KNOW YOUR COUNTERPARTY (KYC) COMPLIANCE POLICY STATEMENT

At  wingu, we are committed to upholding the highest standards of integrity, transparency, and regulatory compliance in all our operations. This Know Your Customer (KYC) Compliance Policy reflects our dedication to preventing and mitigating risks associated with money laundering, fraud, and other financial crimes. Our KYC procedures are designed to foster a secure and trustworthy business environment.

  1. Purpose and Scope:
    This policy outlines our approach to conducting thorough counterparty due diligence as part of our commitment to KYC compliance. It serves as a guiding framework for interactions with customers and counterparties.
  2. Counterparty Identification:
    We will obtain and verify the identity of our counterparties through reliable sources, collecting relevant information and applicable identification documents. Enhanced due diligence measures will be taken for higher-risk counterparties, ensuring a robust assessment of their backgrounds.
  3. Risk Assessment:
    We will categorize our counterparties based on their risk profiles, considering factors such as geographic location, nature of business, and transaction volume. These risk assessments will guide the intensity of due diligence measures applied to each counterparty category.
  4. Ongoing Monitoring:
    We are committed to continuous monitoring of transactions and activities to detect any unusual or suspicious behavior. Our monitoring systems will be regularly updated to adapt to emerging risks and regulatory changes.
  5. Record Keeping:
    All identification and transaction records will be accurately maintained and securely stored as required by applicable regulations. These records will be readily accessible for internal and external audits, as well as regulatory examinations.
  6. Training and Awareness:
    Regular training programs will be conducted to ensure that all employees are knowledgeable about our KYC policies and procedures. Employees will be informed of the importance of identifying and reporting suspicious activities promptly.
  7. Reporting Suspicious Activities:
    Employees are obligated to report any suspicious activities or transactions that may indicate money laundering, fraud, or other criminal behavior. Reporting channels have been provided to facilitate the timely communication of such concerns.
  8. Cooperation with Authorities:
    We will cooperate fully with relevant authorities, such as law enforcement and regulatory agencies, in investigations related to money laundering, fraud, and other financial crimes. This includes sharing information, providing records, and assisting in legal proceedings as required by law.
  9. Periodic Review and Updates:
    This KYC Compliance Policy will be reviewed periodically to ensure its effectiveness and alignment with changing regulatory requirements. Updates will be made as necessary to reflect the evolving landscape of financial crime risks.

    10. At wingu, we view KYC compliance as a cornerstone of our commitment to ethical business practices. By adhering to this policy, we aim to maintain the trust and confidence of our customers, partners, and stakeholders while contributing to the integrity of the global financial system.