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KYC & AML Policy

Version 0.1.0-draft · Last updated

Capital pays performance fees to people. That makes us responsible for knowing who we are paying, for not paying anyone we are prohibited from paying, and for keeping a record that shows both. This page says how we do it.

Draft.

This policy is written to industry practice, not to a named regime. Which anti-money-laundering regime applies depends on the Company's country of incorporation and is not yet settled; counsel must confirm the obligations, thresholds, reporting channel and the Money Laundering Reporting Officer before launch — see docs/legal-review.md.

1. When verification happens

Identity verification is required before your first reward is paid. It is not required to buy a challenge or to trade, because until a reward is due no money moves toward you.

Verification is triggered earlier when:

  • you pass the final evaluation phase, so a funded account is about to be issued;
  • an automated risk check flags the account and a review is opened;
  • a sanctions or duplicate-identity match needs to be resolved.

After a final pass, you have 30 days to complete verification. We remind you as the deadline approaches. If it passes without a completed verification, the challenge is closed.

2. What we check

Through a specialist verification provider, we check:

  1. A government-issued identity document — that it is genuine, unexpired and belongs to you.
  2. A live selfie matched to the document, to confirm the document is yours and not a photo of someone else's.
  3. Your name and country as extracted from the document.
  4. Sanctions and watchlist screening of the verified name and date of birth.
  5. Duplicate identity — the same document used on more than one account, detected through a one-way hash of the document number. We never store the number itself.

You have 3 verification attempts. A declined attempt tells you why, where the provider gives a reason, and a resubmission at the provider's request does not consume an attempt. After the third attempt, verification moves to manual review by our compliance staff.

3. What happens with the result

| Result | Effect | | --------------------- | ---------------------------------------------------------------------------------------------------------- | | Approved | Your legal name is locked to the verified name, the funded account is provisioned, and rewards can be paid | | In review | Nothing is refused; a person is looking at it | | Resubmission required | You are asked for a clearer or different document; no attempt is consumed | | Declined | You may try again while attempts remain; after that, compliance reviews it manually |

An approved verification locks the legal name on your account. Changing it afterwards requires re-verification, because the name we pay must be the name we verified.

4. Geography

The country on your verified document must be a country we may serve, and it must match the country you declared at onboarding. A mismatch is not automatically fraud — people move — but it stops the payout until compliance has resolved it. The current list is on Restricted Countries.

5. Payments and payouts

  • Incoming. Program fees are taken by a payment provider. We do not accept cash, and we do not accept payment from a third party on your behalf.
  • Outgoing. Rewards are paid only to a payout method registered on your own account. A new payout method requires a one-time code sent to your email and cannot be used until a cooling-off period has passed, which is there to make an account takeover unprofitable.
  • We do not hold balances for you, we do not transfer value between users, and we do not process payments for anyone else. The platform is not a payment service.

6. Monitoring

Automated checks raise a risk flag for review when they see, for example: the same identity document on more than one account, coordinated trading between accounts, a payout destination shared across accounts, a chargeback, or a trading pattern matching the prohibited conduct in the Terms. A flag is a signal for a human to look, not a finding.

Every staff action on your account is written to an append-only audit log with who did it, when, and what changed.

7. Refusing and reporting

We may refuse to onboard you, refuse a payout, or close an account where we cannot verify your identity, where a sanctions match is confirmed, or where we have reasonable grounds to suspect money laundering or fraud. Where the law requires us to report a suspicion, we do so, and the law may prohibit us from telling you that we have.

8. Records

We keep verification decisions, the extracted identity fields, the document-number hash, payment and payout records and the audit log for the periods set out in the Privacy Policy, section 5 — 5 years after the relationship ends for verification data and 7 years for financial records.

9. Contact

Questions about verification, or about a decision that affects you: support@f8ware.com, or a ticket under Verification in the app.

Simulated trading only. No real funds are traded, held, or invested. Fees purchase an evaluation service; rewards are performance fees paid by the company.