Know Your Customer (KYC) Policy

1Purpose & Regulatory Basis

Proxiware LLC operates this KYC Policy in furtherance of its obligations and commitments under applicable anti-money laundering (AML), counter-terrorism financing (CTF), and fraud prevention regulations. While Proxiware is primarily a technology services company and not a regulated financial institution under the U.S. Bank Secrecy Act (BSA), we voluntarily adopt rigorous KYC practices consistent with:

• The Bank Secrecy Act (BSA) and associated FinCEN guidance;
• The USA PATRIOT Act, including Customer Identification Program (CIP) principles;
• OFAC (Office of Foreign Assets Control) sanctions compliance requirements;
• EU Anti-Money Laundering Directives (4AMLD, 5AMLD, 6AMLD) where applicable to EU users;
• United Nations Security Council sanctions lists;
• Our payment processor compliance requirements (Stripe, Cryptomus).

The purpose of this Policy is to: (a) verify the identity of customers; (b) assess customer risk profiles; (c) detect and prevent the use of our Services for money laundering, terrorist financing, or other financial crimes; and (d) ensure compliance with applicable sanctions regimes.

2Scope & Applicability

This Policy applies to all users of Proxiware's Services, including individuals and legal entities. It governs all customer onboarding, account management, and ongoing transaction monitoring activities conducted by Proxiware LLC.

This Policy is incorporated by reference into Proxiware's Terms of Service. By using the Services, you acknowledge and agree to cooperate with our KYC procedures as required.

3Who Must Complete KYC

Proxiware applies a risk-based approach to KYC. Verification may be required in the following circumstances:

• Accounts that reach or exceed certain spending thresholds as determined by Proxiware;
• Accounts exhibiting unusual activity patterns or risk indicators;
• Accounts seeking access to high-volume or enterprise-tier proxy plans;
• Accounts from jurisdictions associated with elevated financial crime risk;
• Accounts flagged by automated fraud detection systems;
• Accounts subject to payment disputes or chargeback history;
• Any account that Proxiware determines, at its sole discretion, requires additional identity verification to satisfy its compliance obligations.

Proxiware may also require KYC verification for all new accounts as part of standard onboarding, at its discretion.

4Individual Verification Requirements

Individual users required to complete KYC must provide:

4.1 Primary Identity Document (one of the following)

• Valid government-issued passport;
• National identity card issued by a recognized government authority;
• Valid driver's license with photograph.

4.2 Proof of Address (one of the following, dated within 90 days)

• Utility bill (electricity, gas, water, internet);
• Bank statement from a regulated financial institution;
• Official government correspondence;
• Lease agreement or mortgage statement.

4.3 Liveness Verification

Proxiware may require a biometric liveness check or selfie verification processed through our KYC provider (Idenfy) to confirm the document presenter matches the submitted identification.

All documents must be legible, unaltered, and submitted in their full, unredacted form. Proxiware will reject incomplete, expired, or tampered documents.

5Business & Entity Verification Requirements

Legal entities (companies, partnerships, and other organizations) required to complete KYC must provide:

5.1 Entity Documents

• Certificate of Incorporation or equivalent formation document;
• Articles of Association or Operating Agreement;
• Current proof of registered business address;
• Employer Identification Number (EIN) for US entities, or equivalent tax identification for non-US entities;
• Evidence of current good standing (where applicable).

5.2 Ultimate Beneficial Owner (UBO) Information

All individuals who directly or indirectly own or control 25% or more of the entity must provide individual verification documents as described in Section 4. The entity must also identify all directors, officers, and authorized account representatives.

5.3 Additional Business Information

Proxiware may request additional information regarding the entity's business purpose, anticipated proxy usage, and the nature and volume of planned transactions.

6Risk-Based Approach

Proxiware employs a risk-based approach to KYC whereby the level of due diligence applied is commensurate with the assessed risk associated with the customer and the nature of the Services requested. Risk factors considered include:

• Geographic location and country of residence/operation;
• Volume and value of transactions;
• Industry or sector of activity;
• Source of funds;
• Nature and purpose of proxy usage;
• Previous account history and behavior;
• Results of sanctions and adverse media screening.

