The onboarding process of new customers makes use of the pillar-framework as defined in the Acquiring/Underwriting Policy and comprises a series of steps which are being handled by the Onboarding Teams within the Risk Operations Department.

The below diagram shows the typical flow for the onboarding of each new customer.

This Procedure covers the Customer Risk Assessment and risk detection, and mitigation processes adopted at Onboarding stage and highlights the pillars addressed by the different types of reviews/checks.

Review and Verification

The six pillars to be reviewed at Underwriting stage are:

• AML/CFT

• Regulatory

• Transaction Laundering

• Content

• Reputation

• Credit risk

Before commencing the full onboarding process, an initial assessment (Pre-vet) is performed by the Head of compliance operations to immediately determine whether the business model falls within Cardaq’s Risk Appetite. This is concretely performed by accessing the customer’s website to identify the goods or services that Cardaq will be processing and checking the associated industry/business model against the Cardaq’s Prohibited industry list.

A notification is triggered through the CRM system in case the application is a duplicate one to promptly determine whether the customer has been previously terminated or declined. Until the CRM system is in place, a duplicate check must be run against the current database.

Any arising showstopper shall be identified as early as possible to ensure an efficient process.

Subject to the successful completion of the above checks and the provision of all the mandatory documentation, the analyst shall initiate the full underwriting process.