OUR COMMITMENT TO RESPONSIBLE ONBOARDING

Javis Holdings LLC is committed to maintaining commercially reasonable anti-money laundering (AML) and Know Your Customer (KYC) onboarding procedures. These procedures are designed to protect Javis Holdings LLC, our clients, our banking and service partners, and the broader financial system from being used for illegal purposes, including money laundering, terrorist financing, fraud, and sanctions evasion.
Our AML and KYC procedures are aligned with the standards of our UK affiliate, Sinda Corporation UK Limited, which is registered with His Majesty’s Revenue and Customs (HMRC) as an Anti-Money Laundering Supervised Trust and Company Service Provider under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), HMRC AML Supervision Registration Number XYML00000133841.

WHY WE COLLECT IDENTITY AND VERIFICATION DOCUMENTS

Prior to commencing any service engagement, we are required to verify the identity of our clients and to assess the nature, purpose, and intended nature of the proposed business relationship. This process helps us to: comply with applicable US federal and state AML/KYC obligations; assess the risk profile of potential client engagements; screen against applicable United States government sanctions lists and restricted party lists; ensure that our services are not used for any unlawful purpose; and maintain the integrity of our banking and service provider relationships.

DOCUMENTS REQUIRED — INDIVIDUAL CLIENTS

If you are an individual client, we may request the following documents. All documents must be current, valid, and legible:

• Passport (preferred) or national government-issued identity card — showing full name, date of birth, nationality, and photograph
• Where a passport is not available: driving licence (front and back) accompanied by a secondary form of identification
• Proof of residential address dated within three (3) months — acceptable documents include a utility bill (electricity, gas, water, or fixed-line telephone), bank statement, or official government correspondence showing your name and address
• Contact details: email address, telephone/WhatsApp number, and country of residence
• Occupation or business background: a brief description of your employment or business activities
• Source of funds: a description of the source of funds being used to pay for services and/or to capitalise the entity being formed, where applicable. For amounts above USD $10,000, documentary evidence may be requested (e.g. employment contract, payslip, company accounts, investment documentation, or bank statements)

DOCUMENTS REQUIRED — CORPORATE CLIENTS

If you are engaging on behalf of a company, partnership, trust, or other legal entity, we may request the following documents:

• Certificate of incorporation or equivalent official registration document
• Memorandum and Articles of Association, or equivalent constitutional document
• Register of directors — full names, nationalities, dates of birth, and residential addresses of all directors
• Register of shareholders/members — full names, nationalities, and percentage holdings of all shareholders or members
• Beneficial ownership chart or UBO declaration — identifying all individuals who ultimately own or control 25% or more of the entity (or a lower threshold where applicable)
• Proof of registered or business address — official correspondence, utility bill, or bank statement in the entity’s name dated within three (3) months
• Identity documents and proof of address for all directors and beneficial owners, as described under Individual Clients above
• Evidence of business activity: a description of the entity’s business activities, its principal markets, and the nature of the proposed services required from Javis Holdings LLC
• Bank reference or professional reference where required by the specific service

ENHANCED DUE DILIGENCE (EDD)

Enhanced due diligence may be applied where we assess that a client engagement presents a higher level of risk. Circumstances that may trigger enhanced due diligence include:

• The client is, or is connected to, a Politically Exposed Person (PEP) — defined as an individual who holds or has held a prominent public function, or a close associate or family member of such a person
• The client is based in, or the proposed company structure involves, a jurisdiction identified as high risk for money laundering or terrorist financing by the FATF, OFAC, or other applicable authority
• The proposed transaction or structure is complex, involves multiple offshore entities, or appears to have no clear legitimate commercial purpose
• The value or volume of the proposed transaction is unusually high relative to the client’s stated business profile
• Inconsistencies are identified in the information or documentation provided

In enhanced due diligence cases, we may request additional documentation including: source of wealth evidence (not just source of funds), contracts or invoices evidencing business transactions, tax returns or company accounts, licences and regulatory approvals relevant to the client’s business, and additional corporate chain documents for multi-layered structures.

SANCTIONS SCREENING

Javis Holdings LLC screens all prospective clients against applicable United States government sanctions lists, including the OFAC Specially Designated Nationals (SDN) List and the Consolidated Sanctions List maintained by the US Department of the Treasury’s Office of Foreign Assets Control. Services are not available to any person or entity on any applicable sanctions list, or located in any jurisdiction subject to comprehensive US sanctions or trade restrictions. By engaging our services, clients confirm and warrant that they are not subject to any such restriction.

ONGOING MONITORING

Our KYC obligations do not end at onboarding. We may periodically request updated documentation from clients, particularly for ongoing service relationships, multi-year engagements, or where changes in circumstance are identified. We may also conduct periodic screening of existing clients against updated sanctions and restricted party lists.

REFUSAL AND TERMINATION OF SERVICES

Javis Holdings LLC reserves the right to refuse to engage, suspend, or immediately terminate any service relationship — without refund of fees where work has already commenced — in the following circumstances:

• The client fails or refuses to provide required KYC documentation within a reasonable timeframe
• The client appears on any applicable US government sanctions list or restricted party list
• The client has provided false, misleading, or materially incomplete information
• We form a reasonable suspicion that the engagement may involve money laundering, terrorist financing, fraud, or any other illegal activity
• The client’s business activities are prohibited under applicable US federal or state law
• Continuation of the engagement would, in our reasonable opinion, expose Javis Holdings LLC to unacceptable legal, regulatory, or reputational risk

CONFIDENTIALITY OF KYC INFORMATION

All KYC and identity verification documentation provided to Javis Holdings LLC is treated as strictly confidential. We will not disclose your KYC documentation to unrelated third parties except as required by applicable law, legal process, or regulatory obligation, or as necessary to perform the services you have engaged us to provide. Please refer to our Privacy Policy at /privacy-policy for details of how we collect, use, store, and protect your personal data.

LEGAL DISCLAIMER

This AML/KYC policy page is provided for informational purposes only and describes the commercially reasonable onboarding procedures of Javis Holdings LLC. It does not constitute legal advice. Javis Holdings LLC is not a licensed law firm, bank, regulated financial institution, or government authority. All compliance procedures described herein are subject to periodic review and may be updated to reflect changes in applicable law, regulatory guidance, and industry best practice.