CRUCIAL MARKETS – KNOW YOUR CUSTOMER (KYC) POLICY
Approved By: Board of Directors
1. Purpose
This Know Your Customer (KYC) Policy establishes the standards and procedures that Crucial Markets (“the Company”) follows to:
Verify the identity of its customers
Assess and monitor customer risk
Prevent identity fraud, money laundering, terrorist financing, and other illicit activities
Ensure compliance with applicable AML/CTF and sanctions regulations
This Policy applies to all employees, officers, directors, and third-party service providers involved in client onboarding and monitoring.
2. Scope
KYC procedures apply to:
Retail individual clients
Corporate entities
Introducing Brokers (IBs)
Affiliates
Investment managers / PAMM operators
Any person or entity opening or controlling an account
No trading or withdrawals may occur until required KYC procedures are completed and approved.
3. Customer Identification Program (CIP)
3.1 Individuals
The Company shall collect and verify:
Full legal name
Date of birth
Residential address
Nationality
Phone number and email
Government-issued photo identification (passport, driver’s license, national ID)
Proof of address (utility bill, bank statement, or government letter dated within 90 days)
3.2 Corporate Entities
For legal entities, the Company shall obtain:
Legal name and registration number
Registered address
Certificate of incorporation
Memorandum & Articles of Association
List of directors
List of shareholders
Identification documents for directors and beneficial owners
Proof of business activity
4. Beneficial Ownership
The Company must identify and verify any individual who:
Owns 25% or more of the company (or lower threshold if required by regulation)
Exercises significant control over the entity
If the ownership structure is complex, enhanced documentation may be required.
5. Risk-Based Approach
Each customer shall be assigned a risk rating:
Low Risk
Retail client from low-risk jurisdiction
Simple ownership structure
Transparent source of funds
Medium Risk
Corporate entity
Higher deposit amounts
Cross-border transactions
High Risk
Politically Exposed Persons (PEPs)
High-risk or sanctioned jurisdictions
Complex ownership structures
Unusual trading or funding patterns
6. Enhanced Due Diligence (EDD)
EDD shall apply where heightened risk is identified, including:
Additional proof of source of funds or source of wealth
Bank statements (3–6 months)
Independent verification of business activity
Senior management approval
Increased ongoing monitoring
7. Source of Funds & Wealth
The Company may request documentation to verify:
Employment income
Business income
Investment income
Sale of assets
Inheritance
Other lawful sources
Large deposits inconsistent with the customer profile may require additional verification.
8. Sanctions & PEP Screening
All customers shall be screened against:
OFAC lists
UN sanctions lists
EU sanctions lists
Other relevant global watchlists
PEPs require:
Senior management approval
Source of wealth verification
Ongoing enhanced monitoring
9. Ongoing Monitoring
KYC is not a one-time process.
The Company will:
Monitor transactions for suspicious activity
Review accounts periodically based on risk rating
Re-verify identification when needed
Request updated documentation if circumstances change
10. Periodic Review
Customer files shall be reviewed:
High Risk: Annually
Medium Risk: Every 2–3 years
Low Risk: Every 3–5 years
Reviews may occur sooner if risk indicators arise.
11. Record Retention
All KYC records shall be maintained securely for a minimum of five to seven years after account closure, or longer if required by applicable law.
Records must be retrievable upon request by regulators.
12. Data Protection
Customer information shall:
Be stored securely
Be encrypted where possible
Be accessed only by authorized personnel
Be processed in accordance with applicable data protection laws
