AML / KYC / Document Verification / Client Acceptance and Service Refusal Policy

1. Introduction and Purpose

This AML / KYC / Document Verification / Client Acceptance and Service Refusal Policy (“Policy”) has been prepared by KS Law Consultancy LLC (“Company”) to regulate client acceptance, identity verification, document control, fraud risk management, internal compliance controls and service refusal procedures within the scope of services offered through the kosovainvestment.com platform.

The Company operates within the framework of its obligation to know its customers in order to ensure a serious, reliable and transparent service environment. This Policy is applicable to any customer, user or business applicant of the Company.

2. Scope

This Policy covers the following processes: new client acceptance, review of existing client relationships, document verification and control, risk-based client assessments, service refusal or suspension decisions, process management in case of suspected fraud and abuse, internal audit and monitoring activities.

3. Client Acceptance Principles

The Company is not obligated to accept every person or entity that requests a service. In making client acceptance decisions, the following may be considered: whether accurate, consistent and up-to-date information has been provided; whether identity and authorization documents are sufficient; whether the service request complies with the legal framework; the nature, complexity and risk level of the business relationship; past client experience and other operational criteria.

4. Identity Verification (KYC)

The Company may request from the client a copy of passport or ID, proof of address, company incorporation documents, partnership structure and beneficial ownership information, signature circular or power of attorney, description of business activity, and explanatory documents regarding the source of income or funds.

5. Document Verification Processes

The Company may review submitted documents through methods such as visual consistency checks, logical cross-checks, data matching, and when necessary, notary verification or verification from publicly available sources.

6. Risk-Based Assessment

A risk-based assessment may be conducted considering factors such as the nature, amount and complexity of the service request, the client’s profile, country risk, sector sensitivities and previous transaction history. If a high risk level is identified, additional documents may be requested, the scope of service may be narrowed or the service may be refused.

7. Service Refusal or Suspension

The Company reserves the right to refuse or suspend the service in the following cases:

• Submission of forged, misleading or inconsistent documents
• Failure to complete identity verification
• Client’s refusal to cooperate
• Service request appearing incompatible with the legal framework
• Identification of an unacceptable risk level
• Suspicion of payment fraud or malicious behavior
• Client displaying threatening, insulting or inappropriate behavior

8. Record Keeping and Archiving

The Company retains records related to client acceptance, identity verification, document control and risk assessment processes within the framework of legal obligations and internal audit requirements.

9. Confidentiality and Data Protection

Information collected and processed within the scope of this Policy is also evaluated in conjunction with the separately published Privacy Policy and Personal Data Protection Notice.

10. Policy Updates

The Company may update this Policy from time to time in accordance with legislative changes, operational requirements or developments in risk assessment.

11. Final Provision

By requesting a service through the platform, the user acknowledges that the Company may exercise its rights of client identification, document verification, risk assessment and service refusal within the framework of this Policy.