject to international embargoes or sanctions regimes;
Adverse information screening: to identify potentially adverse information regarding the client, or individuals or entities connected to the client.
Evidence of the screening undertaken and the results are maintained with the KYC Profile to provide a record of the screening conducted.
What individuals or entities require screening?
In general, the following individuals or entities require screening:
the client, and all UBOs and key principals relating to that client, who have been identified as part of the CDD requirements, are required to be screened for sanctions and adverse information; and
all clients that are natural persons, and UBOs and key principals, who have been identified as part of the CDD requirements (who are natural persons), are required to be screened for PEPs.
Steps to be taken where the CDD process identifies additional high risk factors
During the course of the CDD or screening process, additional high risk factors may arise as a result of identifying:
that the client, or an individual connected to the client, meets the definition of a PEP;
that the client, or an individual or entity connected to the client, is subject to economic sanctions;
that the client or the engagement is connected to countries subject to comprehensive sanctions or to sectoral or economic sanctions;
adverse information in relation to the client, or an individual or entity connected to the client;
The steps to be taken will be different depending on the nature of the high risk factor identified.
Revenue Capital retains completed KYC Profiles (including the information and documentation contained therein) for 5 (five) years after the date of expiry of the KYC Profile validity period.