Commertize, Inc. ("Commertize," "we," "us," or "our") is committed to maintaining the highest standards of regulatory compliance and preventing financial crimes. This Know Your Business (KYB) Policy outlines the procedures and requirements for verifying the identity and legitimacy of business entities that wish to use our platform for real estate investment opportunities.
1. Purpose
The purpose of this KYB Policy is to establish a framework for identifying and verifying business entities, their ownership structures, and their sources of funds. This helps us comply with applicable anti-money laundering (AML) regulations, counter-terrorism financing (CTF) requirements, and securities laws, while protecting our platform and users from fraudulent activities.
2. Scope
This policy applies to:
- All business entities seeking to register on the Commertize platform
- Property sponsors and real estate developers
- Institutional investors and investment funds
- Corporate entities making investments through our platform
- Any other legal entities engaging with our services
As part of our KYB verification process, we collect the following information:
Business Identification
Legal business name, trading names (if any), business registration number, date of incorporation, jurisdiction of registration, tax identification number (EIN/TIN).
Business Address & Contact
Registered office address, principal place of business, business phone number, official email address, website (if applicable).
Ownership Structure
Details of all beneficial owners holding 25% or more ownership, organizational chart, shareholder register, partnership agreements (if applicable).
Authorized Representatives
Names and contact information of directors, officers, and authorized signatories, proof of authority to act on behalf of the entity.
Financial Information
Source of funds, bank account details, financial statements (if required), expected transaction volumes.
4. Required Documentation
Business entities must provide the following documents:
- Certificate of Incorporation or equivalent formation document
- Articles of Incorporation, Bylaws, or Operating Agreement
- Certificate of Good Standing (issued within the last 90 days)
- Proof of business address (utility bill, bank statement, or lease agreement)
- Government-issued ID for all beneficial owners and authorized representatives
- Board resolution or power of attorney authorizing platform usage
- W-9 form (for U.S. entities) or W-8BEN-E (for non-U.S. entities)
5. Beneficial Ownership
We are required to identify and verify all beneficial owners of business entities. A beneficial owner is defined as:
- Any individual who directly or indirectly owns 25% or more of the equity interests of the entity
- Any individual who exercises significant control over the entity, including senior officers or managers
For each beneficial owner, we require personal identification information consistent with our KYC (Know Your Customer) requirements, including government-issued photo ID and proof of address.
6. Verification Process
Our KYB verification process includes:
Document Verification
We verify the authenticity of all submitted documents through trusted third-party verification services and government databases.
Sanctions Screening
The business entity and all beneficial owners are screened against global sanctions lists, including OFAC, UN, EU, and other relevant watchlists.
Adverse Media Screening
We conduct searches for any negative news or adverse media related to the business and its key individuals.
PEP Screening
Beneficial owners and authorized representatives are screened for Politically Exposed Person (PEP) status.
7. Risk Assessment
Each business entity is assigned a risk rating based on factors including:
- Country of incorporation and operation
- Industry and business activities
- Ownership structure complexity
- PEP involvement
- Source of funds
- Expected transaction patterns
Higher-risk entities may be subject to enhanced due diligence (EDD) measures, including additional documentation requirements and more frequent reviews.
8. Ongoing Monitoring
KYB verification is not a one-time process. We conduct ongoing monitoring and periodic reviews to ensure continued compliance. This includes monitoring for changes in ownership structure, sanctions status, and any other material changes that may affect the entity's risk profile. Business entities are required to notify us promptly of any material changes to their information.
9. Data Protection
All information collected as part of our KYB process is handled in accordance with our Privacy Policy and applicable data protection laws. We employ appropriate technical and organizational measures to protect the confidentiality and security of your business information.
10. Non-Compliance
Failure to provide required information or documentation, or providing false or misleading information, may result in denial of access to our platform, termination of existing accounts, reporting to relevant authorities as required by law, and legal action where appropriate.
For questions about our KYB requirements or to submit verification documents, please contact us at:
Commertize, Inc.
Attn: Compliance – KYB
20250 SW Acacia St. #130
Newport Beach, California 92660
Email: compliance@commertize.com