KYC Policy

Last Updated: 26/11/2024

1. Introduction

ONE MEDIA SYSTEM LIMITED. Сompany number: EIN 77229081, Address: RM 8, S-V, 6/F VALIANT IND CTR 2-12 AU PUI WAN ST FO TAN HONG KONG (“Company” or “we” or “us”) is committed to preventing fraud, money laundering, and other illicit activities by establishing a robust Know Your Customer (“KYC”) program. This KYC Policy outlines our procedures and requirements for verifying the identity and legitimacy of our Clients to ensure compliance with applicable laws, regulations, and industry best practices.

2. Purpose

The purpose of this KYC Policy is to:

  1. Verify the identity and legitimacy of our Clients and their businesses.
  2. Ensure compliance with anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) regulations, as well as any other relevant laws in the jurisdictions in which we operate.
  3. Prevent fraud, illegal activities, and potential reputational damage.
  4. Maintain comprehensive records of due diligence documents and procedures.

3. Scope

This KYC Policy applies to all Clients (“Clients”), including individuals, corporations, partnerships, and any other form of legal entity that engages with the Company to use our marketing and advertising services. All employees, consultants, and agents acting on behalf of the Company must adhere to this Policy.

4. KYC Principles

  1. Customer Identification – We collect and verify relevant data to confirm the identity and legitimacy of the Client.
  2. Risk Assessment – We determine the Client’s risk profile based on factors such as geographic location, nature of business, ownership structure, and other relevant criteria.
  3. Ongoing Monitoring – We monitor Clients’ use of our services to ensure continued compliance with our KYC, AML, and CFT obligations.

5. Information Collected

To comply with applicable regulations, we require the following information and documentation from Clients. All data collected will be treated in accordance with our Privacy Policy and applicable data protection laws:

5.1 Corporate Entities

  1. Registered Company Name
  2. Trademark Used in Commercial Activities (if applicable)
  3. Date of Registration
  4. Registration Number
  5. Country of Incorporation
  6. Company Website
  7. Registered Address and Mailing Address (if different)
  8. Number of Years in Business and Countries of Operation
  9. Payment Method (e.g., credit card, bank transfer)

Directors and Ultimate Beneficial Owners (UBOs)

  1. List of Directors 
    • Passport Details, Date and Place of Birth
    • Copies of Their Passports (to be provided in a separate file)
  2. List of UBOs (shareholders with a specified percentage of ownership, typically 25% or more, or a threshold determined by local law) 
    • Ownership Percentage
    • Passport Details, Date and Place of Birth
    • Copies of Their Passports (to be provided in a separate file)

5.2 Contact Person

  • Name and Position
  • Relation to the Company
  • Contact Information (email, phone number)
  • Additional Information (if relevant for risk assessment or compliance checks)

6. Verification Procedures

  1. Collection of Documents: The Client must submit all required KYC documents and information.
  2. Document Review: The Company reviews the documents to verify accuracy, consistency, and legitimacy. This may include cross-checking official registration documents, passports, and other relevant data sources.
  3. Third-Party Verification: Where necessary or required by law, the Company may use reliable external databases or third-party service providers to verify the authenticity of documents and identities.
  4. Enhanced Due Diligence (EDD): If a Client presents a higher risk (e.g., operates in a high-risk jurisdiction), the Company may request additional information, including but not limited to financial statements, references, or supporting documentation on the source of funds.

7. Risk Assessment

  • Low-Risk Clients: Entities or individuals operating in jurisdictions with strong AML/CFT regulations, providing full and consistent documentation, and having a transparent ownership structure.
  • High-Risk Clients: Entities or individuals with opaque corporate structures, operating in high-risk countries, or appearing on public sanctions or watch lists. High-risk Clients may be subject to enhanced due diligence measures and ongoing monitoring.

8. Ongoing Monitoring and Review

  1. Periodic Updates: We may request updated information and documents from Clients periodically to ensure records remain accurate.
  2. Transaction Monitoring: We monitor Clients’ transactions or business activities conducted via our platform or services to detect suspicious patterns or anomalies.
  3. Reporting Obligations: If suspicious activity is identified, we may be required to report such activity to the relevant regulatory or law enforcement authorities in accordance with applicable laws.

9. Data Protection & Privacy

All personal data and documentation collected under this Policy will be handled in accordance with our Privacy Policy and applicable data protection laws (e.g., GDPR). We maintain strict security measures to prevent unauthorized access, disclosure, or misuse of Client data. Access to sensitive data is restricted to authorized personnel who require the information for compliance and verification purposes.

10. Record Keeping

  1. Document Retention: The Company maintains all KYC documents, transaction records, and related correspondence for at least the minimum period required by applicable law (commonly 5 years from the end of the business relationship).
  2. Confidentiality: We treat all Client information as confidential and will not disclose it to third parties except as required by law or with the Client’s explicit consent.

11. Employee Training

All employees and contractors involved in the client onboarding process receive regular training on KYC, AML, CFT, and data protection regulations. The Company strives to keep staff informed of the latest legal and regulatory requirements to ensure ongoing compliance.

12. Non-Compliance and Termination

  • If a Client fails to provide the required KYC documentation or if we suspect the Client is engaging in illegal or high-risk activities, we reserve the right to refuse to onboard, suspend, or terminate the Client’s access to our services.
  • Non-compliance with this KYC Policy or any applicable laws may also lead to termination of the business relationship.

13. Policy Updates

We may update or modify this Policy from time to time to reflect changes in legal, regulatory, or operational requirements. The updated Policy will be posted on our website with a revised “Last Updated” date. Clients are encouraged to review the Policy periodically to stay informed of any changes.

14. Contact Us

If you have any questions regarding this KYC Policy or require additional information, please contact: info@onemediasystem.com