1. Scope and purpose
This policy applies to every investor, agent, developer, and counter-party that transacts on ReptoState. The goal is to prevent the platform from being used to launder funds, finance terrorism, evade sanctions, or commit fraud.
2. Customer due diligence (KYC)
Every investor must complete KYC before they can transact. We collect:
- CNIC (front + back) for Pakistani residents, or passport for overseas Pakistanis.
- A liveness selfie matched against the ID photo.
- Proof of address less than three months old.
- A self-declared source of funds and source of wealth.
- Tax information (NTN where applicable; FATCA self-declaration for US-linked persons).
Verification is performed by {{ FOUNDER: kyc_vendor }}.
3. Sanctions and PEP screening
Every applicant is screened against UN, OFAC, EU, UK, and Pakistani sanctions lists, as well as politically-exposed-person (PEP) lists. Hits trigger enhanced due diligence before the account can be opened or, where applicable, rejection. Screening is rerun periodically and on every material change of circumstance.
4. Transaction monitoring
Investments, withdrawals, and resale transactions are monitored for unusual patterns — structuring, rapid in/out flows, round-tripping, wash trading between related accounts. Our monitoring partner: {{ FOUNDER: tx_monitoring_partner }}.
5. Suspicious-transaction reporting
Suspicious activity is escalated internally to the Money-Laundering Reporting Officer and, where required, filed with {{ FOUNDER: str_filing_authority }} (the Financial Monitoring Unit, in Pakistan). Investors are not informed when a report is filed (tipping-off is prohibited).
6. Compliance officer
Our compliance officer (MLRO) is {{ FOUNDER: compliance_officer_name }}. They can be reached at compliance@reptostate.com.
7. Record-keeping
KYC documents, screening results, transaction history, and STRs are retained for at least five years after the account is closed, as required by Pakistani AML regulations.
Last reviewed: 2026-05-01
