AML and KYC policy

1. Introduction

Worthamence maintains a compliance programme covering client identification (KYC), ongoing monitoring and the prevention of money laundering and the financing of terrorism (AML/CTF). The purpose of these procedures is to establish, with reasonable confidence, who our clients are, that the funds they use are theirs, and that the activity on their accounts is consistent with what a legitimate client would do. Verification is not a formality we tolerate; it is a condition of service, and it applies to every client without exception.

The procedures are proportionate: most clients experience them as one document upload and a short wait. The sections below describe the framework in full, including the steps that apply only in particular situations, so that nothing about the process is a surprise.

2. What KYC is

Know-your-client procedures confirm the identity of each person who opens an account and the authenticity of the details they provide. Identification collects the information needed to distinguish you from every other person: full legal name, date of birth, residential address and an identity document. Verification then checks that information against authoritative sources and documents, establishing that the account belongs to a real, identifiable person.

KYC is not a one-time event. Basic details are confirmed at onboarding, and selected information is refreshed periodically or when something changes materially, such as a new address or a new payout destination. Keeping this information current is what allows the rest of the framework to function honestly.

3. What AML and CTF involve

Anti-money-laundering procedures are designed to prevent the platform from being used to disguise the origin of criminally derived funds. They begin with a risk assessment of each client and relationship, continue with monitoring of account activity against the expected pattern, and conclude with the handling of matters that cannot be explained: escalation, internal review, and where the law requires it, reporting to the competent authorities.

Countering the financing of terrorism follows the same structure with a different target: identifying activity that may be connected to the financing of proscribed organisations, whatever the apparent origin of the funds. In practice both obligations translate into the same client-facing behaviours: accurate identity records, attention to transactions that do not fit, and the discipline to ask rather than assume.

4. Why identity verification is required

Verification serves four purposes. It prevents fraud by ensuring an account cannot be opened in someone else's name, which protects both the impersonated person and the platform. It protects your account by anchoring recovery and payout changes to verified identity rather than to whoever happens to control an email address. It fulfils the legal obligations that apply to the services we provide in Australia. And it reduces financial risk across the system by making the platform unattractive to launderers, who depend on anonymous access.

The requirement is not discretionary and does not bend for convenience. An account that cannot be verified cannot transact, however genuine its owner may feel, because the framework has no lawful way to make exceptions.

5. Documents we ask for

Identity is confirmed with a government-issued photographic document: a passport, a driver licence, or another official identity document of equivalent standing. Address is confirmed with a document in your own name that is recent, typically issued within the last three months: a bank statement, a utility bill, or an official letter. Where a document does not cover both elements, you may be asked for one of each.

For some accounts we also complete a liveness check: a short selfie-style capture compared against your identity document, which establishes that the person submitting the documents is their holder and is present. We do not collect biometric templates beyond what that comparison requires, and we do not ask for documents unrelated to identity, address or source of funds. If you are ever unsure whether a request is genuine, confirm it with your manager through the contact details on this site before sending anything.

6. The verification process, step by step

Step one is registration, where you provide your basic details and create credentials. Step two is document submission, through the secure upload in your account rather than by email. Step three is automated checking, where the document's authenticity features and the data on it are validated electronically. Step four, used where automated checks are inconclusive, is manual review by a trained specialist. Step five is the outcome: a confirmation in your account, or a specific request for anything further, with the reason stated.

Each stage leaves a record, and you can see the current status of verification in your account at any time. The process is sequential on purpose: later stages see only what earlier stages could not resolve, so straightforward cases are usually finished before a human is ever involved.

7. Enhanced due diligence

Some situations call for enhanced due diligence (EDD): a deeper look before or during a relationship. These include clients or counterparties associated with higher-risk jurisdictions, unusually large or structurally complex transactions, entities with opaque ownership, and cases where the source of funds is not yet clear from standard evidence. EDD may involve additional documents about the origin of funds, an explanation of the expected nature of activity, or refreshed identification.

EDD is applied to situations, not judgements about people. A request for enhanced documentation means the situation warrants it under the framework, nothing more, and a clear explanation from you usually resolves it quickly.

