Know Your Customer (KYC) Policy

At Verity Spurt, we are committed to fully complying with all Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations. This protects our bank, customers, and the overall financial system against risks of money laundering and terrorist financing activities.

Customer Identification Program When opening a new account, we require customers to provide the following information:

• Full legal name
• Date of birth
• Physical residential address
• Social Security Number or other government ID

We use this information to verify each customer’s identity through non-documentary and documentary methods such as:

• Comparing identification documents to non-public data sources
• Analyzing activity to identify suspicious patterns
• Screening names against government sanction lists

We may also require additional documentation to properly verify identity, such as:

• Recent utility bills or financial statements
• A clear photograph or non-resident alien documentation

We will not open an account or conduct transactions until we successfully verify the customer’s identity to our standards.

Customer Due Diligence Verity Spurt conducts ongoing due diligence on our customer base by:

• Monitoring transactions for suspicious activity
• Keeping customer information up-to-date
• Identifying high-risk customers for enhanced due diligence

Higher-risk scenarios that require enhanced due diligence include:

• Customers from higher-risk industries or geographies
• Politically exposed persons
• Those with higher risk investment or transaction patterns

Anti-Money Laundering (AML) Policy

Verity Spurt maintains robust AML controls, including:

Transaction Monitoring We use sophisticated behavioural analytics software to detect potentially suspicious transactions. This covers activities like:

• Large cash deposits/withdrawals
• Frequent funds transfers to high-risk regions
• Attempts to evade reporting requirements
• Unexplained spikes in transactional activity

Suspicious Activity Reporting Any cases of potentially suspicious activity are promptly investigated per regulatory requirements. If reasonable grounds are found, we file a Suspicious Activity Report with the appropriate authorities within 30 days.

Sanctions Compliance We screen all customers and transactions against the Office of Foreign Assets Control (OFAC) sanctions lists, including:

• Specially Designated Nationals (SDN) list
• Foreign Sanctions Evaders list
• Sectoral Sanctions Identifications list

Any true matches are blocked or rejected prior to transacting.

Record Keeping We maintain all books, records and identification documents related to customers and transactions for at least 5 years as required by the Bank Secrecy Act.

We have a Chief AML Officer responsible for ensuring our program is effectively managed. All employees receive periodic AML awareness training. We cooperate fully with any regulatory examinations or audits.