KYC Policy

Introduction

Skillzena LTD (Registration number 14816795, registration address: 85 Great Portland Street, First Floor, London, United Kingdom, W1W 7LT; office address: Unit 202-203, 1st floor Poultry Market, East Poultry Avenue, London EC1A 9LH), operating under the brand Cardgifters via website cardgifters.com is committed to maintaining the highest standards of integrity, transparency, and compliance within the gift card reselling industry. We have established this Know Your Customer policy in alignment with our dedication to regulatory requirements and legal standards.

Purpose

The purpose of this Know Your Customer policy is to ensure compliance with the relevant Money Laundering Regulations and legal requirements in the gift card reselling industry. The KYC procedures are applied for transactions involving purchasing gift cards valued at 500 EUR or more. This applies to all ways of purchasing: Buy for Myself, Buy for a Friend. 

Customer Identification

All customers engaging in gift card transactions exceeding 500 EUR must undergo thorough identification processes.

Before initiating any transaction, Skillzena LTD will obtain and verify essential customer information, including but not limited to:

  • Full legal name
  • Residential address
  • Date of birth
  • Contact details (phone number and email address)

The verification process involves the submission of valid documents:

Government-Issued ID:

  • Passport
  • UK Driving License
  • National Identity Card (if applicable)

Proof of Address:

  • Utility Bill (e.g., electricity, water, gas)
  • Bank Statement
  • Council Tax Bill

National Insurance Number:

  • Provide the National Insurance number, a unique identifier used for tax and social security purposes.

Proof of Income:

  • Payslip
  • P60 or P45
  • Tax Return (if self-employed)

Business Documentation (for business customers):

  • Companies House Registration Certificate
  • VAT Registration Certificate (if applicable)
  • Business Bank Statement

Customer Selfie:

  • A selfie of the customer holding their identification document for additional verification.

Corporate Clients:

  • Additional documentation: Articles of Incorporation, Business Registration, and information about beneficial owners may be necessary.

Additional Documents for Non-UK Residents:

  • Proof of Residency in the UK (if applicable)
  • Any required visa or immigration documentation

Skillzena LTD is committed to safeguarding the privacy and security of customer information during the identification process.

Customers must provide accurate and up-to-date information to facilitate a smooth and compliant transaction process. Any discrepancies or inconsistencies in the provided information may result in additional verification steps or the suspension of the transaction until the matter is resolved.

Skillzena LTD reserves the right to refuse or suspend transactions if a customer fails to meet the identification requirements outlined in this policy. This measure is in place to ensure the integrity of our operations and to adhere to legal obligations within the gift card reselling industry.

Document Verification

As part of Skillzena LTD’s commitment to robust Know Your Customer practices, customers engaging in gift card transactions exceeding 500 EUR must submit valid government-issued identification documents.

Customers must provide clear and legible copies of documents such as a passport, national ID card, or driver’s licence. The submitted documents should prominently display the customer’s photograph, full legal name, date of birth, and other relevant information.

Skillzena LTD employs approved verification methods to check the authenticity of the submitted documents. These methods may include but are not limited to, advanced document scanning technology and comparison against reputable databases.

The document verification process is designed to ensure the accuracy and legitimacy of customer information. Skillzena LTD is committed to safeguarding customer privacy during this verification process and will handle all submitted documents with the utmost confidentiality.

Customers are advised to submit clear and unaltered copies of their identification documents to expedite the verification process. In cases where discrepancies or irregularities are identified, Skillzena LTD may request additional information or take appropriate measures to resolve the matter in compliance with regulatory standards.

Risk Assessment

Skillzena LTD adopts a comprehensive risk-based approach to meticulously identify and assess the risk associated with customers engaging in gift card transactions exceeding 500 EUR. This approach is crucial for ensuring the integrity of our operations and complying with regulatory standards.

Categorization Criteria

Skillzena LTD establishes clear criteria for categorising customers based on various risk factors. These factors include but are not limited to:

  • Transaction volume: Assessing the monetary value of transactions within a specified timeframe.
  • Transaction frequency: Evaluating the frequency at which a customer engages in gift card transactions.
  • Customer behaviour: Analysing patterns and anomalies in customer behaviour during transactions.

