KYC/KYB Policy

1. Purpose and scope

This KYC/KYB Policy describes how Omicron Gama S.A. ("Omicron Gama", "we", "us") identifies and verifies its customers before and during a business relationship. It is designed to help prevent money laundering, terrorist financing, sanctions evasion, fraud and other financial crime. This policy is an integral part of Omicron Gama's Terms and Conditions and should be read together with the AML Policy.

This policy applies to every customer. Individuals acting for business purposes complete the KYC (Know Your Customer) process; companies and other legal entities complete the KYB (Know Your Business) process.

2. Due diligence measures

In accordance with applicable law, the FATF Recommendations and our AML Policy, our due diligence measures include:

• Identification and verification of the customer.
• Identification of the beneficial owners.
• Verification of the company and of its directors and authorized representatives.
• Understanding the purpose and intended nature of the business relationship.
• Gathering information on whether a person is a politically exposed person, or a family member or close associate of a politically exposed person.
• Sanctions screening.
• Ongoing monitoring of the business relationship.

3. Individual customers (KYC)

We may require the following information: first name, last name, date of birth, identity document number, taxpayer identification number (RUC, for Paraguay), telephone number, residential address, email address and any other document we consider necessary for identification.

Proof of identity. A valid government-issued photo ID, such as a passport, national identity card (for example, the Paraguayan cédula de identidad) or driving license. The entire document must be provided in color and show the full name, ID number, photo, signature and expiry date, with at least six (6) months of remaining validity.

Proof of address. A utility bill (water, electricity, gas, internet or landline telephone) or a bank statement showing the full name, physical address, issue date and the name of the utility company or bank, issued within the last three (3) months before submission.

4. Business customers (KYB)

For companies and other legal entities, we may require:

• Legal name, trade name, registration number, date and jurisdiction of incorporation, and registered and operating addresses.
• Incorporation documents and evidence of good standing or equivalent registry extracts.
• Tax identification number (RUC, for Paraguayan companies).
• Ownership structure and identification of the ultimate beneficial owners.
• Identification of directors and authorized representatives, and evidence of their authority to act on behalf of the company.
• A description of the business activity, the intended use of the products and the expected volume of activity.

Beneficial owners, directors and authorized representatives may be required to complete identity verification as described in sections 3 and 5.

5. Identity verification

We verify identities through Veriff, a third-party identity verification provider. Verification may include document verification and selfie, liveness or short-video checks, and may also be carried out through a video call. Verification may take place during onboarding or before or after a transaction.

Submitted documents must be valid. If documents are written in non-Latin characters, we may request a certified translation into Spanish or English. We may also request certified, notarized or apostilled copies at the customer's expense. Customers must keep us informed if any information or document they provided changes.

6. Financial information and source of funds

We may request financial information, such as bank details, bank statements and information on the source of funds or wealth, and ask the customer to complete a questionnaire about the purpose of the business relationship.

7. Third-party inquiries

To carry out verification and background checks in accordance with our AML Policy, we may make inquiries, directly or through third-party service providers, to verify identity and to prevent fraud, misidentification, money laundering or other prohibited activity. The customer acknowledges that personal information may be shared with these providers for that purpose, as described in our Privacy Policy. We may take the actions we consider necessary based on the results of these inquiries.

8. Ongoing due diligence and monitoring

We may verify identity on an ongoing basis, including when identification information changes or when activity appears unusual. We may request up-to-date documents even if the customer has passed verification before.

We monitor customer activity. Unusual activity is reviewed and escalated internally when appropriate, and additional controls are applied when the risk requires it.

9. Limits and access levels

Limits and access levels are set according to each customer's verification level, risk profile and type of access, and may be modified as the relationship develops.

10. Refusal, suspension and termination

We may refuse to start a business relationship, request additional information, or suspend or terminate access when a customer does not provide the requested information or documents, when the information provided is false or inconsistent, or when we suspect involvement in unlawful activity.

11. Cooperation with competent authorities

Where required by applicable law, Omicron Gama cooperates with competent authorities and may provide information in response to valid legal requests.

12. Record keeping

We keep the information and documents obtained for identification purposes, and the related transaction records, for at least five (5) years after the end of the business relationship, or longer where required by law.

13. Changes and contact

We may update this policy to reflect changes in our processes or in applicable law. The English version is the master version and prevails in the event of any inconsistency. For questions about this policy or about the onboarding process, contact [email protected].