Zil Money is a financial technology company, not a bank or an FDIC member. Zil Money offers banking services through partnership with FDIC member banks Silicon Valley Bank, Texas National Bank, and East-West Bank.

CUSTOMER IDENTIFICATION PROGRAM MANUAL (“CIP MANUAL”)

 

INTRODUCTION:

At Zil Money, we recognize the paramount importance of establishing and maintaining a robust Customer Identification Program (CIP) to safeguard the integrity of our services and comply with regulatory requirements. This comprehensive CIP Manual serves as a guiding document that outlines our unwavering commitment to customer identification, anti-money laundering (AML) compliance, and adherence to industry standard international best practices. With a deep-rooted dedication to transparency, we have diligently crafted this manual to demonstrate our steadfast commitment to fulfilling the stringent demands of our banking and service partners, while also ensuring compliance with all applicable legal and regulatory frameworks.

1. Purpose of the CIP Manual:

The purpose of this CIP Manual is to articulate Zil Money’s tailored approach to identifying and verifying our valued customers in a meticulous and efficient manner. It serves as a definitive resource, equipping our employees with clear and comprehensive guidelines to execute the customer identification process accurately and effectively. The manual underscores our commitment to combatting money laundering and financial crimes, thereby fostering a secure and trustworthy environment for our customers and partners alike.

2. Scope and Applicability:

This manual sets forth the scope and applicability of our Customer Identification Program (CIP) at Zil Money. It encompasses all aspects of our customer identification procedures, including individual and corporate customers, as well as the identification and verification of beneficial owners of legal entities. The manual extends its purview to cover all departments and employees involved in the customer identification process, emphasizing the significance of consistent adherence to the CIP policies and procedures throughout our organization.

3. Legal and Regulatory Framework:

Incorporating a risk-based approach, our CIP Manual ensures strict compliance with the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations. We remain steadfast in upholding our responsibilities as a federally chartered financial institution and recognize the rigorous due diligence conducted by our partner banks before entering into any collaboration.

Through this CIP Manual, we reiterate our dedication to safeguarding our customers, mitigating risk, and adhering to the highest standards of compliance. By combining precision, transparency, and diligence, Zil Money is resolute in maintaining a resilient and dependable Customer Identification Program that fosters trust, security, and long-lasting partnerships with our valued stakeholders.

 

CUSTOMER IDENTIFICATION PROGRAM (CIP) OVERVIEW:

This section provides an in-depth overview of our CIP, encompassing the significance of customer identification, our objectives, and our risk-based approach to ensure rigorous compliance with regulatory requirements and industry best practices.

1. Importance of Customer Identification:

The identification and verification of our customers are of paramount importance in mitigating risks associated with financial crimes, including money laundering, terrorist financing, and other illicit activities. By accurately identifying our customers, we fortify our defenses against potential threats and ensure the utmost safety and confidentiality of financial transactions conducted through our platform. Our rigorous customer identification process bolsters trust and confidence in our services, fostering long-lasting relationships with our clientele.

2. Objectives of the CIP:

The primary objectives of our CIP are twofold. Firstly, we seek to adhere to legal and regulatory mandates set forth by the Bank Secrecy Act (BSA), Anti-Money Laundering (AML) regulations, and other relevant laws. Secondly, our CIP aims to safeguard our platform against fraudulent activities, unauthorized access, and potential breaches. By establishing and adhering to a robust CIP, we not only comply with regulatory requirements but also foster a secure environment that enhances the overall integrity of our services.

3. Risk-Based Approach to Customer Identification:

We adopt a risk-based approach to customer identification, recognizing that different customers may present varying levels of risk. Our comprehensive risk assessment process evaluates factors such as the type of customer, nature of transactions, geographical location, and industry. This approach enables us to allocate resources efficiently and prioritize due diligence measures for higher-risk customers, ensuring the effectiveness and efficiency of our customer identification procedures.

4. CIP and Compliance with Regulatory Requirements:

As a cutting-edge fintech platform, Zil Money is acutely aware of the critical importance of complying with all applicable legal and regulatory requirements. Our CIP is meticulously designed to meet and surpass these obligations, including those outlined in the Bank Secrecy Act (BSA), Anti-Money Laundering (AML) regulations, and other relevant laws. Our unwavering commitment to compliance further extends to fulfilling the stringent due diligence standards imposed by our partner banks, affirming our dedication to maintaining transparency and upholding industry best practices.

Through the comprehensive overview presented in this section, Zil Money underscores its dedication to customer identification as an essential tenet of our business operations. Our CIP embodies the core values of security, compliance, and transparency, ensuring that our platform remains at the forefront of the payment processing industry while safeguarding the interests of our valued customers and partners.

 

CUSTOMER IDENTIFICATION PROCEDURES:

At Zil Money, our Customer Identification Procedures are meticulously designed to ensure the accurate identification and verification of individual and corporate customers, in strict compliance with relevant laws, regulations, and industry best practices. This section outlines the comprehensive procedures we employ to ascertain the identity of our valued customers and entities, while leveraging a combination of manual processes and cutting-edge technology for enhanced efficiency and security.

1. Identifying Individual Customers:

(a) Information Collection and Verification:

For individual customers, we employ a stringent process of information collection and verification. During the account opening process, we gather essential identifying information, such as name, address, date of birth, and identification numbers, which includes government-issued IDs and Social Security Numbers (SSNs). The accuracy of the provided information is diligently verified through reliable sources to ensure the integrity of the identification process.

(b) Documentation Requirements:

To maintain thorough documentation, we maintain records of all customer identification information obtained during account opening and any subsequent updates. Customer identification documents, including government-issued IDs, are securely retained in accordance with legal and regulatory retention requirements.

2. Identifying Corporate Customers:

(a) Verification of Business Entities:

For corporate customers, we undertake a meticulous verification process to ascertain the legitimacy and authenticity of the business entity. This process includes gathering relevant information, such as the company’s legal name, physical address, and business registration details. We also verify the existence and good standing of the entity through official government registries or trusted third-party sources.

(b) Verification of Beneficial Owners:

In compliance with Anti-Money Laundering (AML) regulations, we identify and verify the beneficial owners of corporate entities. We obtain comprehensive details about these individuals, including names, addresses, dates of birth, and identification numbers. The verification process ensures that beneficial owners are not concealed or misrepresented, allowing us to adhere to our commitment to prevent financial crimes.

3. Methods for Customer Identification:

(a) Manual Process and Strategies:

Our customer identification process encompasses a combination of manual verification methods and risk-based strategies. Trained personnel conduct thorough due diligence and scrutiny to assess the level of risk associated with each customer. This risk-based approach enables us to allocate resources efficiently and apply the appropriate level of scrutiny to high-risk customers.

(b) Technology and Software Integration:

To enhance efficiency and accuracy, we integrate cutting-edge technology and software into our customer identification procedures. We leverage platforms like Alloy, Persona, and Yodlee for identity verification, biometric authentication, and financial data aggregation. By harnessing the power of technology, we ensure seamless onboarding and robust security measures.

(c) Government Watchlist Screening:

As part of our compliance measures, we perform regular screenings of customer identities against government watchlists, including the OFAC Specially Designated Nationals (SDN) List. Utilizing tools like Sift and IPQualityScore, we detect potential threats and promptly mitigate risks associated with prohibited transactions and illicit activities.

Through this systematic and dynamic Customer Identification Procedures, Zil Money remains committed to ensuring the integrity of our services, fostering a secure environment for all stakeholders, and upholding the highest standards of compliance in the payment processing industry.

 

CUSTOMER IDENTIFICATION PROGRAM (CIP) TRAINING:

At Zil Money, we recognize the critical role of well-trained employees in ensuring the effectiveness and compliance of our Customer Identification Program (CIP). As part of our commitment to maintaining a robust and secure environment, comprehensive training programs are provided to our employees, encompassing essential aspects of AML and BSA compliance, as well as proficiency in using CIP tools and software.

1. Training Requirements for Employees:

We place great emphasis on the ongoing education and training of our employees to equip them with the knowledge and skills necessary for effective customer identification and risk management. All relevant personnel involved in the customer identification process undergo rigorous training to understand the significance of their roles and responsibilities in maintaining a strong CIP framework.