Risk Categories

Based on the defined criteria, customers will be categorised into risk segments, such as low, medium, or high risk. Each category will prompt appropriate levels of scrutiny and due diligence.

Enhanced Due Diligence

High-risk customers, as identified through the risk assessment, will undergo enhanced due diligence. This involves additional verification steps and a more thorough examination of transaction details to mitigate potential risks.

Continuous Monitoring

Skillzena LTD implements continuous monitoring mechanisms to dynamically reassess customer risk levels over time. This ensures that risk categorizations remain current and reflective of evolving customer behaviour.

Documentation and Review

The risk assessment results, including customer categorizations and any subsequent EDD conducted, will be documented and periodically reviewed. This documentation serves as a record of compliance and is available for regulatory inspections.

Enhanced Due Diligence Procedures

Skillzena LTD places a strong emphasis on Enhanced Due Diligence to address the unique challenges posed by high-risk customers engaging in gift card transactions exceeding 500 EUR. EDD measures are implemented to ensure a more robust understanding of high-risk scenarios and to maintain compliance with regulatory standards.

High-Risk Triggers

Clear and predefined criteria are established to trigger EDD processes. These criteria are based on risk assessments and may include, but are not limited to:

  • Unusually high transaction volume or frequency.
  • Transactions involving certain high-risk jurisdictions.
  • Suspicious or inconsistent customer behaviour patterns.

Document Verification

High-risk customers undergoing EDD will be subject to more rigorous document verification processes. This may involve additional scrutiny of submitted identification documents, focusing on ensuring their authenticity and validity.

Transaction Scrutiny

EDD includes heightened scrutiny of transaction details associated with high-risk customers. This may involve examining transaction patterns, purpose, and counterparties to identify any potential irregularities or suspicious activities.

Ongoing Monitoring

EDD involves continuous monitoring of high-risk customers to identify and promptly respond to any changes in risk indicators. This ensures that Skillzena LTD remains proactive in addressing potential risks.

All EDD measures undertaken, including the rationale for applying EDD to specific customers, will be thoroughly documented. Skillzena LTD is committed to reporting such activities to relevant authorities by legal obligations in cases where suspicious activities are detected.

Skillzena LTD is dedicated to maintaining the highest standards of vigilance and compliance through continuous monitoring of customer transactions, particularly those exceeding 500 EUR. This ongoing monitoring is essential for promptly identifying any unusual or suspicious activities that may pose a risk to our operations.

Transaction Monitoring

Skillzena LTD employs advanced monitoring systems to scrutinise customer transactions in real-time. This includes analysing transaction volumes, patterns, and any deviations from established norms. Any transactions that raise concerns during this monitoring process will be subject to further investigation.

Periodic Customer Information Updates

To ensure the accuracy and relevance of customer information, Skillzena LTD conducts periodic updates. Customers engaging in transactions exceeding 500 EUR will be requested to provide updated information, including changes to personal details or contact information.

Automated Alerts and Notifications

Automated alerts are integrated into our monitoring systems to promptly notify relevant personnel of any identified anomalies or suspicious activities. These alerts trigger a rapid response to assess the situation and take appropriate actions.

Documentation of Monitoring Activities

All monitoring activities and their outcomes are documented comprehensively. This documentation serves as a record of ongoing compliance efforts and is available for regulatory inspections or audits.

Continuous Improvement

Skillzena LTD is committed to continuous improvement in monitoring processes, staying abreast of industry best practices, and adapting to emerging risks. Regular reviews of monitoring procedures are conducted to enhance the effectiveness of our KYC practices.

Record Keeping

Skillzena LTD places paramount importance on maintaining thorough records of customer identification and transaction details to uphold transparency and compliance within the gift card reselling industry, particularly for transactions exceeding 500 EUR.

Comprehensive Record Maintenance

All customer identification information, including documents submitted during the KYC process and transaction details, are meticulously recorded and stored securely and organised.

Retention Period

Records are retained for a specified period by applicable legal and regulatory requirements. The retention period ensures that Skillzena LTD can address any inquiries or audits that may arise during the defined timeframe.

