KYC and Anti-Money-Laundering

Akontec is not a regulated financial institution. These controls are applied because a services business handling client payments, partner payouts and investment participation is an obvious target for misuse, and because a single laundering incident would end the business.

Absolute rules

1. No cash. Not for services, franchise fees, partner arrangements or investment participation. No threshold, no exception, no "part payment in cash".
2. Banking channels only, into the account in Akontec's own name.
3. Third-party payments are not accepted. The payer must be the contracting party. A payment from an unrelated individual or entity is returned, not applied.
4. No payment to a third-party account. Refunds and payouts go only to the original or registered account of the counterparty.
5. No structuring. Splitting a payment into smaller amounts to avoid a threshold or a check is refused and reported internally.

Client onboarding checks

Entity verification (incorporation, PAN, GST) · authorised signatory identity and authority · address verification · bank account validation in the entity's name · beneficial ownership for corporate clients · sanctions and adverse media screening on the entity and its principals.

Partner onboarding checks

Full requirements at 18_Vendors/02_Registration_And_KYC.md — entity documents, signatory ID, premises verification, bank validation, sanctions screening, source-of-funds questions where the arrangement involves investment.

Investor checks — enhanced

Identity and address verification · source of funds and, where the amount warrants, source of wealth · sanctions and PEP screening · beneficial ownership where investment is through an entity · declaration that funds are the investor's own and lawfully obtained.

Investment participation is never accepted from an unverified party, however attractive the amount. See 15_Investment/04_Investor_Disclosures.md.

Red flags requiring escalation to the Director

Reluctance or refusal to provide identification · a payment offered from an unrelated third party or from a jurisdiction with no connection to the business · a request to over-pay and receive a refund of the excess · unusual urgency combined with pressure to skip documentation · a request to route payment through an intermediary · funds offered in cash or via untraceable instruments · a counterparty unwilling to explain the source of funds · a partner or client whose ownership cannot be established · a request to invoice a different entity from the one receiving the service.

Escalation is mandatory. An employee is never penalised for escalating a transaction that turns out to be legitimate.

Screening

Sanctions and adverse media screening at onboarding and periodically thereafter. Any positive or possible match stops the onboarding immediately and goes to the Director before any further contact.

Records

KYC documentation, screening results, source-of-funds evidence and escalation records are retained per 06_Document_Retention.md and are producible on regulatory request.

Refusal and exit

Akontec refuses or exits a relationship where identification cannot be completed, screening produces a match that cannot be resolved, source of funds cannot be established, or the counterparty resists the checks. A commercially attractive relationship is refused on these grounds without negotiation, and the reason for refusal is not disclosed to the counterparty beyond stating that we are unable to proceed.