Introduction
This Know Your Customer policy establishes the customer due diligence framework applied by 100jili to verify the identity and assess the risk profile of individuals who hold an account on the 100jili platform. The policy governs all KYC activities undertaken by the Company and applies to every registered user who engages in activity on the platform.
Purposes
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Prevent violations of the platform terms and applicable regulatory documents.
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Mitigate money laundering, terrorist financing and related crimes in accordance with AML and CFT laws.
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Prevent access to the platform by minors and other ineligible individuals.
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Disrupt cheating, collusion and other unlawful or deceptive conduct on the platform.
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Protect the legal, financial and reputational interests of the Company and its customers.
Risk assessment
The Company adopts a risk based approach to customer evaluation in line with FATF guidance. Risk is categorized as follows:
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Country or geographical risk — residence or domicile of the customer, including jurisdictions designated as high risk or having strategic deficiencies by competent authorities, or lacking robust AML regimes.
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Customer risk — indicators such as political exposure, sanctions status, adverse activity signals, and complexity of ownership or control.
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Transaction risk — pattern and intensity of activity, source of funds, and potential irregular funding or transfer activity.
Verification
Standard verification is conducted when one or more conditions indicate the need for enhanced confidence in a customer's identity and conduct. Standard verification may be triggered by any of the following, individually or in combination: the total value of a customers transactions reaches or exceeds 1,000 USD; the customer presents elevated risk of money laundering or terrorist financing; suspicious behavior or anomalies are observed; or other circumstances deemed by the Company to require verification.
During Standard Verification, the Customer shall be required to provide the following documents or data to the extent requested by the Company:
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Identification: a copy or photograph of a government issued identification document showing the customers full name and date of birth. The document must be valid and legible; scans of front and back are preferred.
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Proof of payment method: a photograph or scan of the payment instrument used for deposits to the platform. The instrument holders name must match the account holder. For cards, display the cardholder name and the first six and last four digits; the CVV and the middle digits must be hidden or redacted. The cardholders name must be clearly visible.
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Photograph of the customer: a recent image that clearly shows the customer and the required documents used for verification. In some cases, residency or address confirmation may be requested.
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Address verification: documents such as a utility bill or bank statement issued within the last three months showing the customers name and residential address.
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Additional data or documents: other data or documents that the Company determines are necessary to complete verification, including support contact verification as required.
The Company may require the customer to complete additional verification steps or to connect with the support team via a secure channel, including real-time verification or video interaction, where appropriate to complete the process.
Additional verification for PEPs and high risk jurisdictions
Enhanced verification applies when a customer is identified as a politically exposed person or a family member of a PEP, or when residence in a high risk or other monitored jurisdiction is established. In such cases, the Company may require:
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Documentation demonstrating the source of wealth and funds used on the platform in accordance with local and international requirements.
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Additional confirmation of identity and ownership structures, where applicable.
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Approval by senior management prior to continuing existing activity or enabling higher transaction limits.
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Ongoing monitoring with periodic reviews or as events warrant additional scrutiny.
Activity monitoring
All customer activity is monitored for indicators of suspicious behavior. Examples of suspicious activity include, but are not limited to: use of multiple cards via different payment agents; repeated error codes on payments; rapid device switching or shared devices; multiple users sharing a single IP address; anomalies in location data or geolocation; reluctance or refusal to pass verification; and device ID matches with other accounts. Any suspected activity is escalated to the antifraud function for risk assessment and further action.
Transactions monitoring
All deposits and withdrawals comply with the following principles to ensure traceability and ownership of funds:
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Card deposits must be conducted by a card holder whose name matches the 100jili account holder; third party card use is prohibited.
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Electronic wallet deposits and withdrawals must use an account associated with the users registered email address.
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Withdrawals must be to instruments in the name of the account holder or to a banking account that is verifiably linked to the customer; funds may not be withdrawn to an instrument not associated with the customer.
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The use of anonymous payment instruments, including unhosted cryptocurrencies or anonymous wallets, is not accepted for deposits or withdrawals.
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When a deposit is made from a source that cannot be verified as belonging to the customer, withdrawals shall be limited to a method that preserves ownership verification, or to the customers bank account where ownership can be demonstrated.
Record keeping and data protection
All documents, data and transaction records obtained during verification, along with related financial data, are stored, retained and processed in accordance with applicable AML laws and data protection regulations. The Company implements access controls, encryption and secure storage. Retention periods comply with the applicable laws and regulations and align with internal data governance policies. Data subject rights and cross-border transfers are handled in accordance with the relevant data protection framework where applicable.
Amendments
The Company reserves the right to amend this Policy at any time. Customers are responsible for reviewing changes. Continued use of the platform after notification of changes constitutes acceptance of the revised policy. Material changes will be communicated to registered users through the contact information on file.
