KYC / Customer Verification

KYC & Customer Verification Policy

PassCash
Effective Date: February 9, 2026


1. Purpose

The purpose of this Know Your Customer (KYC) and Customer Verification Policy is to establish procedures for verifying the identity of individuals, merchants, and agents using the PassCash platform. This policy supports PassCash’s commitment to preventing fraud, money laundering, terrorist financing, and other financial crimes, while complying with applicable laws and regulations in the Caribbean, the United States, and other jurisdictions where we operate.


2. Scope

This policy applies to:

  • Individual users
  • Merchants
  • Agents
  • Employees, contractors, and compliance personnel involved in onboarding and monitoring activities

It covers all PassCash services, including wallet usage, cashouts, currency exchange, escrow services, APIs, and merchant integrations.


3. Regulatory Framework

PassCash aligns its KYC practices with:

  • Financial Action Task Force (FATF) recommendations
  • Caribbean Financial Action Task Force (CFATF) standards
  • Applicable U.S. regulations, including the Bank Secrecy Act (BSA)
  • Local financial and data protection laws in operating jurisdictions


4. Customer Identification Requirements

4.1 Individual Users

Before accessing financial services, individual users must provide:

  • Full legal name
  • Date of birth
  • Residential address
  • Government-issued photo identification (passport, national ID, or driver’s license)
  • Proof of address (utility bill, bank statement, or similar document)

Verification may be conducted electronically or manually. Additional information may be requested based on risk level.


4.2 Merchants

Merchants using PassCash for payments or integrations must provide:

  • Legal business name and registration details
  • Business address and contact information
  • Certificate of incorporation or business registration
  • Identification of directors, owners, and authorized signatories
  • Beneficial ownership information for owners holding significant control
  • Nature of business and expected transaction activity


4.3 Agents

Agents participating in the PassCash agent network must provide:

  • Full legal name and contact details
  • Government-issued photo identification
  • Proof of address
  • Agent identification or assigned Agent ID (AID)
  • Bank or payout details where applicable

Agents are subject to enhanced review due to their role in cash-based transactions.


5. Risk-Based Approach

PassCash applies a risk-based approach to customer verification:

  • Low-Risk Customers: Standard KYC and periodic reviews
  • Medium-Risk Customers: Additional verification and monitoring
  • High-Risk Customers: Enhanced Due Diligence (EDD), including source of funds checks and ongoing monitoring

Risk factors include transaction volume, geography, customer type, and behavior patterns.


6. Ongoing Monitoring and Reviews

PassCash continuously monitors customer activity to ensure consistency with declared profiles. This includes:

  • Reviewing transaction patterns
  • Updating customer information periodically
  • Re-verifying customers when risk levels change
  • Monitoring dormant or unusual account activityz


7. Refusal, Suspension, and Termination

PassCash reserves the right to:

  • Refuse onboarding if verification requirements are not met
  • Suspend accounts pending verification or investigation
  • Terminate accounts involved in fraudulent or illegal activities

Customers may be required to re-submit documents at any time to maintain account access.


8. Data Protection and Confidentiality

All customer information collected under this policy is:

  • Stored securely
  • Used solely for compliance and operational purposes
  • Protected in accordance with applicable data protection laws

Access to KYC data is restricted to authorized personnel only.


9. Record Keeping

PassCash maintains records of:

  • Customer identification documents
  • Verification results
  • Risk assessments
  • Account and transaction history

Records are retained for the period required by applicable laws and regulations.


10. Employee Training and Awareness

Employees involved in onboarding and monitoring receive regular training on:

  • KYC requirements
  • Fraud detection
  • Regulatory obligations
  • Data privacy and confidentiality


11. Policy Review and Updates

This policy is reviewed periodically and updated as necessary to reflect changes in regulations, technology, or business operations.


12. Compliance Statement

All users, merchants, agents, and employees are required to comply with this KYC & Customer Verification Policy. Failure to comply may result in account restrictions, termination, or reporting to relevant authorities where required by law.

KYC / Customer Verification | PassCash