Customer Onboarding

Introduction:

This document outlines the comprehensive procedure for new customer onboarding, crucial for establishing a Business Relationship. This process is integral when the GSI-Group is mandated to conduct Customer Due Diligence (CDD) as per our Anti-Money Laundering (AML) Policy. Customers and their representatives will undergo a series of identification procedures, primarily conducted online, with Enhanced Due Diligence (EDD) measures applied as necessary. Any discrepancies or suspicious details identified during the onboarding process are immediately reported to the Compliance Officer, potentially delaying the process pending further directives.

Customer’s Remote Onboarding Process:

Account Creation:

The Customer's representative initiates by setting up an account on the GSI-Group’s platform, establishing login credentials with an email and password.

Email Verification:

A verification link is sent to the representative's email, which they must click to verify their email address.

Account Verification:

The representative logs into their account on the GSI-Group’s platform and proceeds to the account verification section.

Sum&Substance Software Procedures:

• Consent and Documentation: The representative consents to the processing of personal data and captures real-time photos of their identity document and a selfie for facial verification.

• Address Verification: Proof of address documents are uploaded, and device ID along with IP address data are collected by the software.

• Sum&Substance Verification: The software conducts checks against watchlists, verifies the authenticity of the identity document, and cross-references the data against various databases.

• Verification Outcome: Failures in verification alerts the KYC agent via the Sum&Substance dashboard.

Data Submission:

Comprehensive information and necessary documents are submitted via the GSI-Group’s platform by the Customer's representative, including business specifics, legal documents, financial statements, and information on beneficial owners.

Manual Verification:

A KYC Agent reviews Customer data and documents against official records and the submitted information, including a review of beneficiary lists.

UBO Verification:

In instances where the Ultimate Beneficial Owner (UBO) is not the representative, the KYC Agent processes the applicant through the Sum&Substance system for the necessary checks.

Risk Assessment:

Following verification, the KYC Agent assesses the Customer's risk level within the GSI-Group’s system and determines any requisite follow-up actions.

Notification of Successful Onboarding:

Upon completing the onboarding process successfully, the Customer's representative receives notification via email and through the platform interface, thus enabling them to commence transactional activities.

Document and Data Submission Guidelines:

Specific documents and data submissions may be deemed unacceptable under certain conditions, including:

• Registry Cards or Registration Certificates that are invalid, damaged, manipulated, or otherwise questionable in authenticity or compliance.

• Real-Time Photos of the Customer’s Representative (Selfie) that are unclear, not taken in real-time, show multiple individuals, or raise objections from the Customer.

• Identity documents that are damaged, forged, or otherwise suspicious, necessitating further investigation for potential reporting to the Financial Crimes Investigation Service after a comprehensive evaluation of ML or TF risks.

This detailed onboarding procedure underscores the GSI-Group's commitment to compliance, security, and integrity in establishing business relationships, ensuring a secure and professional engagement for all parties involved.