Accessibility for Regulatory Inspections or Audits

Skillzena LTD is committed to ensuring all records are easily accessible for regulatory inspections or audits. Designated personnel are responsible for facilitating records retrieval promptly upon request from regulatory authorities.

Security Measures

Rigorous security measures are implemented to protect the confidentiality and integrity of stored records. Access to customer information is restricted to authorised personnel, and robust data protection protocols are maintained.

Data Integrity and Accuracy

Periodic reviews are conducted to verify the accuracy and integrity of stored records. Any discrepancies or inaccuracies are promptly addressed to maintain the reliability of the information.

Disposal Procedures

At the end of the specified retention period, records are disposed of by data protection and privacy regulations. Disposal procedures are designed to prevent unauthorised access or disclosure.

Staff Training

Skillzena LTD recognizes the critical role of well-informed and trained staff in maintaining effective Know Your Customer practices. To uphold the highest standards of compliance within the gift card reselling industry, particularly for transactions exceeding 500 EUR, Skillzena LTD is committed to providing ongoing training to staff involved in KYC processes.

Regular Training Programs

Scheduled and comprehensive training programs are conducted regularly to ensure staff members are well-versed in the latest regulatory requirements and industry best practices related to KYC.

Updates on Regulatory Changes

Staff members are informed of any changes in relevant laws and regulations about gift card reselling and financial transactions. This proactive approach enables Skillzena LTD to adapt its procedures to comply with evolving standards swiftly.

Identification of Suspicious Activities

Training enhances staff members’ ability to identify and assess suspicious activities during the KYC process. This includes recognizing red flags, understanding risk indicators, and taking appropriate actions in response to potential threats.

Practical Exercises and Case Studies

Training incorporates practical exercises and case studies to provide staff with real-world scenarios. This hands-on approach enhances their ability to apply KYC principles effectively.

Certification and Continuous Learning

Staff members involved in KYC processes are encouraged to undergo certification programs relevant to their roles. Additionally, Skillzena LTD promotes a culture of continuous learning, enabling staff to stay updated on emerging trends and technologies in the financial and compliance sectors.

Feedback Mechanism

A feedback mechanism allows staff to express concerns, seek clarification, and provide insights into potential improvements in KYC processes. This fosters a collaborative environment that enhances the overall effectiveness of our compliance efforts.

Reporting Suspicious Activities

Skillzena LTD is dedicated to maintaining a secure and compliant environment within the gift card reselling industry, particularly for transactions exceeding 500 EUR. A robust mechanism for reporting and escalating suspicious activities has been established to achieve this.

Mechanism for Reporting

All staff members must promptly report any identified or suspected suspicious activities. Skillzena LTD has implemented a designated reporting system that allows staff to escalate concerns to the appropriate personnel responsible for compliance oversight.

Escalation Protocols

Clear escalation protocols are in place to ensure that reported suspicious activities are promptly assessed and escalated to the relevant authorities as required by law. Skillzena LTD is committed to cooperating fully with law enforcement agencies and regulatory bodies in any investigations that may arise.

Legal Compliance

Skillzena LTD strictly adheres to all legal requirements regarding reporting suspicious activities. Staff members are trained to understand their obligations and the legal framework surrounding reporting, ensuring compliance with applicable laws and regulations.

Confidentiality and Whistleblower Protection

Skillzena LTD maintains strict confidentiality regarding the identity of staff members reporting suspicious activities. Whistleblower protection measures are in place to safeguard individuals who come forward with concerns about any form of retaliation.

Culture of Compliance and Vigilance

Skillzena LTD staff members. This involves fostering an awareness of the importance of KYC practices and each employee’s role in upholding our operations’ integrity.

Regular Training and Awareness Programs

Training programs include modules that emphasise the importance of reporting suspicious activities. Regular awareness programs reinforce the significance of staff vigilance in maintaining a secure environment.

Compliance Review

Skillzena LTD is committed to maintaining the highest standards of compliance within the gift card reselling industry, particularly for transactions exceeding 500 EUR. Skillzena LTD conducts regular reviews and audits of its KYC policy to ensure the effectiveness and relevance of our KYC practices.

Regular Policy Reviews

The KYC policy is subject to regular reviews to assess its alignment with changes in regulations and evolving industry best practices. Updates are made promptly to address any emerging requirements or enhance existing procedures.

