KYC and AML policy

How Fexenvance confirms who its clients are and watches for financial crime, under United Kingdom law. It explains what we ask for, why we ask and what happens to the information.

  • Money Laundering Regulations 2017
  • UK GDPR safeguards

Introduction

This policy describes the procedures Fexenvance uses for Know Your Customer (KYC), anti-money laundering (AML) and counter-terrorist financing (CTF). Their purpose is to confirm that clients are who they say they are, to stop the platform being used for crime and to meet the legal duties that apply to services of this kind in the United Kingdom.

Verification is not a formality we can waive. It applies to everyone, whatever the size of the account, and the same standards are applied whether you are a first-time or long-standing user.

What is KYC

Know Your Customer means identifying a client and checking that the details they give are true. In practice we collect your name, date of birth, address and a government-issued identity document, then compare them with the evidence provided and with the information from our verification partners.

KYC is not a one-off event. We may ask you to refresh your information if a document expires, if your circumstances change or if our monitoring raises a question.

What is AML

Anti-money laundering covers the policies that prevent criminals from disguising the origin of illegal money by moving it through legitimate services. It includes assessing the risk each client presents, monitoring transactions for unusual patterns and reporting suspicions to the National Crime Agency, as the Proceeds of Crime Act 2002 requires.

Staff receive regular training on these duties. We also appoint a senior person responsible for oversight of our approach, who reviews it at least once a year.

Why identity verification is required

Checks reduce fraud, protect your account against takeover by someone using stolen details, satisfy the legal rules that apply to us and lower financial risk for clients and the business alike. They also protect you indirectly, because a platform that cannot verify its clients is a platform criminals prefer.

Documents we ask for

We ask only for what we actually use. To prove identity, we accept a valid passport, a UK photocard driving licence or a national identity card. To prove address, we accept a utility bill, a bank or building society statement or a council tax letter issued in the last three months.

We may also ask for a selfie or short liveness check to confirm that the person holding the document is the person applying. Documents must be complete, in colour, readable and not edited.

The verification process

  1. Register. You create an account and your manager explains what will be needed.
  2. Submit data and documents. You upload the items above through the secure form.
  3. Automated check. Software checks the document's security features and compares your face with the photo.
  4. Manual review where needed. A trained analyst reviews any case the software cannot resolve.
  5. Confirmation. You are told the outcome and can then fund and use the account.

Enhanced due diligence

Some clients present higher risk, for example politically exposed persons, people linked to high-risk countries or those with unusually large or complex activity. For them we apply enhanced due diligence (EDD), which can include asking for the source of funds or wealth, such as payslips, savings evidence or a sale agreement, and for senior approval before we proceed.

How long checks take

Most automated checks finish within minutes and manual reviews within one to two working days. We cannot give a fixed time, because it depends on document quality, whether extra evidence is needed, the volume of requests and how quickly you respond.

Why verification may be refused

We may decline or suspend a check when a document is invalid, expired or unreadable, when the details do not match, when we suspect forgery, when requested information is not supplied, or when the activity raises financial crime concerns. Where the law allows, we will tell you what went wrong so you can fix it.

Transaction monitoring

We monitor deposits, withdrawals and platform activity for patterns that suggest laundering or fraud, such as rapid movement of funds in and out, payments from third parties or sudden changes in behaviour. If something looks suspicious we may limit features, delay a withdrawal or ask questions. The law may prevent us from telling you that a report has been made.

Your responsibilities

You must give accurate, current and genuine information and documents, and tell us promptly if your details change. Providing false information may lead to account closure, funds being held pending enquiries and reports to the relevant authorities, and may be a criminal offence.

Storage and protection of data

KYC documents are encrypted, held in restricted systems and accessible only to staff who need them. Under the Money Laundering Regulations 2017 we must keep identity records for five years after the relationship ends. How we handle personal data in general is set out in the Privacy Policy.

Sharing data

Where necessary we share KYC information with identity-verification providers, IT suppliers who host our systems under contract, affiliated companies in the same group, and with regulators, law enforcement and other public bodies when we are required or permitted to do so. We do not sell your data.

Compliance with legal requirements

We work within the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the UK sanctions regime, and follow guidance from HMRC and the Joint Money Laundering Steering Group where relevant. See Licensing and regulation for our regulatory position.

Contact and support

For questions about verification, document requirements or this policy, write to [email protected] or ask your personal manager. Please do not email identity documents; use the secure upload your manager sends you.

Examples of what we may ask you for

Most clients need nothing beyond an identity document, proof of address and a selfie. In a smaller number of cases we ask for more, and the request is always specific. For instance, if a deposit is much larger than your account history suggests, we may ask where the money came from and accept a payslip, a savings statement, a property sale document or an inheritance letter. If a payment comes from a bank account that is not in your name, we will ask you to use one that is.

If a document is hard to read, we will ask for a clearer copy rather than closing your application. Please reply promptly. Accounts with outstanding requests may have deposits or withdrawals paused until the review is complete.

Sanctions and politically exposed persons

We screen clients against UK sanctions lists and against lists of politically exposed persons, which means people who hold or recently held prominent public roles, and their close family and associates. Being on such a list does not prevent anyone from using the platform, but it does lead to enhanced checks. We cannot serve anyone who is subject to UK financial sanctions.

Record keeping and training

We keep records of identity checks, risk assessments and monitoring decisions, and we review them regularly. Staff in client-facing roles complete anti-money laundering training when they join and again each year, so that suspicious situations are recognised and escalated properly.