2. AML and BSA Compliance Training:

To uphold the highest standards of Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) compliance, specialized training is provided to employees. This training covers the identification and reporting of suspicious activities, recognizing red flags, and adhering to regulatory guidelines. Employees are educated about the importance of staying vigilant in detecting potential money laundering and terrorist financing activities.

3. Training on Using CIP Tools and Software:

As part of our commitment to harnessing technology for efficient customer identification, employees receive comprehensive training on utilizing CIP tools and software. Training sessions are conducted to familiarize employees with the proper use of Alloy, Persona, Yodlee, Sift, IPQualityScore, and other proprietary tools. This ensures that our team can leverage these resources to their full potential, enhancing accuracy and expediency in customer identification.

Throughout the training process, our employees are encouraged to actively participate in continuous professional development to stay abreast of the latest industry trends, regulatory updates, and technological advancements. This proactive approach ensures that our Customer Identification Program remains adaptive, compliant, and robust in the face of evolving challenges and requirements.

By investing in the knowledge and expertise of our employees, Zil Money reinforces its commitment to maintaining a strong CIP, promoting a secure financial environment, and safeguarding the interests of our customers and partners.

 

RECORD KEEPING AND DOCUMENTATION:

Zil Money recognizes the paramount importance of maintaining accurate and comprehensive records to support our Customer Identification Program (CIP) and comply with applicable laws, regulations, and industry standards. This section outlines our robust record-keeping and documentation practices, ensuring the integrity and transparency of our customer identification process.

1. Data Retention Periods:

We adhere to strict data retention policies that dictate the periods for which customer identification records are to be retained. These retention periods are in accordance with relevant regulatory requirements and industry best practices. Customer identification data, including information collected during account opening and ongoing monitoring, is securely stored for the specified duration. Our data retention practices are designed to ensure compliance, facilitate audits, and support ongoing customer due diligence efforts.

2. Document Management and Access:

Zil Money implements secure document management systems to organize and store customer identification records. Access to these records is strictly controlled and restricted to authorized personnel on a need-to-know basis. Our robust security measures safeguard against unauthorized access, ensuring the confidentiality and privacy of customer data. As part of our commitment to transparency, we maintain a detailed log of employees who access customer identification information, enhancing accountability and traceability.

3. Reporting and Audit Requirements:

We recognize the significance of timely and accurate reporting to regulatory authorities and our banking partners. As such, we have in place a structured reporting process that facilitates the submission of required information. Our reports encompass customer identification activities, suspicious transaction reports, and any other relevant data needed to comply with regulatory mandates. Additionally, Zil Money undergoes periodic internal and external audits to assess the effectiveness and adherence of our CIP to regulatory requirements and industry standards.

 

INTEGRATION WITH SERVICE AND BANKING PARTNERS:

Zil Money recognizes the critical importance of seamless integration with our service and banking partners to ensure a robust and compliant Customer Identification Program (CIP). This section outlines our commitment to meeting the requirements and expectations of our partners, thus reinforcing our reputation as a trusted and compliant fintech platform.

1. Compliance with Service/Banking Partners’ Requirements:

As a responsible fintech platform, we understand the significance of meeting the specific requirements set forth by our service and banking partners. We diligently review and understand their compliance standards, due diligence criteria, and other relevant procedures. By incorporating their requirements into our CIP, we ensure alignment with their risk appetite and regulatory obligations. Our proactive approach to addressing partner-specific compliance standards fosters a collaborative and mutually beneficial relationship.

2. Meeting Service/Banking Partners’ Expectations:

Zil Money is committed to not only meeting but exceeding the expectations of our service and banking partners. By consistently adhering to the highest standards of customer identification and anti-money laundering practices, we demonstrate our dedication to maintaining a strong partnership. Our customer-centric approach and commitment to regulatory compliance instill confidence in our partners, reinforcing the trust they place in us.

