KYC Policy
Version 1.0 as of December 15, 2025
1. Introduction
This KYC Policy sets out the principles and procedures adopted by UP-X (hereinafter “the Company”, “We”, “Us”) to verify the identity, age, and residence of users, in order to prevent money laundering, terrorist financing, and other financial crimes.
All users accessing or using the Platform are required to comply with this KYC Policy. Failure to provide the necessary information or documentation may result in restricted access, suspension, or termination of services.
This Policy ensures that:
Users are accurately identified and verified;
Transactions are monitored for suspicious activity;
The Platform operates in compliance with applicable AML regulations and international standards, including FATF recommendations;
High-risk users, including Politically Exposed Persons (PEPs), are subject to enhanced scrutiny.
This Policy applies to all users of the Platform and all interactions where the Company is required to collect and verify user information.
The Company is fully committed to complying with:
Local AML and Counter-Terrorist Financing (CTF) regulations;
FATF guidelines and international best practices for financial crime prevention.
2. Principles and General Provisions
The Company may, at any time, request any documentation or information necessary to verify the identity, residence, and legitimacy of a User on the Platform. In line with this, the Company may take the following measures:
A) Access Restrictions: The Company may temporarily suspend, limit, or restrict access to certain services, including deposits, withdrawals, payments, or gaming features, until the User’s identity and verification process are fully completed. Such restrictions may also be applied in cases of incomplete information, suspected fraudulent activity, or potential non-compliance with applicable laws and regulations.
B) Risk-Based Monitoring: The Company implements a risk-based approach to continuously assess User activity. This includes reviewing transaction patterns, account behavior, and any anomalies that may indicate potential risks of money laundering, fraud, or other illicit conduct. The geographical location of Users, particularly in higher-risk jurisdictions, is also monitored.
C) Enhanced Due Diligence (EDD): Users identified as high-risk, due to location, transaction behavior, or other factors, are subject to Enhanced Due Diligence. This may involve additional verification steps, requesting supplementary documentation, independent third-party checks, and closer scrutiny of the source of funds, especially for large or unusual transactions.
D) Source of Funds Verification: Where there is suspicion or indication that funds originate from unlawful activities, or where User activity is considered high-risk, the Company may require documentation to substantiate the legal origin of funds. Acceptable evidence may include financial statements, income records, bank statements, or other documentation confirming legitimate earnings.
E) Transaction Oversight: All transactions are monitored for signs of suspicious or unusual activity indicative of financial crime. Transactions exceeding established thresholds or originating from high-risk jurisdictions are subject to enhanced review. Any transactions deemed suspicious are reported to the relevant authorities in accordance with local and international regulatory obligations, including filing of Suspicious Activity Reports (SARs) when required.
3. KYC Documentation Requirements
In addition to the general verification procedures, all Users requesting withdrawals or conducting transactions deemed unusual or suspicious are required to complete the full Know Your Customer (KYC) process. During this process, Users must provide basic personal information and submit the following documentation:
1. Government-Issued Photo ID
Purpose: To confirm the User’s identity and ensure that registration details match official records.
Requirements:
Validity: ID must be valid and unexpired for at least 3 months from submission.
Legibility: All text, images, and signatures must be clearly visible.
Matching Information: Name, date of birth, and other personal details must match the registration information.
Age Verification: Must confirm that the User is over 18 years of age.
Front and Back Copies: Depending on the ID type, both sides may be required.
Accepted Forms: Passports, national identity cards, driver’s licenses, or other government-issued photo IDs.
Non-compliance: Failure to provide a valid ID may result in delays or inability to complete the verification process.
2. Selfie with ID Document
Purpose: To verify that the User submitting the ID is the same person depicted in the document.
Requirements:
Clarity and Quality: Image must be clear, well-lit, and allow identification of both the User and the ID.
Unobstructed Face: No sunglasses, hats, or accessories covering the face.
Current Appearance: Should reflect the User’s current look (preferably taken within the last 3 months).
Visible ID Details: All text and images on the ID must be fully readable.
Neutral Background: Background should not distract from the User and the ID.
Non-compliance: Failure to meet these criteria may delay or prevent completion of KYC verification.
3. Proof of Residence
Purpose: To confirm the User’s residential address.
Accepted Forms:
Bank statements from a recognized financial institution.
Utility bills (electricity, water, gas, internet).
Requirements:
Must clearly show the User’s name and residential address.
Address must match registration information.
Document date must be within the last 3 months.
Must be clear and legible; damaged, obscured, or unclear documents will not be accepted.
Non-compliance may result in delays or inability to complete KYC verification.
Document Submission
Users can provide the required documents through:
1. Email Submission: Sending documents to the designated support email.
2. Other Methods: Subject to mutual agreement and regulatory compliance.
All submissions must adhere to the requirements above. Failure to provide valid documentation may result in temporary restrictions, suspension of transactions, or refusal of service until verification is complete. These measures ensure compliance with regulatory obligations, maintain the integrity of the Platform, and protect both Users and the Company from fraud.
4. Record-Keeping and Risk Management
Data Retention
All KYC documentation, verification logs, transaction records, and Suspicious Activity Reports (SARs) are retained for a minimum of five (5) years from the date of collection or creation, or longer if required by applicable law or regulatory obligations. Retention periods ensure compliance with legal requirements and enable effective audit and investigation procedures.
Secure Storage
All records are maintained in a secure manner, including:
Encryption of digital records to prevent unauthorized access;
Access controls ensuring only authorized personnel can view sensitive data;
Physical security measures for any hard-copy documents, where applicable.
These measures are designed to protect user information, prevent data breaches, and maintain the integrity of the verification process.
Risk Assessment
Users and their transactions are continuously assessed and categorized based on risk levels:
Low Risk: standard verification and routine monitoring;
Medium Risk: increased monitoring and periodic review;
High Risk: subject to Enhanced Due Diligence (EDD), including detailed verification, source-of-funds checks, and more frequent transaction monitoring.
Risk assessment helps detect suspicious activity, prevent financial crime, and ensure compliance with applicable AML regulations.
AML Compliance Officer
A dedicated AML Compliance Officer is responsible for overseeing all aspects of KYC and AML compliance, including:
Verification procedures and ongoing monitoring;
Reporting suspicious transactions to relevant authorities;
Conducting internal audits and risk assessments;
Ensuring that all staff follow AML policies and procedures.
The Compliance Officer acts as the primary point of accountability for regulatory adherence and internal control, ensuring that all activities are documented, monitored, and auditable.
5. Prohibited Countries
Due to regulatory requirements, the Company cannot accept applications or documents from Users residing in high-risk locations, in compliance with regulatory obligations. Such Users will not be able to complete registration, verification, or any financial transactions on the Platform. The Company appreciates your understanding and compliance with these restrictions.
6. Policy Review and Updates
This KYC Policy is periodically reviewed and updated. Any updated version becomes effective immediately upon publication on the Platform. Continued use of the Platform after publication constitutes acceptance of the revised Policy.
7. Contact Information
For questions or clarifications regarding KYC procedures, users may contact our compliance team at: support@xp5byq04u.life.