Policy Guidelines on ‘Know Your Customer’ (KYC) and ‘Anti Money Laundering’ (AML) Measures
Purpose and Scope
Parthian Watch Company (PWC) is committed for transparency and fairness in dealing with all customers and ensuring adherence to all applicable United States laws and regulations. The company ensures that information collected from customers for any purpose will be kept confidential. The company also commits that the information sought from the customer is relevant to the perceived risk, is not intrusive and conforms to general industry guidelines issued in this regard. Any information from the customer that falls outside these parameters shall be sought from the customer separately with his/her consent and after effective rendering of service. The company shall also make available its KYC norms to the customers upon request.
The objective of PWC’s guidelines is to prevent transactions being used, intentionally or unintentionally, for money laundering purposes. The guidelines also mandate making reasonable efforts to determine the identity and beneficial ownership of bank accounts, source of funds, the nature of customer’s business, reasonableness of transactions in the account in relation to the customer’s resources, and other relevant information which in turn helps PWC manage its risks prudently. Accordingly, the main objective of this policy is to enable PWC to have positive identification of its customers and the source of their funds.
Customer Acceptance Policy
- A. The customer must be a major (i.e., at least 18 years older) and not incapacitated and unable to enter into a contract.
- B. PWC reserves the right to reject transactions from any countries that may put PWC at risk of non-compliance with the US Department of State policies.
- C. Proposed transaction from, proposed money transfers from, or shipping requests to any countries listed in the US State Department Sponsors of Terrorism are automatically rejected.
- D. The name of the customer should not appear in the list of banned entities as circulated by UNSCR.
- E. If a customer is a government official or an officer of a non-profit organization, PWC reserves the right to request additional information confirming the source of funds is private, rather than institutional.
- F. If a customer is domiciled in a region where shipping presents a high risk of loss, PWC reserves the right to ask the customer to arrange transportation and insurance of the goods at their own expense.
Key Customer Acceptance Considerations:
- Risk categorization shall be undertaken based on parameters such as customer’s identity,
social/financial status, nature of business activity, information about the clients’ business and
their location, as well as other relevant factors. While considering customer’s identity, the ability to confirm identity through online or other services offered by issuing authorities may also be factored in to enable categorization of customers as an acceptable risk. For example, customers’ identification, location and nature of business may be verified through commonly available resources such as LinkedIn, Chrono24.com, Facebook and other public sites. Risk assessment and identification of this nature will not be deemed as intrusive by any person wishing to conduct business with PWC.
- While preparing a customer profile, PWC will seek only such information from the customer as is relevant to the risk category and is not intrusive. The customer profile will be a confidential document and details contained therein will not be divulged for cross-selling or any other purpose.
Medium & High-Risk Customers
Customers that are likely to pose a higher-than-average risk will be categorized as medium or high risk depending on the customer’s background, nature and location of activity, country of origin, sources of funds and his client profile and other information. PWC may, at its sole discretion, refuse to conduct business with medium and high-risk customers.
Illustrative examples are:
- Non-US-Resident customers
- High Net worth Individuals
- Trust, charities, NGO’s and Organization receiving donations
- Companies having close family shareholding or beneficial ownership
- Firms with ‘sleeping partners’
- Politically Exposed Persons
- Those with dubious reputation as per available public information
- Accounts of bullion dealers and jewelers
- Customers who may wish to engage in business using Crypto currency
- Customers asking for shipment to countries with high risk of loss
In certain cases, customers wishing to do business with PWC may have existing relationships with commercial entities engaged in business with PWC. Some illustrative examples are the major auction houses, online marketplaces such as Chrono24.com, eBay.co, getbezel.com, and more. Notwithstanding that a customer may present an acceptable risk to these related entities, PWC may refuse to transact directly with a customer based on our own risk assessment.
PWC shall document and implement appropriate procedures to retain records of KYC due diligence and anti-money laundering measures. The business process shall implement, at a minimum, the following procedures for retaining records:
All transactions invoices will be saved for a minimum of five years, including the amount of the transaction, taxes charged (if applicable), detailed record of goods sold and shipping address (including the shipper’s reference numbers).
Sharing of Records
While PWC is committed to protecting our customers’ privacy, and specifically not use customer information for commercial purposes, PWC will share transaction records if such information is requested by US government law enforcement and/or taxation authorities.
Any potential customer wishing to keep information private from US government institutions should not pursue business with PWC. By engaging in the act of buying or selling a watch to PWC, you consent to details of current and prior transactions to be disclosed upon a governmental inquiry.
Designated Director / Principal Officer
Mr. Amin Majidi, the owner and director of PWC, is responsible for ensuring overall KYC compliance is observed.