Know Your Customer (KYC) Policy

Know Your Customer (KYC) Policy - ID Shipping Agency

1. Purpose

The purpose of this Know Your Customer (KYC) Policy is to define the principles, procedures, and controls adopted by ID Shipping Agency (“the Company”) to identify, verify, and assess the risk profile of its clients, vessels, and business partners.

This Policy aims to prevent the Company from being involved—directly or indirectly—in money laundering, terrorist financing, sanctions violations, fraud, or other illicit activities, while protecting the Company’s legal standing and reputation.

2. Scope

This Policy applies to all services provided by ID Shipping Agency, including but not limited to:

1. Ship agency services
2. Port and shipyard agency operations
3. Turkish Straits (Bosphorus & Dardanelles) transit services
4. Crew change, CTM, logistics, and maritime support services
5. Vessel, cargo, and trade-related transactions

The Policy applies to all clients, counterparties, vessels, beneficial owners, and third parties involved in Company operations.

3. Regulatory Framework

ID Shipping Agency conducts KYC checks in accordance with applicable national and international regulations and industry best practices, including:

1. Anti-Money Laundering (AML) regulations
2. Counter-Terrorist Financing (CTF) regulations
3. International sanctions regimes (OFAC, EU, UN, UK)
4. Maritime industry compliance standards
5. Banking and P&I Club compliance expectations

4. KYC Principles

ID Shipping Agency applies the following core KYC principles:

1. Know who we are doing business with
2. Verify the identity and legitimacy of clients and counterparties
3. Identify beneficial ownership and control structures
4. Assess and classify risk before and during business relationships
5. Apply enhanced due diligence where higher risk is identified
6. Maintain accurate and up-to-date records

5. Client Identification & Verification

Prior to commencing a business relationship, the Company may collect and verify the following information, as applicable:

1. Corporate Clients
2. Legal entity name and registration details
3. Registered address and country of incorporation
4. Trade registry documents
5. Tax identification number
6. Authorized signatories
7. Individual Clients
8. Full name
9. Nationality
10. Valid identification document (passport / ID)

6. Beneficial Ownership

The Company takes reasonable measures to identify the ultimate beneficial owner(s) of corporate clients.

This includes:

1. Reviewing ownership and control structures
2. Identifying individuals who ultimately own or control the entity
3. Ensuring no sanctioned or high-risk individuals are involved

7. Vessel Due Diligence (Maritime-Specific KYC)

For shipping-related services, ID Shipping Agency performs vessel-related checks, including:

1. Vessel name, IMO number, and flag
2. Owner, manager, and operator details
3. Sanctions and blacklist screening
4. Trade routes and operational history
5. Risk indicators related to shadow fleet or high-risk operations

8. Cargo & Trade Risk Assessment

Where applicable, the Company assesses:

1. Nature of the cargo
2. Origin and destination
3. Trade routes
4. Potential restricted or dual-use goods

Transactions involving higher-risk cargoes or destinations may be subject to enhanced review or rejection.

9. Risk Classification

Clients, vessels, and transactions are classified into risk categories:

1. Low Risk
2. Medium Risk
3. High Risk

Higher-risk relationships may require:

1. Additional documentation
2. Enhanced due diligence
3. Senior management approval
4. Ongoing monitoring

10. Ongoing Monitoring

KYC is an ongoing process. ID Shipping Agency continuously monitors:

1. Changes in client ownership or control
2. Vessel status and trading patterns
3. Regulatory and sanctions updates

The Company reserves the right to request updated documentation at any time.

11. Refusal and Termination of Business Relationships

ID Shipping Agency reserves the right to refuse to establish or to terminate a business relationship if:

1. KYC information is incomplete or misleading
2. A client or vessel is linked to prohibited or high-risk activities
3. There is a risk of sanctions or regulatory breach

12. Record Keeping

All KYC-related records are maintained securely in accordance with applicable legal and regulatory retention requirements.

13. Roles and Responsibilities

Senior Management is responsible for ensuring effective implementation of this Policy.

Compliance Function oversees KYC checks and risk assessments.

Employees must comply with KYC procedures and report any concerns promptly.

14. Policy Review

This Policy is reviewed periodically and updated as necessary to reflect regulatory developments and operational changes.