3. Enhancing Zil Money’s Reputation as a Compliant Fintech Platform:

Integration with service and banking partners who prioritize compliance and risk management strengthens our position as a reputable and compliant fintech platform. By leveraging our established relationships, we can access cutting-edge technologies, innovative solutions, and a broader customer base. This integration enhances our ability to provide reliable and secure payment processing services, positioning us as a market leader in the industry. Zil Money remains resolute in our commitment to continuously improve our CIP, bolster our partnerships, and foster a reputation for excellence in regulatory compliance.

 

REVIEW AND UPDATES:

1. Periodic Review of CIP:

Zil Money recognizes the importance of conducting regular and comprehensive reviews of its Customer Identification Program (CIP) to ensure its effectiveness and compliance with applicable laws, rules, and regulations. The CIP will be subject to periodic reviews, conducted at least annually, or more frequently if deemed necessary by the Compliance Officer or any other relevant authority.

During the periodic review, the Compliance Officer will assess the adequacy and appropriateness of the CIP in light of any changes in the business environment, regulatory requirements, or industry best practices. The review process will encompass an examination of all relevant aspects of the CIP, including but not limited to customer identification procedures, risk assessment methodologies, data collection and verification processes, and the overall risk management framework.

2. Updating the CIP in Response to Regulatory Changes:

Zil Money is committed to promptly updating the CIP to reflect any changes in laws, rules, or regulations that may affect customer identification, risk assessment, or any other relevant aspect of the CIP. The Compliance Officer will diligently monitor regulatory developments at the national and international levels to identify any pertinent changes.

In the event of significant regulatory changes, the Compliance Officer will promptly initiate a review of the CIP to determine the necessary modifications. The updates will be implemented within a reasonable timeframe, and all relevant employees and stakeholders will be promptly notified of the changes and provided with any necessary training to ensure seamless implementation.

3. Ongoing Improvement and Best Practices Implementation:

Zil Money acknowledges the dynamic nature of the financial industry and the continuous evolution of money laundering and terrorist financing risks. As such, Zil Money is committed to ongoing improvement and implementation of international best practices in its CIP.

The Compliance Officer, in coordination with other relevant departments, will continually monitor the effectiveness of the CIP and seek opportunities for enhancement. This includes, but is not limited to, incorporating emerging technologies, refining risk assessment methodologies, and adopting industry-leading practices for customer due diligence and enhanced due diligence.

To ensure the consistent implementation of best practices, the Compliance Officer will maintain open communication channels with regulatory authorities, industry peers, and relevant professional associations. The insights gained from such collaborations will be utilized to drive improvements and strengthen the overall integrity of the CIP.

 

CONCLUSION:

1. Commitment to Customer Identification:

Zil Money reaffirms its unwavering commitment to maintaining a robust and effective Customer Identification Program (CIP) as a cornerstone of its efforts to combat money laundering, terrorist financing, and other illicit financial activities. Through the implementation of comprehensive customer due diligence procedures, Zil Money aims to establish the true identity of its customers, assess their risk profiles, and ensure that only legitimate and law-abiding individuals and entities are granted access to its financial services.

2. Upholding Compliance and Industry Standards:

In pursuit of the highest standards of compliance, Zil Money acknowledges the importance of adhering to all relevant laws, rules, and regulations pertaining to customer identification and anti-money laundering (AML) and countering the financing of terrorism (CFT) practices. The CIP has been developed in strict accordance with applicable legal requirements and is continuously updated to reflect changes in regulatory frameworks. Furthermore, Zil Money recognizes the significance of international best practices in the fight against financial crime. By incorporating industry-standard practices, Zil Money strives to stay ahead of evolving risks and emerging trends.

3. Future Directions for the CIP:

As the financial landscape continues to evolve, Zil Money acknowledges the need for constant vigilance and adaptation to emerging risks. The future of the CIP lies in embracing innovative technologies and data analytics to strengthen customer due diligence and risk assessment capabilities. Zil Money will explore advanced identity verification solutions, artificial intelligence, and machine learning algorithms to enhance the accuracy and efficiency of the CIP. Additionally, Zil Money will maintain a proactive approach to regulatory changes and promptly update the CIP as required. Regular reviews will be conducted to ensure that the CIP remains effective and relevant in the face of dynamic challenges.