Anti-Money Laundering (AML) & Know-Your-Customer (KYC) Policy — skgonline | https://shartiskg.com/ 💼🛡️

Last Updated: 9 November 2025

This Anti-Money Laundering (AML) and Know-Your-Customer (KYC) Policy (the “Policy”) sets out the principles,
controls, and procedures used by skgonline (accessible at https://shartiskg.com/) to prevent our
learning platform and any related financial interactions (e.g., course purchases, refunds, affiliate payouts, sponsorships)
from being used for money laundering (ML), terrorism financing (TF), fraud, or other illicit conduct. We are an
education-focused platform and do not provide gambling or betting services. Nevertheless, consistent with
global best practices, we apply proportionate AML/KYC safeguards to protect users and the integrity of our systems. ✅

1) Scope & Alignment with EEAT and YMYL 📚

Because our content may influence user decisions in sensitive domains (YMYL), and because we accept payments for educational
services, we adopt rigorous editorial and compliance standards consistent with EEAT (Experience, Expertise, Authoritativeness,
Trustworthiness). This Policy applies to:

  • All purchases, refunds, sponsorships, and payouts processed via shartiskg.com.
  • All vendors, partners, affiliates, and contributors who receive or send funds through our platform.
  • All internal teams and contractors handling user identity, billing, or support data.

2) Governance & Responsibilities 🧭

Policy Owner: Compliance Lead (reports to executive management).
AMLCO: An Anti-Money Laundering Compliance Officer (AMLCO) oversees implementation, training, monitoring,
recordkeeping, and reporting. The AMLCO may delegate tasks to trained analysts while remaining accountable.

  • Management approves Policy changes and allocates resources.
  • AMLCO designs and enforces procedures, risk assessments, and controls.
  • All staff must complete mandatory AML/KYC training and report suspicious activity.

3) Legal Baseline & Best-Practice Frameworks ⚖️

While skgonline is an educational platform, our internal AML/KYC framework is informed by widely accepted standards,
including FATF recommendations and relevant data-protection principles. We do not claim licensing as a financial or
gambling institution; this Policy is a good-faith, risk-based framework to protect users and our brand.

4) Definitions 🔍

  • Money Laundering (ML): Concealing or disguising the origins of criminal proceeds.
  • Terrorism Financing (TF): Providing or collecting funds to support terrorist acts or organizations.
  • KYC: Processes to verify user identity, address, payment method ownership, and—where needed—source of funds/wealth.
  • Enhanced Due Diligence (EDD): Additional checks for higher-risk profiles, geographies, or transactions.

5) Risk-Based Approach (RBA) 🧮

We calibrate controls to the assessed risk of a user, transaction type, payment rail, and geography.
Risk factors include unusual velocity, mismatched identities, proxy/obfuscation signals, sanctioned regions,
and complex routing patterns.

5.1 Geographic Risk Tiers 🌍

TierRisk LevelTypical Controls
Tier 1LowerStandard KYC, payment ownership checks, continuous monitoring.
Tier 2MediumEarlier KYC triggers, EDD on anomalies, stricter refund/payout review.
Tier 3HighService restrictions or blocks; onboarding may be declined.

6) Customer Identification & Verification (KYC) 🔐

We verify identity proportional to risk and transactional thresholds. Users may be asked to complete KYC before certain
actions (e.g., large payments or payouts).

6.1 Core KYC Data

  • Full name, date of birth, nationality, and residential address.
  • Government-issued photo ID (all four corners visible, readable details, selfie if required).
  • Proof of address (e.g., utility bill or bank statement issued within 3 months).
  • Payment method ownership (card/bank statement redacted to minimum necessary data).

6.2 Verification Thresholds & Triggers

LevelTrigger ExamplesWhat We May Request
Level 1 (Basic)Account creation, initial purchase, standard refunds.Profile details, email/phone verification, basic payment checks.
Level 2 (Standard KYC)Higher aggregate spend or payout requests; anomalies detected.Government ID + selfie, proof of address, payment ownership evidence.
Level 3 (EDD)High-value transactions, Tier-2/3 regions, complex patterns.Source of funds/wealth (e.g., employment, business, inheritance, investments), additional documents.

7) Source of Funds / Source of Wealth (SoF/SoW) 💳

Where required, we may request documents demonstrating the legitimate origin of funds/wealth (e.g., payslips, business ownership,
tax filings, inheritance paperwork, investment statements). If legitimacy cannot be established, we may decline or reverse the
transaction and/or restrict the account.

8) Payment Rules & Red Flags 🚩

  • Refunds and payouts must generally flow back to the same method used for payment wherever feasible.
  • We may freeze or delay transactions that appear inconsistent with user profile or risk thresholds.
  • Structuring/splitting, rapid in-and-out flows, or identity mismatches may trigger EDD or reporting.

9) Ongoing Monitoring 🔁

Automated and manual reviews assess transaction behavior against KYC baselines. Alerts are investigated by trained staff; unresolved
anomalies may result in temporary holds, additional documentation requests, or closure.

10) Recordkeeping 🗂️

  • Identity and KYC records: retained for up to 10 years after the end of the relationship, unless law requires otherwise.
  • Transaction records: retained for up to 10 years from the date of the transaction.

11) Data Protection & Privacy 🔏

We apply data-minimization and security safeguards. Personal data are processed for legitimate purposes (KYC, fraud prevention,
compliance) and are stored securely. We do not sell personal data. We may disclose data to competent authorities if required by law.
For inquiries, contact: [email protected].

12) Training & Awareness 🎓

  • Manda