1. KYC | AML | CTF | Privacy Kanchan Kumar
#CashlessConsumer May 30, 2020 @kanchankumar

2. Disclaimer
This advice is for educational and informative processes only.
The content of this presentation belongs with Remitr and can be used in
fair use. Remitr does not take responsibility for liability or damages.

3. REMITR
Remitr is a B2B payments platform. We are an alternative to wires, checks,
and bank visits - a catalyst to global commerce.
● Pay suppliers within Canada, US or anywhere in the world
○ Receive payments from customers in US, UK, EU
○ Send payment to Email
○ Automate Payments using API
○ Automate AR, AP, Bookkeeping
● Modern proprietary payment network covering 75+ countries
○ Collect and disburse funds using local rails
○ Strong KYC, AML, CTF, Fraud & Currency Control Compliances
○ Cover off-network countries using legacy railes

4. Effective Compliance
● Saying what you do and how
● Training team on doing it
● Doing what you said you’d do
● Keeping record of what you did
● Auditing what was done
● Review and repeat periodically
THE STRONGER THE KYC, THE LOWER THE AML RISK

5. It starts with intent
● What are the obligations under privacy laws?
○ PII
○ Financial data
● How can we preparing for data localization?
● What if there are conflict of privacy and AML regulations?
● Policies & Procedures for KYC, AML, CTF
● Risk assessment

6. Nuts & Bolts
● Individual v/s Business KYC
● ID verification v/s KYC
● Elements of Business KYC
○ Company constitution
○ Dealing with Sole proprietors
○ Jurisdiction of incorporation
○ ID of authorized person signing up +
Director
○ Nature of business
○ Nature, purpose & volume of transactions
○ Ultimate beneficial owner
○ Politically exposed person

7. Nuts & Bolts
● Verifying the KYC data collected
○ Company registry and/or 3rd-party sources
○ ID verification by document/selfie/video
○ Web searches
○ Bonafides of the business
● AML
○ Watchlist
○ Adverse media reports
○ PEP databases
○ False positive
○ Customer v/s Beneficiary AML
○ EDD

8. Nuts & Bolts
● Transaction monitoring
○ Value, Purpose, Beneficiary, Payment method
○ Many to one
○ Placement & Layering
○ Patterns tracking
○ IP/Geolocation
○ EDD
● Reporting to FIU
○ What, When & How?
○ What is considered suspicious?

9. Global Nuances
● Global Regulations around KYC, AML, CTF
○ US - State by state licenses and regulation. Risk based approach to KYC/AML. Getting
banks to work with MSB is difficult
○ Canada - Federal regulation is quick & simple, access to banking is difficult. KYC/AML
is prescriptive
○ UK - FCA is most progressive in terms of regulations, banking access is pretty good as
well.
○ India - No regulatory provision for non-banks in cross-border business payments.
○ Singapore - Risk based approach to KYC & AML, Fintech friendly regulation, decent
access to banking
● FIU reporting variance in what & when to report.

10. Tools & Platforms - What & How to pick
● AML:
○ iComplyKYC - all-in-one AML software for fintechs
○ SmartSearch - one-stop-shop for AML
○ FileInvite - automation for collecting AML documents
○ Dow Jones - Watchlist + Adverse Media reports
○ Accuity - AML + Watchlist
○ WorldCheck
● KYC:
○ RDC Customer Screening - automates checking PEPs, sanctions, adverse media
○ Sumsub - one of the leaders in Central/Eastern Europe and Asia
○ ACE - offers a configurable workflow
○ Trulioo - Individual + Entity KYC + AML
○ GIACTS - Company profile USA
○ SecureFacts Legal Entity Validator - Canada
○ Alloy - Individual + Company profiles
○ Berbix - Individual ID checks

11. REMITR Stack
● KYC & AML
○ ID Verification - proprietary + Third party tool for Photo ID document verification + Selfie
& Liveness check
○ Incorporation - access to company registry in Canada (Third party API)
○ Credit file checks - Credit rating agency
○ Watchlist/PEP/Media reports database - Third party
○ Proprietary Risk scoring
○ Proprietary transaction monitoring
○ EDD process
● Going beyond
○ IP/Geolocation tracking & flagging
○ Tracking of customer communications and seeking patterns
○ Identity theft and other fraud prevention

12. Questions?
@kanchankumar