05 · Investor Qualification, KYC & AML Policy — Flow 1

Applies to every SAFE investor before funds are accepted or an entry is made in the SAFE Registry. Private (PII). Draft for Bulgarian AML + DIFC counsel. Not legal advice.

1. Principle

No money is accepted and no Registry entry is made until: (a) qualification is verified, (b) KYC/AML is cleared, and (c) the SAFE is executed. The SAFE is offered privately, to qualified investors only — never to the public.

2. Qualification (who may invest)

The investor must be a qualified / professional investor under the rules of their own jurisdiction. Evidence, one of:

• entity: regulated firm, fund, family office, or company meeting the local professional threshold (registry extract + authorised-signatory proof);
• individual: certified/sophisticated/accredited status per local law (self-certification plus supporting evidence such as net-worth or income confirmation, or an adviser's certificate).

A self-declaration checkbox on the website is an intake signal only — never sufficient on its own.

3. KYC — identification

Individuals: full name, date of birth, nationality, residential address, government-issued photo ID (passport/ID), proof of address (≤3 months), source of funds statement.

Entities: legal name, registration number, registered address, certificate of incorporation, constitutional documents, register extract, UBO (≥25%) identification, directors/authorised signatories, corporate authority to invest, source of funds.

PEP screening for individuals, UBOs and signatories.

4. AML — screening & risk

1. Sanctions screening against EU, UN, OFAC and UK lists — investor, UBOs, signatories; re-screened at least annually and on any change.
2. Risk rating — low / medium / high (jurisdiction, structure, PEP, source of funds). High risk → enhanced due diligence and founder sign-off.
3. Source of funds / source of wealth — documented; unexplained wealth → reject.
4. Payment matching — funds must arrive from an account in the investor's own name. No third-party payments. No cash.
5. Prohibited — sanctioned persons/jurisdictions; anonymous or nominee-obscured parties; funds from unlawful or non-halal sources (see negative screen).

5. Ongoing obligations

• Records retained ≥5 years after the relationship ends.
• Suspicious activity → report to the Bulgarian FIU (DANS) per Bulgarian AML law; no tipping-off.
• Re-verification on material change (control, address, status).
• Annual review of this policy.

6. Roles

• Founder/Manager (Oleksandr Kuguk) — MLRO for the pre-incorporation phase; final accept/reject.
• Investment & Donation Manager — collects and pre-checks the file.
• Records held in the private investor CRM (digiwaqf_safe_leads → Registry, doc 02), access-restricted.

7. Outcome

Cleared → SAFE executed (doc 01), payment matched, Registry entry (doc 02), Proof of Payment issued (doc 07). Rejected → funds returned to source; reason recorded; no explanation given where tipping-off rules apply.

8. Donations (Flows 2 & 3)

Consumer donations are lower-risk but still subject to sanctions screening and payment-provider (Stripe) controls; enhanced checks apply above [EUR 10,000] or on any red flag.

9. Governing law

Bulgarian AML law and applicable EU AML directives; DIFC requirements apply to U21C on incorporation.