KNOW YOUR CUSTOMER (KYC) POLICY

1. LEGAL BASIS AND POLICY OBJECTIVES

The KYC Policy outlines the Company’s obligations regarding customer identity verification in accordance with Romanian Law No. 129/2019, the regulations of the Romanian Financial Supervisory Authority (ASF), and relevant EU directives.

AFACERI INTERNATIONALE S.R.L. implements the KYC Policy to identify clients and ultimate beneficial owners (UBOs), assess business reputation, and verify the legality of the origin of assets or funds handled by the company. The policy also aims to prevent fraud, terrorism financing, and other financial misconduct.

2. CUSTOMER IDENTIFICATION

AFACERI INTERNATIONALE S.R.L. conducts comprehensive client identification both prior to and throughout the business relationship.

For individuals: collection of personal information (full name, date of birth, nationality), document verification, screening against sanctions lists, PEP (Politically Exposed Person) status check, and analysis of income sources.

For legal entities: verification of incorporation documents, ownership structure, UBOs, registration in the national beneficial ownership register (in accordance with Article 19 of Law No. 129/2019), and verification of the legality of fund sources.

3. MONITORING THE CLIENT RELATIONSHIP AND BUSINESS PURPOSE

AFACERI INTERNATIONALE S.R.L. is obligated to:

• determine the commercial intent of the client at the start of the relationship (e.g. investment strategy, business optimization, HR projects);
• understand the expected transaction volumes;
• clarify the client’s funding sources;
• perform regular assessments of existing clients;
• review available information in case of any changes or risks identified during the relationship.

4. ENSURING THE RELIABILITY OF CLIENT DATA

KYC is not a one-time process. AFACERI INTERNATIONALE S.R.L. ensures:

• regular updates of client information;
• continuous screening against sanctions lists (EU, OFAC, UN);
• re-identification in the event of changes in ownership or risk profiles.

5. DATA PROTECTION

All information is processed in accordance with Regulation (EU) 2016/679 (GDPR) and Romanian Law No. 190/2018 on implementing measures related to GDPR.