Adaptation to Regulatory Changes

Skillzena LTD guidelines. The KYC policy is adjusted to ensure ongoing compliance with the latest legal and regulatory standards.

Internal Audits

Periodic internal audits are conducted to evaluate the implementation and effectiveness of the KYC policy. These audits are designed to identify areas of improvement, measure adherence to established procedures, and ensure that the policy is consistently applied across all relevant departments.

External Audits

In addition to internal audits, Skillzena LTD engages external audit firms to assess its KYC practices independently. External audits provide an unbiased evaluation of compliance efforts and offer valuable insights to strengthen our procedures further.

Documentation of Reviews and Audits

All reviews and audit activities, including findings and corrective actions, are documented comprehensively. This documentation records our commitment to maintaining a robust KYC framework and is available for regulatory inspections or audits.

Continuous Improvement

Feedback from reviews and audits drives continuous improvement in our KYC practices. Skillzena LTD is dedicated to evolving with the industry landscape, embracing technological advancements, and staying at the forefront of compliance excellence.

Customer Communication

At Skillzena LTD, transparency and customer understanding are paramount. To ensure a smooth and compliant process, we communicate our Know Your Customer requirements clearly to customers through this KYC policy page. If customers have questions, they can contact our support at [email protected]

Transparency in KYC Requirements

Customers engaging in transactions above the 500 EUR are informed of the necessity to comply with our KYC procedures. This includes the provision of accurate and up-to-date information during the identification process.

Communication Channels

Clear communication channels are established to convey KYC requirements to customers. This may include notifications on our platform, email communications, and dedicated customer support to address any queries related to the KYC process.

Importance of Accuracy

Customers are explicitly informed of the critical importance of providing accurate and truthful information during the KYC process. Accuracy is vital to ensuring the integrity of transactions and regulatory compliance.

Transaction Suspension

Failure to comply with KYC requirements may result in the suspension of transactions exceeding 500 EUR. Customers are made aware of this possibility, emphasising the need for proactive cooperation to facilitate a seamless and secure transaction experience.

User-Friendly Guidelines

To assist customers in meeting KYC requirements, Skillzena LTD provides user-friendly guidelines and instructions. This includes step-by-step processes for document submission and any additional information required for verification.

Responsive Customer Support

A dedicated customer support team is available to address customer queries and provide assistance throughout the KYC process. This ensures that customers can seek clarification or support as needed.

Regular Updates

Customers receive regular updates on any changes to KYC procedures, ensuring that they are kept informed of the latest requirements and expectations.

Legal Compliance

Skillzena LTD is dedicated to upholding the highest standards of legal compliance within the gift card reselling industry, particularly for transactions exceeding 500 EUR. Our commitment extends to staying informed about and adhering to all relevant national and international laws and regulations governing gift card reselling and financial transactions.

Continuous Regulatory Monitoring

Skillzena LTD actively monitors changes in national and international laws and regulations related to gift card reselling and financial transactions. This ongoing regulatory monitoring ensures our operations align with the latest legal requirements.

Legal Expertise and Consultation

Skillzena LTD engages legal experts and consultants to interpret and understand the implications of regulatory changes. This proactive approach enables us to swiftly adapt our policies and procedures to maintain compliance with evolving legal standards.

Implementation of Regulatory Changes

Skillzena LTD promptly implements necessary adjustments to its policies, procedures, and operational practices upon identifying any changes in relevant laws or regulations. This ensures that our activities consistently meet or exceed legal requirements.

International Compliance Standards

In addition to compliance with national laws, Skillzena LTD adheres to international standards and regulations governing financial transactions and gift card reselling. This commitment extends to any applicable cross-border transactions.

Legal Documentation and Records

Skillzena LTD maintains comprehensive documentation of legal compliance efforts. This includes records of legal reviews, consultations, and any actions taken to address changes in the regulatory landscape. These records are available for scrutiny during audits or regulatory inspections.

Employee Training on Legal Compliance

Staff members at Skillzena LTD undergo regular training sessions to stay informed about legal requirements relevant to gift card reselling and financial transactions. This ensures that all employees know their responsibilities in maintaining legal compliance.