Know Your Customer Policy

Issued by Krepling Inc.

Effective Date: 20th June 2025

1. Purpose

This Know Your Customer (“KYC”) Policy outlines the standards, procedures, and documentation required by Krepling Inc. (“Krepling”) for verifying the identity of all merchants using Krepling Pay. It ensures compliance with U.S. regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, card network requirements, and standards from our sponsor banks.

What This Means:

We follow strict rules to confirm who you are before allowing you to use Krepling Pay.

2. Scope

This policy applies to:

  • All new and existing merchants on Krepling Pay

  • All business types (except those on our Exclusion List)

  • All geographic regions where Krepling Pay operates

What This Means:

All Krepling Pay merchants must meet our KYC standards, unless they’re on the restricted list.

3. Legal Framework

KYC is conducted in compliance with:

  • Bank Secrecy Act (BSA)

  • USA PATRIOT Act Section 326

  • FinCEN guidance

  • Card Network rules (Visa, MasterCard, Amex, Discover)

  • Sponsor bank requirements (Wells Fargo, Synovus, Deutsche Bank)

What This Means:

Our verification rules follow U.S. laws and global banking standards.

4. KYC Requirements (EXHIBIT A Reference)

We collect and verify the following:

Individual (Sole Proprietor):

  • Full legal name

  • Government-issued ID (driver’s license or passport)

  • Social Security Number (SSN)

  • Contact information (email, phone, address)

Business Entity:

  • Legal entity name

  • Employer Identification Number (EIN)

  • Articles of Incorporation or business license

  • Names and SSNs of beneficial owners and control persons

  • Physical business address

  • Website or marketing materials

What This Means:

We check your identity and business legitimacy before onboarding you.

5. Domain Inspections and Verifications

A merchant site inspection may be required, especially for:

  • High-risk businesses (see Exhibit B)

  • Drop shippers or third-party fulfillment models

  • Businesses without a physical office location

Inspections may include:

  • Third-party or internal review

  • Confirmation of business operations

  • Photos and documentation of business premises

What This Means:

We may inspect your physical location or operations to make sure they’re real.

6. Merchant Risk Classification

Krepling classifies merchants as:

  • Low/Medium Risk: <$15M annual volume, swiped/chip-read >65%, future delivery <30 days

  • Low Volume High Risk: <$2.5M volume, high future delivery, high keyed rates

  • High Risk: >$2.5M volume, >$5K average ticket, future delivery >30 days

Each category requires:

  • Increasing levels of documentation

  • Deeper due diligence

  • Additional verification (e.g., financial statements, PGs)

What This Means:

The higher your risk level, the more documents and checks we need.

7. Ongoing Monitoring

Krepling continuously monitors:

  • Changes in business structure, ownership, or activity

  • Transaction volume and patterns

  • Updated sanctions and watchlists (e.g., OFAC SDN)

Periodic KYC re-validation may be required for:

  • High-risk or high-volume merchants

  • Businesses with multiple chargebacks or flags

What This Means:

We check accounts regularly and may ask for updated documents over time.

8. Enhanced Due Diligence (EDD)

EDD is required for:

  • High-risk merchant categories (Exhibit B)

  • Merchants with complex structures or international operations

  • Merchants flagged for suspicious activity

EDD may involve:

  • Site visit and ownership interviews

  • Additional financial records

  • Review of refund/return policies

What This Means:

Risky or complex businesses must go through extra checks.

9. Recordkeeping

KYC records are maintained securely for at least 5 years after the end of the merchant relationship. These include:

  • All documents submitted

  • Verification logs

  • Notes from site inspections or interviews

What This Means:

We securely store your KYC documents for at least 5 years.

10. Failure to Comply

If a merchant fails to complete KYC or submits fraudulent documentation:

  • The account may be suspended or declined

  • Existing funds may be held until resolution

  • Reports may be filed with law enforcement or regulators

What This Means:

If KYC is not completed properly, we can freeze or close your account.

11. Contact Information

For questions regarding this KYC policy, contact:
Email: compliance@krepling.com

What This Means:

You can contact our compliance team if you have questions about verification.