Tier 1: Basic KYC
(Up to ¥2,000,000 Per Day)

1. Registration & Identity Capture

• Personal Details:
  • Full Legal Name, including middle name if applicable. [FSA Rule]
  • Complete Residential Address with postal code. [FSA Rule]
  • Nationality based on official ID. [FSA Rule]
  • Date of Birth and Gender. [FSA Rule]
  • Valid Email Address for account verification.
  • Mobile phone number for two-factor authentication. [FSA Practice]
• Email Verification:
  • Send verification link to complete registration.
  • Account access only enabled after email confirmation.

2. Account Activation & Security

• Dashboard Access:
  • User sees transaction summary, KYC status, and secure QR code. [FSA Practice]
• QR Code Issuance:
  • Dynamic, time-sensitive code for use during every exchange. [FSA Practice]
• Facial Snapshot:
  • Live photo captured at each transaction. Used to verify account holder. [Internal Policy]

3. Transaction Rules & Limits

• Daily Limit: Up to ¥2,000,000. [FSA Rule]
• Automated Monitoring:
  • Tracks daily totals and blocks transactions over the limit. [FSA Practice]
  • Alerts user when they are nearing the threshold.

4. Compliance & Retention

• User data, logs, and photos retained for 7 years. [FSA Regulation]

Tier 2: Enhanced KYC
(For transactions exceeding ¥2,000,000/day or  under ¥5,000,000/week)

1. Trigger & Customer Notification

• Trigger Conditions:
  • Single-day exchange exceeds ¥2,000,000 or weekly exchange exceeds ¥5,000,000. [FSA Rule]
  • Detected irregular activity, flagged manually. [FSA Practice]
• Notification:
  • Automated email and on-screen message guiding customer to complete Tier 2 KYC.

2. ID Verification

• Photo ID Submission:
  • Valid government-issued ID (passport, residence card, driver’s license). [FSA Rule]
  • Clear image with all fields readable.
• Live Selfie Verification:
  • Real-time image capture matched to ID photo. [FSA Practice]
  • Includes liveness detection and posture verification.

3. Blacklist & Sanctions Screening

• Database Checks:
  • Scanned against local and international watchlists. [FSA Requirement]
  • Any matches escalate to internal compliance for review.

4. Result & Access

• Verification Outcome:
  • Upon success, user notified and transaction limits lifted.
  • If denied, instructions for retry or document clarification are provided.

5. Recordkeeping (FSA Regulation)

• All ID records, video capture, and match logs stored securely for 7 years.

Tier 3: High-Value KYC
(For transactions exceeding ¥5,000,000/week or ¥10,000,000/month)

1. Trigger & Notification

• Trigger Conditions:
  • Triggered automatically when customer transactions exceed thresholds. [FSA Rule]
  • Manually triggered by compliance staff if risk indicators or patterns are observed. [FSA Practice]
• Customer Notification:
  • Customer receives a system-generated alert with instructions. [FSA Practice]

2. Required Documentation (Required by FSA)

• Bank Statements:
  • Minimum of 3 months of original bank statements. [FSA Rule]
  • 6 months may be requested based on transaction volume or inconsistencies. [Internal Policy]
  • Statements must include full name, account details, and visible transaction records.
• Source of Funds Proof:
  • Salary slips, tax returns, pension summaries, or business earnings reports. [FSA Rule]
  • Documents must align with transaction values and be from a verifiable source.

3. Enhanced Identity Match

• Live Facial Recognition:
  • Customer takes a real-time selfie matched with prior biometric records. [FSA Practice]
  • Liveness detection required to prevent spoofing attempts. [FSA Practice]

4. Internal Review Process

• Compliance Officer Review:
  • All submitted documents and biometrics are reviewed by certified in-house staff. [FSA Practice]
  • FSA does not directly approve accounts, but our review must be compliant with their inspection standards. [FSA Compliance Requirement]
  • Any issues or mismatches may result in manual verification steps or a Suspicious Transaction Report (STR). [FSA Rule]

5. Final Outcome & Next Steps

• Approval:
  • Access granted to Tier 3 transactions upon document approval.
  • Customer notified via dashboard and email.
• Rejection:
  • Specific guidance given for corrections or re-submission.
  • Account may be temporarily frozen until resolution.

6. Recordkeeping & Legal Retention (FSA Regulation)

• All documents, photos, and logs stored for 7 years in encrypted systems.
• Access logs and internal notes retained for audit trail purposes. [FSA Regulation]

Tier 4: Corporate & PEP KYC
(Required for businesses and individuals with public exposure)

1. Trigger & Eligibility

• Trigger Conditions:
  • Account registered under a company name or legal entity. [FSA Rule]
  • Customer or Ultimate Beneficial Owner (UBO) is identified as a Politically Exposed Person (PEP). [FSA Rule]
  • Manually triggered if business activity is deemed high risk. [FSA Practice]
• Customer Notification:
  • Email and dashboard notification outlining all additional documentation requirements.

2. Corporate Documentation Requirements (FSA Required)

• Company Registration Documents:
  • Certificate of Incorporation or Tokibo Tohon. [FSA Rule]
  • Articles of Association or company bylaws. [FSA Rule]
  • Recent tax documents or corporate registration renewal. [FSA Practice]
• Authorized Representative Verification:
  • Government-issued ID of the representative. [FSA Rule]
  • Board resolution or power of attorney authorizing the individual to act on behalf of the company. [FSA Practice]
• Corporate Bank Account:
  • Last 3 months of corporate bank statements. [FSA Rule]
  • Statements must match registered company details and show operational activity.

3. UBO & PEP Declarations (FSA Rule)

• UBO (Ultimate Beneficial Owner) Identification:
  • Identification of all individuals holding 25% or more of ownership. [FSA Rule]
  • ID verification of each UBO. [FSA Rule]
• PEP Screening:
  • Automated screening against global PEP and sanctions databases. [FSA Requirement]
  • Flagged matches must be escalated for Enhanced Due Diligence (EDD). [FSA Practice]

4. Manual Compliance Review

• Verification & Risk Assessment:
  • All corporate, UBO, and PEP documentation is reviewed by our internal compliance team. [FSA Practice]
  • Risk-based approach applied to high-risk jurisdictions or politically linked individuals. [FSA Guideline]
• Decision & Follow-Up:
  • If approved, account is cleared for corporate use and Tier 4 limits apply.
  • If rejected, customer is informed with reasons and possible remedial actions.

5. Recordkeeping & Retention (FSA Regulation)

• All files (ID, documents, correspondence, screening logs) must be stored securely for at least 7 years. [FSA Regulation]
• Data must be available upon request for FSA audits or regulatory inspection.

6. Ongoing Monitoring & Annual Review

• PEP-linked and corporate accounts are monitored continuously for abnormal activity. [FSA Rule]
• Annual review of company ownership, financial health, and document freshness. [FSA Practice]
• All alerts or suspicious findings are escalated immediately to the compliance officer and may result in an STR (Suspicious Transaction Report). [FSA Rule]

How We Secure Your Data

All sensitive customer KYC data is securely stored on encrypted servers, ensuring compliance with global security standards.

Our own database only stores minimal reference data to track transactions and compliance triggers, reducing security risks.