Individual Client Verification Requirements

1. Purpose

This policy (Ref: COMP-KYC-002) defines the minimum identification and verification standards for individual (natural person) clients of the Bank. It implements the requirements of AMLD6, FATF Recommendation 10, and applicable national regulations across all jurisdictions in which the Bank operates.

2. Scope

This policy applies to all individual clients, including sole traders, joint account holders, authorised signatories on corporate accounts, and beneficial owners identified through the corporate KYC process.

3. Identification Requirements

The following information must be collected for every individual client:

• Full legal name (as it appears on official identification documents).
• Date of birth.
• Place of birth (where required by local regulation).
• Nationality or nationalities.
• Current residential address.
• Tax identification number (TIN) and country of tax residence (in accordance with the Common Reporting Standard).
• Occupation or employment details.
• Purpose and intended nature of the business relationship.
• Expected account activity and transaction volumes.

4. Verification Requirements

4.1 Identity Verification

Identity must be verified using at least one of the following primary documents:

Copies of identification documents must be certified as true copies or verified against originals by a Bank employee. Digital copies obtained through the Bank's electronic onboarding channel must comply with the eIDAS framework or equivalent local standards.

4.2 Address Verification

Residential address must be independently verified using one of the following:

• Utility bill (gas, electricity, water, telephone — not mobile) dated within the last three (3) months.
• Bank or building society statement dated within the last three (3) months.
• Government-issued correspondence (tax notice, voter registration) dated within the last twelve (12) months.
• Tenancy agreement or mortgage statement from a recognised financial institution.

4.3 Electronic Verification (eKYC)

The Bank permits electronic identity verification as an alternative or supplement to document-based verification, provided that the electronic verification solution:

• Draws on multiple independent and reliable data sources (e.g., credit reference agencies, government registries, telecommunications databases).
• Achieves a minimum match confidence level as defined in the Bank's eKYC Standard (COMP-KYC-002a).
• Is approved by the Compliance Department and subject to periodic validation.

5. Special Cases

5.1 Non-Face-to-Face Onboarding

Where the client is onboarded remotely, additional verification steps are required, including liveness detection, video identification, or certified document submission via secure digital channels. Refer to COMP-KYC-002b for detailed remote onboarding requirements.

5.2 Minors

Accounts for clients under the age of 18 require the identification and verification of the legal guardian or parent, in addition to the minor's details. The guardian must provide proof of legal authority (e.g., birth certificate, court order).

5.3 Vulnerable Clients

Additional care must be taken when verifying the identity of clients who may be vulnerable due to age, disability, or other circumstances. The Bank's Vulnerable Client Policy (OPS-VC-001) must be applied in conjunction with this procedure.

6. Timing

Verification must be completed before the establishment of the business relationship. In exceptional circumstances, verification may be completed within thirty (30) calendar days of account opening, provided that appropriate risk mitigating measures are in place (e.g., transaction limits, enhanced monitoring) and approval is obtained from a Compliance Officer.

7. Record Keeping

All identification and verification records must be retained for a minimum of five (5) years following the termination of the business relationship.

8. Review

This policy is reviewed annually. Next review: Q2 2027.