Purpose and Scope

The Tk10 Know Your Customer and Anti Money Laundering Policy governs all onboarding, account management, and transaction activity on the Tk10 platform. It establishes mandatory identification, verification, risk assessment, ongoing monitoring, record-keeping, and disclosure procedures to comply with applicable anti money laundering and countering financing of terrorism laws. The policy applies to all Tk10 customers and accounts, including individuals and entities, throughout the customer lifecycle.

Regulatory Framework and Definitions

  • Anti Money Laundering and Countering Financing of Terrorism requirements encompass all identification, verification, monitoring, and reporting obligations imposed by applicable law and regulation.
  • Know Your Customer means procedures to establish and verify the identity of customers and to assess the risk of illicit activity associated with the relationship.
  • Customer Due Diligence requires the company to identify and verify the customer and to understand the nature and purpose of the business relationship.
  • Enhanced Due Diligence applies for customers or transactions presenting higher risk, including additional verification, source of funds checks, and closer ongoing monitoring.
  • Politically Exposed Person refers to an individual who holds or has held a prominent public function, together with their immediate family and close associates, subject to enhanced scrutiny.
  • Source of Funds refers to the origin of the funds used to fund the customer’s account, which must be verifiable and consistent with the declared activity or profile.

Identity Verification and Minimum Data

On onboarding the Tk10 platform will collect and verify the following data and documents to establish identity and prevent fraud.

  • Minimum data set required for identity verification includes: full name, date of birth, nationality, permanent residential address, and a valid identification number issued by a competent authority.
  • Acceptable identity evidence includes a current passport or national identity card. A documentary proof of address must be an original or verifiable document showing the customer name and residential address, not older than three months.
  • Additional identity documents may be requested if the initial evidence does not conclusively establish identity or as required by risk assessment, including secondary government-issued IDs.
  • For ownership verification the company may require a photograph of the user with the identity document or a photograph of the front of a bank card showing the cardholder name and the first five digits and last four digits to confirm card ownership.

Source of Funds and Source of Wealth

Customers must provide evidence of the origin of funds used for deposits and transfers. Acceptable sources include:

  • Employment income evidenced by payslips or official remuneration statements;
  • Management fees, dividends, pensions, or other retirement income supported by statements from the payer or administrator;
  • Direct bank transfers or statements showing a traceable, legitimate source of funds;
  • Documented ownership or control of funds consistent with declared wealth or income, such as investment accounts or endowments.

Risk Based Approach and Enhanced Due Diligence

The Tk10 policy applies a risk based approach to customer identification and ongoing monitoring. Enhanced due diligence is required where risk indicators are identified, including but not limited to:

  • Customers located in high risk or restricted jurisdictions;
  • Unusual or large value transactions inconsistent with the customer profile;
  • Opaque or rapidly changing sources of funds or wealth;
  • Presence of politically exposed persons or their close associates or family members.

EDD measures may include additional identity verification, deeper source of funds analysis, closer monitoring of activity, and escalation to senior compliance for review.

Prohibited and Linked Accounts

Anonymous or nominal accounts are prohibited. The Tk10 platform shall identify and verify identity for all accounts. If multiple accounts appear to be held by the same individual or are otherwise linked to the same ownership, the company may:

  • Suspend or close additional or linked accounts;
  • Reverse winnings and refund deposits associated with the linked accounts.

Politically Exposed Persons

The company applies enhanced scrutiny to customers identified as PEPs or as immediate family or close associates of a PEP. The level of scrutiny and ongoing monitoring is risk-based and proportionate to the potential risk posed by the customer.

Ongoing Monitoring and Record Keeping

The Tk10 KYC/AML program requires ongoing monitoring of customer activity to detect unusual or suspicious transactions and to ensure records remain current. This includes:

  • Automated transaction monitoring aligned with customer risk profiles;
  • Periodic review of customer information and documents, at least annually or when risk factors change;
  • Retention of all KYC records, verification results, and transaction data for a minimum of five years after account closure or as required by applicable law;
  • Updating customer records promptly upon material changes to personal data or business activity.

Sanctions Screening and Adverse Media

All customers and counterparties are screened against applicable sanctions lists and adverse media sources. Alerts may trigger enhanced due diligence or other actions consistent with regulatory obligations and this policy.

Suspension, Termination and Refunds

Tk10 reserves the right to take action including restricting access, suspending transactions, or terminating the customer relationship if there is reasonable suspicion of noncompliance with KYC/AML rules or if documentation fails to establish identity or source of funds. Refunds of valid deposits may be issued in accordance with internal policies and applicable law. If a breach is discovered after onboarding, existing activity may be reversed or halted as appropriate.

Privacy, Data Protection and Security

Personal data collected under this policy will be processed in accordance with applicable privacy laws and Tk10 data protection policies. Access to personal data is restricted to authorized personnel. Data subject rights such as access, correction, and deletion will be respected where permitted by law. Appropriate security measures are maintained to protect data integrity and confidentiality.

Governance, Training and Compliance

The compliance function oversees the KYC/AML program. All relevant staff receive regular AML/KYC training. The policy is approved by the board and reviewed at least annually or sooner if required by changes in law or risk profile.

Policy Review and Updates

This policy is reviewed at least annually or upon regulatory guidance changes. Updates are implemented to reflect new requirements, risk findings, or improvements in controls.

Questions, Complaints and Contact

Queries regarding this policy should be directed to Tk10 compliance at the contact address published by Tk10. In cases of suspected AML/CTF issues, customers may be required to provide additional information or documentation as part of the investigation.