KYC POLICY

For KYC (Know Your Customer) purposes, a client is defined as:

• An individual or organization that holds an account or has a business relationship with HalbergFin, including the ultimate beneficial owner.
• Recipients of transactions carried out by authorized intermediaries, such as brokers, accountants, or legal professionals, as allowed by law.
• Any party involved in a financial transaction that could present reputational or other risks to HalbergFin, such as large wire transfers or high-value single transactions.

Our KYC policy covers eight essential areas: customer identification, transaction monitoring, risk assessment, staff training, internal controls, record retention, regular audits of KYC procedures, and clear assignment of responsibilities. KYC documents must be submitted within four business days of account activation; otherwise, HalbergFin reserves the right to close all open trades and limit future activity.

HalbergFin has implemented a robust KYC program with clear procedures and effective oversight. This includes strong management supervision, reliable systems and controls, separation of duties, ongoing training, and clear accountability. Specific roles are assigned to ensure all policies and procedures are followed throughout the company.

The level of due diligence required depends on the risk profile of each client. Our internal audit and compliance teams play a key role in reviewing and ensuring adherence to KYC standards. Compliance independently evaluates our policies and ensures all legal and regulatory obligations are met. Auditors are trained in KYC requirements and regularly check that procedures are properly applied at all branches and offices, reporting any issues found.

FOR MORE DETAILS ON DOCUMENT REQUIREMENTS, PLEASE VISIT OUR COMPLIANCE PAGE.