Know Your Customer (KYC) Policy

1. Introduction

1.1. Blaze Trail Management Limited (the/our “Company”) is committed to ensuring the highest standards of integrity and compliance with legal and regulatory requirements.

1.2. The present Know Your Customer (KYC) Policy outlines the procedures for verifying the identity of Company’s customers to prevent illegal activities such as money laundering, terrorist financing, and fraud.

2. Purpose

2.1. The purpose of this Policy is for the Company to ensure compliance with the UK’s anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.

2.2. The KYC Policy protects the Company from being used as a vehicle for illegal activities and thus ensure the integrity and reputation of the Company.

3. Scope

3.1. This Policy applies to all employees, directors, and officers of the Company who are involved in the customer onboarding and due diligence processes.

4. Customer Due Diligence (CDD)

4.1. Standard CDD

For all customers, the Company shall:

• Obtain and verify the customer’s identity using reliable, independent source documents, data, or information.
• Collect and maintain records of the customer’s identification documents.
• Understand the nature of the customer’s business and their source of funds.

4.2. Enhanced Due Diligence (EDD)

• Enhanced Due Diligence is required in higher-risk situations, including but not limited to Customers with high-risk profiles (e.g., politically exposed persons, high-net-worth individuals), transactions involving high-risk countries or jurisdictions and complex or unusually large transactions.
• In such cases, the Company shall perform additional checks to understand the source of wealth and funds, obtain information on the purpose of the business relationship and monitor the business relationship more closely.

5. Identification & Verification Procedures

5.1. Individual Customers

For individual customers, the Company shall:

• Collect and verify personal information including full name, date of birth, and address.
• Obtain a government-issued identification document (e.g., passport, driving license).
• Verify the address using a utility bill or bank statement.

5.2. Corporate Customers

For corporate customers, the Company shall:

• Obtain and verify the company's registration details and business address.
• Identify and verify the individuals who own or control the company.
• Verify the identity of the individuals who are authorized to act on behalf of the Company.

6. Risk Assessment & Management

6.1. Blaze Trail Management Limited will conduct a risk assessment of each customer and their transactions.

6.2. Based on the risk assessment, Company shall determine the level of due diligence required.

6.3. Higher-risk customers will undergo more rigorous scrutiny and enhanced due diligence procedures.

7. Record Keeping

7.1. The Company will maintain records of all customer identification documents and due diligence measures for a minimum of five years from the end of the business relationship.

7.2. These records will be readily accessible for inspection by regulatory authorities.

8. Training & Awareness

8.1. The Company will provide regular training to employees on KYC and AML requirements.

8.2. Employees will be informed of their responsibilities and the procedures for reporting suspicious activities.

9. Reporting Suspicious Activities

9.1. Employees must report any suspicious activity or transactions to the Line Manager immediately.

9.2. The Line Manager will assess the situation and, if necessary, file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).

10. Review & Updates

10.1 This Policy will be reviewed annually or as required to ensure compliance with changes in regulations and industry best practices.

10.2 Any amendments will be communicated to all employees.

11. Contact

11.1. For any enquiries and/or further information regarding this Policy, please do not hesitate to contact us at info@blazetrailmanagement.co.uk.

Reviewed & Approved: November 2024