Customers assessed as higher-risk will be subject to Enhanced Due Diligence (EDD) as described in Section 7.

7Enhanced Due Diligence (EDD)

For customers deemed high-risk, Proxiware will conduct Enhanced Due Diligence, which may include:

• Additional identity document verification;
• Source of wealth and source of funds documentation;
• Detailed description of intended use cases;
• Enhanced ongoing transaction monitoring;
• Senior management approval before account activation;
• Periodic re-verification at intervals determined by Proxiware.

High-risk indicators include but are not limited to: residence in a FATF high-risk or monitored jurisdiction, association with industries or activities subject to heightened regulatory scrutiny, or patterns of activity inconsistent with stated purpose.

8Politically Exposed Persons (PEPs)

Proxiware screens all customers against PEP databases as part of its onboarding process. A Politically Exposed Person is an individual who holds or has held a prominent public position, or a close associate or family member of such a person.

Accounts associated with PEPs are subject to:

• Mandatory Enhanced Due Diligence;
• Senior management approval;
• Source of wealth verification;
• Enhanced ongoing monitoring.

Proxiware reserves the right to refuse or terminate service to any PEP where the risk cannot be adequately mitigated.

9Sanctions Screening

Proxiware screens all customers and transactions against applicable sanctions lists, including:

• OFAC Specially Designated Nationals and Blocked Persons List (SDN List);
• OFAC Consolidated Sanctions List;
• EU Consolidated Financial Sanctions List;
• UN Security Council Consolidated Sanctions List;
• UK HM Treasury Financial Sanctions List;
• Other applicable national and international sanctions regimes.

Proxiware will not provide Services to any individual or entity that appears on any applicable sanctions list, is located in or ordinarily resident in a comprehensively sanctioned country or territory, or is owned or controlled by a sanctioned party. Access from sanctioned jurisdictions is strictly prohibited and will result in immediate account termination and, where required, reporting to relevant authorities.

Comprehensively sanctioned jurisdictions currently include, but are not limited to: Cuba, Iran, North Korea, Russia (selected sectors), Syria, and the Crimea/Donetsk/Luhansk regions of Ukraine, as designated by OFAC.

10KYC Data Handling

KYC documents and verification data are processed in accordance with our Privacy Policy. Specifically:

• KYC documents are processed by our authorized verification provider, Idenfy, under a data processing agreement;
• Verification data is used solely for identity verification, fraud prevention, and legal compliance purposes;
• KYC documents are stored securely with access restricted to authorized compliance personnel;
• We do not use KYC data for marketing or share it with unauthorized third parties;
• You have the right to request information about how your KYC data is processed, subject to legal retention obligations.

11Refusal of Service

Proxiware reserves the right to refuse, limit, or terminate service to any customer in the following circumstances, without obligation to provide reasons:

• Failure or refusal to provide required KYC documentation within a reasonable time period;
• Submission of fraudulent, forged, or otherwise unacceptable documentation;
• Failure to pass sanctions or PEP screening;
• Assessment of unacceptably high risk based on KYC findings;
• Reasonable suspicion of money laundering, terrorism financing, or other financial crime;
• Operating in a prohibited jurisdiction or industry.

Where legally required, Proxiware may file a Suspicious Activity Report (SAR) with FinCEN or equivalent authority without notifying the customer (tipping-off prohibition).

12Ongoing Monitoring

Proxiware conducts ongoing monitoring of customer accounts and transactions. This includes:

• Automated monitoring of usage patterns for anomalies inconsistent with stated purpose;
• Periodic re-screening of customers against sanctions and PEP lists;
• Review of accounts upon triggering of risk-based thresholds;
• Periodic KYC refresh for high-risk accounts, typically every 12–24 months.

You are required to promptly notify Proxiware of any material changes to your identity information, business purpose, or ownership structure that may affect your KYC status.

13Record Retention

Proxiware retains KYC records in accordance with applicable legal requirements. Identity verification documents and associated records are retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later, as required by applicable AML regulations.

Records are stored securely and may be disclosed to competent authorities upon receipt of a lawful request.

14Contact

For questions regarding our KYC Policy, identity verification requirements, or your verification status, please contact our compliance team: