KYC and Source of Funds Notice

1. Purpose of KYC and verification

Know Your Customer, or KYC, is the process used to identify and verify customers, understand the purpose of the relationship, assess risk and help prevent fraud, money laundering, terrorist financing, sanctions evasion and other unlawful activity.

KYC also helps Kingscross protect customers from account takeover, impersonation, scams and misuse of their personal or business information.

2. When checks may apply

Kingscross may carry out verification:

• when a customer registers;
• before a first transaction;
• before a higher-value or higher-risk transaction;
• when customer information changes;
• when activity differs from the expected profile;
• when a new beneficiary, corridor, currency or funding method is used;
• when required by law, regulation, a bank or payment partner;
• during periodic customer reviews;
• when fraud, sanctions or AML concerns arise.

3. Individual customer information

An individual customer may be asked to provide:

• full legal name and any former name;
• date and place of birth;
• nationality and country of residence;
• national identity number, passport or other approved document;
• residential and postal address;
• telephone number and email address;
• occupation, employer or business activity;
• expected transaction value, frequency and countries;
• source of funds and, where required, source of wealth;
• purpose of the account or transaction.

4. Business customer information

A business customer may be asked to provide:

• registered and trading names;
• registration and tax numbers;
• registered, principal and operating addresses;
• business activity, sector and expected transaction profile;
• directors, shareholders, partners or trustees;
• beneficial owners and controllers;
• authorised signatories and representatives;
• constitutional documents, ownership charts and resolutions;
• licences and regulatory status where applicable;
• bank details, financial statements, contracts, invoices and supporting records.

5. Beneficial ownership and control

Kingscross must understand the natural persons who ultimately own or control a business customer, directly or indirectly.

Verification may include:

• shareholding or ownership percentage;
• voting rights;
• control through agreements or other means;
• senior managing officials where no other owner can be identified;
• ownership through parent companies, trusts, nominees or intermediaries.

Kingscross may request an ownership chart, company-search results, shareholder registers, trust documents or other evidence.

6. Directors, signatories and authorised persons

Kingscross may verify the identity and authority of any person who gives instructions, accesses the account or represents the customer.

Evidence may include board resolutions, powers of attorney, mandates, employment confirmation or other written authority.

7. Document standards

Documents should be valid, legible, complete and consistent with the information provided.

Kingscross may reject or request replacement documents where they are:

• expired;
• damaged or unreadable;
• altered or incomplete;
• inconsistent with other information;
• not from a reliable or recognised source;
• suspected to be forged or misleading.

Certified, translated or independently verified copies may be required in some cases.

8. Source of funds

Source of funds means the origin of the money used for a specific transaction.

Examples may include:

• salary or employment income;
• business revenue;
• sale of goods or services;
• sale of property or another asset;
• savings;
• loan proceeds;
• dividend or investment income;
• inheritance or gift;
• insurance or legal settlement;
• another lawful and verifiable source.

Kingscross may request evidence showing both the source and the movement of the money into the funding account.

9. Source of wealth

Source of wealth explains how a customer’s overall assets or financial position were accumulated over time.

Examples may include:

• long-term employment or professional income;
• business ownership;
• investment activity;
• inheritance;
• sale of a business or property;
• family wealth;
• another lawful source.

Source-of-wealth information may be required for higher-risk, higher-value or more complex relationships.

10. Transaction purpose

Customers must provide a truthful and sufficiently clear purpose for each transaction.

Examples include:

• supplier payment;
• family support;
• education fees;
• medical expenses;
• rent or property-related payment;
• salary or payroll;
• travel or business expenses;
• purchase of goods or services;
• investment or capital contribution where lawful and approved.

Descriptions such as “personal”, “business” or “payment” may be insufficient where more detail is reasonably required.

11. Beneficiary relationship and information

Kingscross may ask:

• who the beneficiary is;
• the customer’s relationship with the beneficiary;
• why the beneficiary is receiving the funds;
• whether the beneficiary is acting for another person;
• whether the beneficiary account is owned by the stated person or business;
• whether the transaction is part of a wider business or personal arrangement.

12. Funding-account ownership

Funds should normally come from an account or payment instrument held in the customer’s own name or the registered name of the business customer.

Third-party funding may require additional evidence, including:

• the relationship between the payer and customer;
• authority to use the funds;
• source of funds;
• reason for third-party funding;
• identity of the actual payer.

Kingscross may reject anonymous, unrelated, split or mismatched funding.

13. Business transaction evidence

For business payments, Kingscross may request:

• commercial invoice;
• purchase order;
• sales contract;
• shipping or customs documents;
• supplier details;
• proof of delivery;
• bank statements;
• tax or import documents;
• board or management approval;
• another document relevant to the transaction.

14. Risk-based approach

Kingscross applies customer due diligence according to the level of risk presented by the customer, transaction, country, product, delivery channel, funding source and beneficiary.

Lower-risk cases may require standard verification. Higher-risk cases may require enhanced checks, additional approvals or closer monitoring.

15. Enhanced due diligence

Enhanced due diligence may apply where:

• the customer or transaction is high value;
• the ownership structure is complex or opaque;
• a high-risk country or corridor is involved;
• the activity is unusual or inconsistent;
• a politically exposed person is involved;
• there is adverse media or sanctions concern;
• remote onboarding creates increased risk;
• the funding or beneficiary arrangement is unclear;
• another significant risk factor is present.

Enhanced checks may include senior approval, additional documents, independent verification, source-of-wealth review or closer transaction monitoring.

16. Politically exposed persons

A politically exposed person, or PEP, is a person entrusted with a prominent public function, together with certain family members and close associates as defined by applicable law and policy.

PEP status does not automatically mean wrongdoing. However, additional measures may be required, including:

• senior management approval;
• source-of-wealth and source-of-funds checks;
• enhanced ongoing monitoring;
• periodic review of the relationship.

17. Sanctions and screening

Kingscross may screen:

• customers;
• beneficial owners;
• directors and authorised persons;
• beneficiaries and counterparties;
• countries, banks and payment institutions;
• transaction references and supporting information.

Potential matches may require investigation before a transaction can proceed.

18. Ongoing transaction monitoring

Kingscross may monitor activity using rules, alerts, risk indicators and manual review.

Factors may include:

• transaction value and frequency;
• rapid or repeated transactions;
• new or unusual beneficiaries;
• high-risk or unexpected countries;
• multiple funding sources;
• activity inconsistent with occupation or business profile;
• unusual device, login or account behaviour;
• attempts to avoid limits or verification;
• transactions lacking a clear commercial or personal purpose.

19. Periodic review and information refresh

Kingscross may periodically ask customers to update or reconfirm:

• identity documents;
• address;
• telephone and email;
• ownership and directors;
• authorised persons;
• occupation or business activity;
• expected transaction profile;
• source of funds or wealth.

Reviews may occur sooner where risk or activity changes.

20. Third-party, nominee and intermediary activity

Kingscross may require full disclosure where a customer is acting for another person, using a nominee, collecting funds, paying on behalf of another party or acting as an intermediary.

Undisclosed third-party activity may result in delay, rejection, account restriction or closure.

21. Verification through agents and branches

An approved Kingscross agent or branch may collect identification and supporting documents where permitted.

The agent must:

• follow Kingscross procedures;
• use approved systems and forms;
• protect customer information;
• avoid making unauthorised exceptions;
• escalate suspicious or incomplete cases;
• not retain copies outside approved systems.

22. Remote and digital verification

Remote onboarding may involve:

• document capture;
• facial comparison or liveness checks;
• database verification;
• OTP confirmation;
• device and fraud checks;
• manual review.

Kingscross may require in-person or additional verification where remote checks are inconclusive or risk is higher.

23. Delay, refusal, restriction and closure

Kingscross may delay or refuse registration or a transaction where:

• required information is missing;
• documents cannot be verified;
• the source of funds is unclear;
• the transaction purpose is inconsistent or unsupported;
• fraud, sanctions or AML concerns arise;
• a bank or payment partner refuses the activity;
• law, regulation or internal risk policy requires it.

Kingscross may suspend or close an account where risk cannot be managed or the customer repeatedly fails to provide required information.

In some circumstances, Kingscross may be legally prohibited from giving a full explanation.

24. Recordkeeping, confidentiality and privacy

KYC, source-of-funds, source-of-wealth and monitoring records may be retained for the period required by applicable law, regulation, audit, dispute and risk-management obligations.

Information may be shared with banks, payment partners, identity-verification providers, regulators, law-enforcement bodies and other competent authorities where lawful and necessary.

Personal data is handled in accordance with the Kingscross Privacy Notice.

25. Customer responsibilities

Customers must:

• provide true, complete and current information;
• submit genuine documents;
• explain the true purpose of the transaction;
• identify the actual source of funds;
• disclose any person on whose behalf they act;
• notify Kingscross of material changes;
• respond promptly to reasonable information requests;
• not structure or split transactions to avoid controls;
• not ask staff or agents to ignore or bypass verification.

26. Examples of supporting evidence

27. Contact details