Know Your Customer (KYC) Policy
Effective Date: August 21st, 2025
Company: Real Labs FZCO
Jurisdiction: Dubai Multi Commodities Centre (DMCC), United Arab Emirates
1. Introduction
Real Labs FZCO (“Real Labs,” “we,” “our,” or “us”) is committed to preventing financial crime and ensuring compliance with applicable UAE AML/CFT laws and DMCC regulations. As part of this commitment, we maintain a Know Your Customer (KYC) Policy that outlines how we verify the identity of clients, partners, and other relevant parties who interact with our Services.
This policy supports our broader Anti-Money Laundering (AML) framework and establishes procedures for identifying, verifying, and monitoring the identification, verification, and monitoring of business relationships.
2. Purpose
The objectives of this KYC Policy are to:
Ensure compliance with UAE Federal AML/CFT regulations and international standards (FATF).
Prevent the misuse of Real Labs software and services for illicit activities.
Maintain transparency and trust with our stakeholders.
Identify and mitigate risks associated with money laundering, terrorist financing, and fraud.
3. Scope
This policy applies to:
All clients and business partners engaging with Real Labs in any financial or contractual capacity.
All employees, contractors, and directors of Real Labs who participate in onboarding or compliance processes.
Any blockchain-based products or services that require user identity verification under applicable law.
4. Customer Identification Program (CIP)
As part of our KYC obligations, Real Labs will collect and verify the following (as applicable):
a. For Individuals
Full legal name
Date of birth
Nationality and country of residence
Valid government-issued identification (passport, Emirates ID, or equivalent)
Proof of address (e.g., utility bill, bank statement)
b. For Legal Entities
Company name and legal form
Registration/incorporation documents
License details (if applicable)
Identity of directors and authorized representatives
Ultimate Beneficial Owner (UBO) information
5. Risk-Based Verification
Real Labs applies a risk-based approach (RBA) to KYC, including:
Standard Due Diligence (SDD): Applied to low/medium-risk clients and transactions.
Enhanced Due Diligence (EDD): Applied to high-risk clients, Politically Exposed Persons (PEPs), and entities from high-risk jurisdictions.
Ongoing Due Diligence: Continuous monitoring of customer relationships to detect suspicious activity.
6. Sanctions and Watchlist Screening
All customers and counterparties will be screened against:
UAE Central Bank sanctions lists.
International sanctions databases (UN, OFAC, EU).
Lists of Politically Exposed Persons (PEPs).
Any positive match will result in an escalated review and may lead to the rejection of the business relationship.
7. Record-Keeping
Real Labs will retain KYC records, including identification documents and verification data, for a minimum of five (5) years after the termination of the business relationship or as otherwise required by UAE law.
Blockchain-based activity records may remain permanently on public networks and cannot be altered or deleted.
8. Training and Awareness
All relevant staff will receive training on:
KYC requirements under UAE law.
Identifying suspicious or unusual activity.
Escalation and reporting procedures.
9. Prohibited Relationships
Real Labs will not establish or maintain relationships with:
Anonymous or fictitious clients.
Individuals or entities on international sanctions lists.
Shell banks or entities that lack a physical presence or adequate supervision.
Clients refusing to provide the required KYC information.
10. Escalation and Reporting
Suspicious activity identified through KYC processes will be reported to the AML Compliance Officer for further review and, where required, escalated to the UAE Financial Intelligence Unit (FIU).
11. Review and Updates
This KYC Policy will be reviewed annually and updated as needed to reflect:
Changes in UAE regulations or international standards.
Updates to Real Labs’ products and business model.
Evolving risks in blockchain and digital asset industries.
12. Contact Information
For questions about this KYC Policy, please contact:
AML/KYC Compliance Officer
Real Labs FZCO
Dubai, United Arab Emirates
Email: [email protected]
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