Know Your Customer (KYC) Policy

Operating under OPDuel

Effective date: September 30, 2025

Approved by: OPDuel

Introduction and Purpose

This Know Your Customer (KYC) Policy outlines the procedures and controls implemented by https://opduel.com operating under OPDuel a limited liability company registered under the laws of Nevis, and having its registered address at Unit 207, Heritage Plaza II, Main Street (collectively referred to as "the Company "), to verify the identity of customers, assess risks associated with money laundering, terrorist financing, and other illicit activities, and ensure compliance with applicable laws and regulations.

ARTICLE 1: PRIMARY OBJECTIVES

The primary objectives of this Policy are to:

Prevent and detect financial crimes in accordance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) requirements.
Establish a robust framework for customer onboarding, verification, and ongoing monitoring.
Protect the integrity of the Company's operations as a provider of cryptocurrency exchange and related financial services.
Foster transparency and trust with customers, regulators, and stakeholders.

This Policy is aligned with international standards, including those from the Financial Action Task Force (FATF), and relevant jurisdictions such as the United States (under FinCEN guidelines), European Union (under 5AMLD/6AMLD), and other applicable regions where the Company operates.

ARTICLE 2: SCOPE

This Policy applies to all customers of https://opduel.com, including individuals, legal entities, and beneficial owners, who engage in services such as cryptocurrency trading, wallet management, or fiat-to-crypto conversions. It covers:

All employees, contractors, and third-party service providers involved in customer onboarding and compliance.
All stages of the customer lifecycle, from initial registration to account closure.
Global operations, with adaptations for local regulatory requirements where necessary.

Exclusions: This Policy does not apply to internal employees or non-customer interactions unless specified.

ARTICLE 3: DEFINITIONS

Customer: Any individual or entity that registers for or uses https://opduel.com services.
Beneficial Owner: The natural person(s) who ultimately owns or controls a customer (e.g., >25% ownership in a legal entity).
KYC Verification:The process of identifying and verifying customer identity using reliable, independent sources.
Enhanced Due Diligence (EDD): Additional scrutiny for high-risk customers, including source of funds/wealth verification.
Politically Exposed Person (PEP): Individuals entrusted with prominent public functions, their family, or close associates.
Sanctioned Entity: Any customer or transaction subject to sanctions lists (e.g., OFAC, UN, EU).

ARTICLE 4: RESPONSIBILITIES

Board of Directors: Oversees the implementation and effectiveness of this Policy.
Compliance Officer: Leads KYC program development, training, and reporting; conducts annual audits.
Customer Onboarding Team: Performs initial KYC checks and escalates high-risk cases.
Risk Management Team: Conducts risk assessments and ongoing monitoring.
All Employees: Report suspicious activities and adhere to training requirements.
Third-Party Providers: Must comply with equivalent KYC standards under contractual agreements.

ARTICLE 5: VERIFICATION AND RISK ASSESSMENT

Verification Process

Registration:Customers submit details via the https://opduel.com platform (name, DOB, address, etc.).
Document Submission: Upload via secure portal; automated AI checks for authenticity (e.g., facial recognition, document tampering detection).
Manual Review: For Standard/EDD, the compliance team reviews within 48 hours.
Approval/Rejection: Successful verifications grant access; rejections include appeal rights with reasons provided.
Biometric Integration: Optional facial recognition for ongoing logins to prevent account takeover.

All documents must be current, legible, and from reliable sources. The Company uses encrypted storage and AI tools for efficiency.

ARTICLE 6: RISK ASSESSMENT

6.1 Customer Risk Scoring

Customers are scored on a scale of Low (1-3), Medium (4-6), or High (7-10) based on:

Geographic Risk: High-risk countries (e.g., FATF grey/black lists).
Customer Type: PEPs, high-net-worth individuals, or entities in high-risk industries (e.g., gambling, crypto mining).
Transaction Patterns: Unusual volume, frequency, or peer-to-peer transfers.
Adverse Media: Screening against global databases for sanctions, watchlists, or negative news.

6.2 Initial and Ongoing Risk Review

Initial assessment at onboarding. Annual re-assessment for all customers; quarterly for High-risk. Automated alerts for risk score changes trigger re-verification.

ARTICLE 7: ONGOING MONITORING AND DUE DILIGENCE

7.1 Transaction Monitoring

Real-time AI-driven surveillance for suspicious patterns (e.g., structuring, rapid in/out flows). Thresholds: Alerts for >$10,000 single transaction or cumulative >$50,000/week.

7.2 Periodic Reviews

Random audits (10% of accounts quarterly); full reviews for High-risk customers.

7.3 Suspicious Activity Reporting (SAR)

Immediate escalation to the Compliance Officer; filing with relevant authorities (e.g., FinCEN) within 30 days if warranted.

7.4 Account Freezing

Temporary holds on suspicious accounts pending investigation.

ARTICLE 8: DATA PROTECTION AND PRIVACY

8.1 Data Privacy

The Company processes KYC data in compliance with GDPR, CCPA, and other data protection laws:

Data is collected only for KYC/AML purposes and retained for 5 years post-relationship (or longer if required by law).
Secure storage with encryption (AES-256); access limited to authorized personnel.
Customer rights: Access, rectification, erasure (subject to legal holds), and consent withdrawal.
Breach Notification: Within 72 hours to regulators and affected customers.

ARTICLE 9: TRAINING AND AWARENESS

Mandatory annual training for all relevant staff on KYC/AML topics. Regular simulations of suspicious activity scenarios. Updates disseminated via internal communications upon Policy revisions.

ARTICLE 10: NON-COMPLIANCE AND ENFORCEMENT

Violations (e.g., bypassing verification) result in account suspension, termination, or legal action. Whistleblower protections for reporting issues. External audits by independent firms annually.

ARTICLE 11: POLICY REVIEW AND UPDATES

This Policy will be reviewed annually or upon material regulatory changes. Version 1.0 supersedes any prior guidelines. Amendments require Compliance Officer approval and Board ratification.

For questions, contact [email protected]