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For the purpose of Etana’s KYC policy a ‘Customer’ is defined as a person or entity that maintains an account and/or has a business relationship with Etana; beneficiaries of transactions conducted by professional intermediaries such as Introducing Brokers (IB’s), Account Managers, Money Managers or solicitors, as permitted under the law; or any person or entity connected with a financial transaction which can pose significant reputational or other risks to Etana.
The Customer Acceptance Policy requires all customers or potential customers to fill in the Etana Application Form to capture the relevant data for all categories of customers and provide supporting documents as given in the form as a part of customer identification process / KYC.
All customers would be included under this policy with the exception when scheduled commercial banks and select regulated financial institutions.
Further, Etana customers will be categorized based on perceived risk, into three categories - A, B & C.
A. High Risk – (Category A)
B. Medium Risk – (Category B)
C. Low Risk – (Category C)
Customer identification means identifying the customer and verifying his/her identity by using reliable, independent, data or information. Etana shall obtain sufficient information necessary to verify the identity of each new customer along with brief details of its promoters and management, whether regular or occasional and the purpose of the intended nature of business relationship. The requirement as mentioned herein may be moderated according to the risk perception.
Monitoring of transactions will be conducted taking into consideration the risk profile of the account. Etana shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified, Special attention will be paid to all complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose.