KYC for ST33 Limited Policy

Anti-Money Laundering & Know Your Counterparty (KYC) Policy and Procedure

This policy confirms [ST33 Limited]’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.

[ST33 Limited] has established Know Your Counterparty (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.

[Our specialised team] is responsible for development and implementation of this policy and relevant procedures, and [ST33 Limited] commits to review our KYC policy and procedure every year.

To support our KYC policy and procedures, [ST33 Limited] has developed a KYC verification process which we send to all our counterparties (this is our business partners: suppliers and customers) to collect relevant business information to identify risks of money-laundering. We require them to upload documents to be completed for all existing and new counterparties.

By collecting and reviewing the information in completed KYC uploads, [ST33 Limited] commits to

• establishing the identity of our counterparties
• checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in FATF
• high-risk jurisdictions, named on government sponsored watchlists or international (UN) sanctions lists, or if they source
• from conflict-affected and high-risk areas (CAHRAs))
• maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses
• maintaining KYC records for at least five years
• maintaining records of all single or linked cash (or cash-like) transactions above 10,000EUR
• monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.

If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:

• Cease trading with the counterparty
• Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list
• Make an on-site visit to the high-risk counterparty.

Performer Verification & Approval.

We verify performers/models before allowing their content publicly accessible. Our solution includes a verification and approval system for performers/models:

Configure verification information required from Live Webcam: Settings > Account records in backend. Administrative records show on the registration page and include document uploads for proof of age and proof of address. By utility bill and a selfie holding passport or driving licence.

Performers can only setup Webcam listings and go live after approval. Same for Studios.

ST33 Limited reviews and approves all users.