DMT Data Driven Venture Capital Ltd AML/CFT & KYC PROCEDURES MANUAL Accepting investments into technology startups from business angels and family offices (HNWI/UHNWI)
1. Introduction This Manual sets out DMT Data Driven Venture Capital Ltd’s internal practices, procedures and controls for preventing money laundering and terrorist financing, KYC and CFT. It is maintained by the MLCO and approved by the CEO.
2. General Definitions (Select terms) ● Beneficial Owner: Natural person(s) with ultimate ownership/control (>25% share or equivalent). ● Business Relationship: Any ongoing professional relationship with a Client. ● Client: Any individual or entity seeking to invest. ● EDD: Enhanced Due Diligence for high-risk Clients. ● SAR: Suspicious Activity Report filed with MOKAS.
3. Responsibilities of the CEO ● Approve AML/CFT policy and Manual ● Appoint MLCO and allocate sufficient resources ● Ensure systems detect and prevent money laundering arising from serious tax offenses ● Oversee annual training program
4. Money Laundering Compliance Officer (MLCO) ● Maintain and update this Manual ● Oversee onboarding, transaction monitoring, SAR filings ● Liaise with MOKAS and regulators ● Design risk-based policies and document internal controls
5. Risk-Based Approach ● Categorize Clients by risk factors (HNWI/UHNWI, PEP status, jurisdiction) ● Apply EDD for high-risk categories ● Sources: FATF, MONEYVAL, EU Sanctions Map, UN Security Council 2
6. Client Acceptance Policy (CAP) ● Preliminary risk assessment on every prospective Client ● Reject or escalate any application lacking satisfactory documentation
7. Client Identification & Due Diligence 7.1 When to Apply ● Onboarding a new Client ● Any single transaction ≥ €15,000 ● Suspicious circumstances, regardless of amount ● Material change in Client profile 7.2 Required Documentation ● Individuals: Valid ID/passport, proof of address, source-of-fund declaration ● Entities: Certificate of incorporation, articles of association, ownership structure, director/beneficial-owner IDs 7.3 Multi-Stage Automated Screening All automated checks run after initial onboarding via Sumsub: 1. 2. 3. 4. Sumsub – sanctions (EU/UN/OFAC), PEP, adverse media, face-document biometric match Cardamon – AI-driven extraction of regulatory obligations, policy-gap detection, remediation guidance Vivox AI – AI-powered document authenticity and facial verification Intrepid Fox – Deep-dive into corporate and trust structures to identify hidden UBOs 7.4 Failure or Refusal If a Client refuses or fails to provide required information, terminate the relationship and consider SAR filing. 7.5 Onboarding of High-Net-Worth Individuals (HNWI) 3
8. Ongoing Monitoring & KYC Updates ● Annual re-screening of all Clients or upon major profile changes ● Real-time transaction monitoring with threshold and behavioral alerts ● Investigate and escalate within 24 hours
9. Suspicious Activity Reporting ● File a SAR with MOKAS promptly upon detecting suspicious behavior ● Retain SAR records for at least five years
10. Sanctions Compliance ● Weekly updates of EU/UN/OFAC lists via Sumsub; validate changes via Cardamon ● Immediately suspend/terminate any Client newly listed
11. Data Retention & Protection ● Retain all KYC and transaction records for minimum five years post-relationship ● Ensure GDPR compliance: encryption, access controls, secure storage
12. Staff Training & Awareness ● Mandatory annual AML/CFT training covering Sumsub, Cardamon, Vivox AI, Intrepid Fox ● Biannual tabletop exercises to validate response protocols References 1. 2. 3. 4. Sumsub – https://sumsub.com/about/ Cardamon – https://cardamon.ai/ Vivox AI – https://www.vivox.ai/ & https://app.vivox.ai/ Intrepid Fox – https://intrepidfox.ai/ Conclusion: By integrating Cardamon, Vivox AI, and Intrepid Fox following Sumsub’s initial screening, DMT Data Driven Venture Capital Ltd ensures a fully automated, risk-based AML/CFT framework. This approach delivers rapid, comprehensive due diligence and ongoing monitoring that meets the unique needs of handling investments from high-net-worth and ultra-high-net-worth investors into technology startups.
