Our Vetting Process for New Sellers
Our platform is committed to ensuring a secure and reliable environment by implementing a comprehensive yet efficient vetting process for new sellers. This procedure typically takes between 1-3 days, depending on the complexity of the situation. Due to our rigorous criteria, only about 13% of applicants successfully pass through the vetting process.
Initial Screening
The vetting process begins with a standard company check-up. We quickly filter out any opportunities that do not meet our basic criteria by assessing the seller’s track record, experience, and reputation. This step helps us swiftly identify any red flags and ensure a high level of initial scrutiny.
Detailed Due Diligence
Once the initial screening is complete, we perform a detailed due diligence check, which includes:
• Background Checks: Comprehensive checks on key individuals to ensure there are no past legal or financial issues.
• Financial Review: Reviewing financial statements and projections to confirm their accuracy and viability.
• Site Visits: For physical assets, we may conduct site visits to verify conditions and assess potential risks.
Assessment and Review
Following the detailed due diligence, our investment team evaluates the opportunity through:
• Management Evaluation: Assessing the experience, stability, and strategy of the management team.
• Risk Analysis: Identifying potential risks, including market trends and regulatory considerations, to ensure they are manageable.
• Investment Thesis Validation: Validating the investment’s potential through market research and performance analysis.
Committee Approval
The final stage involves a thorough review by our investment committee, which:
• Scrutinizes the Investment Thesis: Ensures all identified risks have been addressed and that the investment aligns with our strategic goals.
• Approves or Rejects the Offering: Makes the final decision to approve or reject the listing on our platform.
Continuous Monitoring
Our commitment to due diligence continues even after an asset or business is listed. We continuously monitor performance and review any new information to manage risks and ensure transparency for our investors.
By keeping our vetting process straightforward and effective, we aim to provide a trustworthy platform for both sellers and investors. This approach ensures that only 13% of new sellers pass through our vetting procedure, maintaining high standards while facilitating a smooth and efficient process.
KYC and AML Process for New Users
For new users, our platform implements a thorough Know Your Customer (KYC) and Anti-Money Laundering (AML) process to ensure compliance with regulatory standards and protect against fraudulent activities. Here’s how we manage this:
KYC Process
1. Customer Identification: Collecting basic information from new users, such as name, address, date of birth, and other identification details.
2. Document Verification: Verifying identity through government-issued IDs (passports, driver’s licenses) and for sellers - proof of address.
3. Biometric Verification: Users may need in some cases to take a selfie or short video for biometric verification, matching their live image with the submitted ID.
4. Cross-Reference Against Sanction Lists: Checking the user’s information against various sanction lists to ensure they are not involved in any illicit activities.
5. Ongoing Monitoring: Regularly reviewing user transactions and behavior to identify any suspicious activities, ensuring compliance with AML regulations.
AML Process
1. Customer Due Diligence (CDD): Establishing the true identity of customers, understanding the nature of their transactions, and assessing risk levels.
2. Enhanced Due Diligence (EDD): Applying more stringent checks for higher-risk customers, including additional background checks and continuous monitoring.
3. Suspicious Activity Reporting (SAR): Detecting and reporting suspicious activities to relevant authorities.
4. Record-Keeping: Maintaining comprehensive records of all customer information and transaction histories to comply with regulatory requirements.
5. Risk Assessment: Continuously assessing and updating the risk profiles of customers to ensure appropriate monitoring and reporting measures are applied.
Legal Compliance
European Union
In Europe, data collection and processing must comply with the General Data Protection Regulation (GDPR). The GDPR requires that personal data collection is lawful, fair, and transparent, and that it is collected for specified, explicit, and legitimate purposes. Here are the key personal details that marketplaces are allowed to collect under GDPR:
1. Identification Information: Full name, date of birth, and contact details such as address, phone number, and email.
2. Verification Documents: Copies of government-issued IDs (e.g., passports, driver’s licenses) and proof of address documents (e.g., utility bills or bank statements).
3. Biometric Data: If necessary for verification purposes, biometric data such as photos or videos for facial recognition.
4. Transaction Data: Information about transactions conducted on the platform, including payment details and transaction history.
5. Sanction List Screening: Data required to cross-check users against international sanction lists and PEP (Politically Exposed Persons) lists.
Relevant Legal Paragraph:
GDPR Article 5 – Principles Relating to Processing of Personal Data:
1. Personal data shall be:
• processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
• accurate and, where necessary, kept up to date;
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
For more detailed information, you can refer to the full text of the GDPR available on EUR-Lex .
Global Compliance
For global operations, compliance with various international regulations is essential. Key frameworks and standards include:
1. Financial Action Task Force (FATF): International standards for combating money laundering and terrorist financing (FATF).
2. USA PATRIOT Act: Requires financial institutions to implement robust AML programs, including KYC procedures (USA PATRIOT Act).
3. Bank Secrecy Act (BSA): U.S. regulation mandating reporting of suspicious activities and maintaining transaction records (Bank Secrecy Act).
4. Common Reporting Standard (CRS): An OECD standard for automatic exchange of financial account information to combat tax evasion (CRS).
References:
• Collecting personal information from users - GOV.UK
Collecting personal information from users - Service Manual - GOV.UK
.
• Collecting personal data - ICO .
• Regulation - 2016/679 - GDPR - EUR-Lex .