8. How long verification takes

Automated checks complete in minutes, and most straightforward verifications finish within one business day. Cases that require manual review are typically resolved within one to three business days, depending on document quality, response times and whether a public holiday intervenes. Liveness checks add only the time it takes to capture the image.

You can shorten your own timeline: photograph documents on a plain background with all four corners visible and no glare, make sure the name on your account exactly matches the document, and respond to follow-up requests the same day. The commonest cause of delay is a document that arrives cropped, angled or obscured.

9. Why verification can be declined or suspended

Verification may be refused or paused for reasons that are specific and correctable or, occasionally, final. Correctable causes include documents that are expired, damaged, cropped or unreadable; details that do not match between the account and the document; a missing element such as address evidence; and incomplete responses to a request for further information.

More serious causes include documents with indications of alteration or forgery, identity details that conflict with authoritative records, indications that the applicant is acting for an undisclosed third party, and refusal to provide information the framework requires. In those cases the account cannot be verified, pending transactions are returned where the law allows, and the matter is recorded as the framework requires. A declined client is always told which category of cause applies, though the detail provided is limited by the same rules the decision follows.

10. Transaction monitoring

Activity on verified accounts is monitored against expected patterns: sizes, frequencies, destinations and timing relative to the profile established at onboarding. Monitoring is automated in the first instance, with unusual matters reviewed by compliance staff who can see the account's history and context. Patterns that matter include rapid movement of freshly deposited funds, activity inconsistent with the stated purpose of the account, and connections to previously flagged elements.

Where monitoring raises a question, possible responses include requesting an explanation, applying temporary limits on specific functions while the review concludes, and in defined cases closing the relationship. Limitation of functions is a protective measure, not a penalty, and it is lifted when the underlying question is answered. We do not disclose to any client whether a specific matter has been reported to authorities, as the law prohibits it.

11. Your responsibilities

The framework depends on information that is accurate, current and genuine. You are responsible for providing details that are true, for updating them when they change, and for submitting documents that are yours, unaltered and complete. Accounts are personal: credentials, verification status and payout destinations must not be shared, transferred or created for the benefit of someone else.

Providing false information, submitting documents that misrepresent anything, or acting as a front for another person are not administrative slip-ups; they are grounds for refusing or ending the relationship and may carry legal consequences for the person responsible. If you notice an error in your own record, telling us promptly has always been the better path than hoping it goes unexamined.

12. Storage and protection of verification data

Identity documents and verification records are stored encrypted, with access restricted to the systems and roles that require it for verification, support and legal duties. Retention periods follow the requirements applicable to records of this kind: verification records are kept for the period the law prescribes after the end of a relationship, which generally extends beyond the life of the account itself. When a retention period ends, records are destroyed or irreversibly anonymised.

The relationship with our general privacy practices, including your rights of access and correction, is set out in the Privacy Policy, which governs how all personal information, verification data included, is handled across the platform.

13. Who verification data can be shared with

Verification information is shared only in defined circumstances and with defined categories of recipient. These include the identity-verification providers that perform the automated document checks; the technology providers that host and process data under contractual confidentiality; companies within our corporate group where the service requires it; executing venues and payment providers that are obliged to know their counterparty; and regulators and other competent authorities, where a lawful requirement to disclose exists.

Each category is bound by purpose limitation: data received for verification may be used for verification and the legal duties connected to it, not for unrelated marketing or resale. We do not sell identity data to anyone, and disclosures outside these categories are made only where the law compels them.

14. Compliance with applicable requirements

Worthamence carries on its activities subject to the Australian legal framework applicable to its services, including requirements relating to client identification, record keeping, monitoring and reporting, and it complies with those applicable requirements. Where questions arise about the application of a requirement to a specific situation, the conservative reading is applied until resolved.

This framework is maintained, not merely possessed: procedures are reviewed as rules and risks change, staff are trained in what the procedures require of them, and the effectiveness of the programme is assessed rather than assumed. Compliance is treated as a condition of operating, not a cost of it.

15. Contact for KYC and AML questions

Questions about this policy, about a verification request you have received, or about the status of your verification can be sent to [email protected], which reaches the team responsible for these matters during support hours, Monday to Friday, 9:00-17:30 AEST. Verification-related questions are answered by staff who can see the actual state of your case, so one message with your question is enough; we will tell you what is needed rather than what is easy.