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KYC policy of Starlink International N.V.

Last updated: 12 March, 2023

When a user registers for an account on the production-ugglobal-v2-nginx platform, it is compulsory for them to provide some basic personal details as below:

1. Full name


2. Date of birth


3. Address


4. CPF, which is a national ID number

When a user requests a withdrawal of any amount inside the production-ugglobal-v2-nginx platform, Starlink’s internal administration team will perform a basic KYC check, by using an online tool provided by the Brazilian government to check the user’s basic details before proceeding with the withdrawal. This tool can be found at https://www.gov.br/pt-br/servicos/consultar-cadastro-de-pessoas-fisicas

When a user makes an aggregate lifetime total of deposits exceeding EUR 2000, then it is compulsory for them to perform a KYC process. During this process, the user will have to provide to Starlink’s administration team their personal documents as below:

1. A copy of government Issued ID


2. A selfie of themselves holding the ID document


3. An utility bill

billOnce provided, the user will get a “Pending KYC” status and the documents will now be on our side, and the “Starlink Team” will have 24hrs to go over them and email the user about the outcome:

• Approval


• Rejection


• More information needed – No change in Status

When the user is on “Pending KYC” status then

• They can use the platform normally


• They cannot complete any withdrawal

Guideline for the “KYC Process”

1. Proof of ID
   
   
   • Signature is clearly visible
   
   
   • Country is not a Restricted Country: United States of America and its territories, France and its territories, Netherlands and its territories and countries that form the Kingdom of Netherlands including Bonaire, Sint Eustatius, Saba, Aruba, Curacao and Sint Maarten, Australia and its territories, United Kingdom of Great Britain, Northern Ireland, Spain.
   
   
   • Full Name matches user’s name
   
   
   • Date of birth matches user’s date of birth
   
   
   • Document does not expire in the next 3 months
   
   
   • Owner is over 18 years of age
   
   
2. Proof of Residence
   
   
   • Utility bill
   
   
   • Country is not a Restricted Country: United States of America and its territories, France and its territories, Netherlands and its territories and countries that form the Kingdom of Netherlands including Bonaire, Sint Eustatius, Saba, Aruba, Curacao and Sint Maarten, Australia and its territories, United Kingdom of Great Britain, Northern Ireland, Spain, and Cyprus.
   
   
   • Full Name matches the user’s name and is the same as in proof of ID.
   
   
   • Date of Issue: Within the last 3 months
   
   
3. Selfie with ID
   
   
   • Holder is the same as in the ID document above
   
   
   • The ID document is the same as in “1”. The photo/ID number must be the same

Notes on the “KYC Process”

1. When the KYC process is unsuccessful then the reason is documented. The explanation is communicated back to the user.


2. Once all proper documents are in our possession then the account gets approved.

“Other AML measures”

1. If a user has not passed full KYC then they cannot make additional deposits or withdrawals of any amount.


2. If a user has passed the KYC process successfully then
   
   
   • There is a deposit limit per transaction (max BRL10,000, eq. EUR 1,800)
   
   
   • Prior to any withdrawal exceeding BRL 1,000 there is a detailed manual check on the activity and balance of the user to see if the amount withdrawn is a result of proper activity in the platform.
   
   
3. Under no circumstances may a user transfer funds directly to another user.