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KNOW YOUR CUSTOMER (KYC) POLICY

1. POLICY STATEMENT

Gamezon Space Corporation (“Gamezon”, “Company”, or “Corporation”), a multinational e-commerce, fintech, logistics, shareholder services, and technology enterprise headquartered in Nairobi, is committed to maintaining the highest standards of regulatory compliance, financial integrity, investor transparency, and risk management.

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This Know Your Customer (“KYC”) Policy establishes the framework for identifying, verifying, assessing, onboarding, and continuously monitoring investors, shareholders, customers, institutional partners, and business entities interacting with the Company.

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The Company adopts a risk-based compliance approach to:

  • Prevent fraud, money laundering, terrorism financing, corruption, and identity abuse;

  • Ensure lawful participation in investment and shareholder activities;

  • Protect the integrity of the Company’s financial and operational systems;

  • Comply with applicable national and international regulations.

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2. PURPOSE OF THE POLICY

The purpose of this KYC Policy is to:

  • Verify the identity of investors, shareholders, and business partners;

  • Establish standardized onboarding procedures;

  • Assess financial crime and compliance risks;

  • Identify ultimate beneficial owners;

  • Ensure compliance with AML/CTF laws;

  • Protect the Company against fraudulent or unlawful activities;

  • Support transparent shareholder registration and investment operations.

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3. SCOPE OF APPLICATION

This Policy applies to:

  • Shareholders

  • Investors

  • Customers

  • Directors

  • Employees

  • Institutional partners

  • Vendors

  • Corporate entities

  • Financial intermediaries

  • Joint venture partners

  • Payment service providers

  • Third-party agents

This Policy applies across all jurisdictions where the Company operates.

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4. LEGAL & REGULATORY COMPLIANCE

The Company shall comply with all applicable:

  • Know Your Customer (KYC) laws;

  • Anti-Money Laundering (AML) regulations;

  • Counter-Terrorist Financing (CTF) requirements;

  • Data protection and privacy laws;

  • Financial crime prevention regulations;

  • Sanctions screening obligations.

The Company aligns its compliance framework with guidance issued by:

  • Financial Action Task Force (FATF)

  • Central Bank of Kenya

  • Financial Reporting Centre

  • United Nations sanctions frameworks

  • Applicable securities and financial regulators.

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5. KYC PRINCIPLES

The Company shall implement KYC controls based on the following principles:

  • Customer identification;

  • Risk-based verification;

  • Transparency of ownership;

  • Continuous monitoring;

  • Regulatory reporting;

  • Data confidentiality;

  • Enhanced due diligence for high-risk relationships.

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6. CUSTOMER & INVESTOR ONBOARDING PROCEDURES

No investor, shareholder, customer, or institutional partner may be onboarded until required KYC verification procedures are completed.

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7. IDENTITY VERIFICATION REQUIREMENTS

The Company shall collect and verify sufficient information to establish the true identity of all individuals and entities.

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7.1 Individual Verification Requirements

Individual investors, shareholders, or customers may be required to provide:

Primary Identification Documents

  • National ID card;

  • Passport;

  • Driver’s license;

  • Government-issued photo identification.

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Supporting Verification Documents

  • Proof of address;

  • Tax identification number;

  • Passport-size photograph;

  • Selfie or biometric verification;

  • Signature specimen.

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Additional Information

  • Date of birth;

  • Nationality;

  • Occupation;

  • Source of funds;

  • Source of wealth;

  • Contact information.

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7.2 Biometric & Digital Verification

The Company may implement:

  • Facial recognition;

  • Liveness detection;

  • Digital identity authentication;

  • AI-powered verification systems;

  • Electronic document verification tools.

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8. BENEFICIAL OWNERSHIP VERIFICATION

The Company shall identify and verify Ultimate Beneficial Owners (“UBOs”) of corporate entities, trusts, investment vehicles, and partnerships.

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8.1 Beneficial Ownership Threshold

Any natural person owning or controlling directly or indirectly:

  • 10% or more;

  • 25% or more; or

  • any threshold required by law

of an entity may be subject to beneficial ownership verification.

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8.2 Required Beneficial Ownership Information

The Company may require:

  • Ownership structure charts;

  • Shareholding details;

  • Director information;

  • Corporate resolutions;

  • Identification documents of UBOs;

  • Source of wealth documentation.

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8.3 Enhanced Ownership Review

Complex or layered ownership structures may require:

  • Independent legal verification;

  • Additional due diligence;

  • Enhanced compliance approvals.

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9. ADDRESS VERIFICATION REQUIREMENTS

The Company shall verify the residential or business address of applicants.

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9.1 Acceptable Proof of Address Documents

Examples include:

  • Utility bills;

  • Bank statements;

  • Government correspondence;

  • Lease agreements;

  • Tax documents;

  • Certified residential confirmations.

Documents must generally:

  • Be recent;

  • Clearly display the applicant’s name and address;

  • Be valid and legible.

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9.2 Electronic Address Verification

The Company may use:

  • Geolocation systems;

  • Electronic databases;

  • Third-party verification services;

  • Digital compliance tools.

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10. INSTITUTIONAL & CORPORATE VERIFICATION

Institutional investors, companies, and organizations shall undergo enhanced verification procedures.​

10.1 Required Corporate Documents

The Company may require:

  • Certificate of incorporation;

  • Business registration certificates;

  • Memorandum & Articles of Association;

  • Partnership agreements;

  • Board resolutions;

  • Tax compliance certificates;

  • Regulatory licenses.

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10.2 Corporate Representative Verification

Authorized representatives must provide:

  • Government-issued identification;

  • Proof of authorization;

  • Board approvals where applicable.

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10.3 Institutional Due Diligence

The Company may conduct:

  • Regulatory status checks;

  • Sanctions screening;

  • Adverse media reviews;

  • Litigation checks;

  • Financial crime risk assessments.

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11. RISK ASSESSMENT & CUSTOMER CLASSIFICATION

The Company shall apply a risk-based approach to classify applicants based on:

  • Geographic risk;

  • Transaction risk;

  • Investor profile;

  • Source of funds;

  • Political exposure;

  • Ownership complexity;

  • Industry sector.

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11.1 Risk Categories

Applicants may be classified as:

  • Low Risk

  • Medium Risk

  • High Risk

Higher-risk applicants may require Enhanced Due Diligence (“EDD”).

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12. ENHANCED DUE DILIGENCE (EDD)

Enhanced Due Diligence may apply to:

  • Politically Exposed Persons (PEPs);

  • High-net-worth individuals;

  • Offshore entities;

  • Cross-border investors;

  • High-risk jurisdictions;

  • Complex ownership structures.

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12.1 EDD Procedures

EDD measures may include:

  • Source of wealth verification;

  • Source of funds verification;

  • Enhanced document review;

  • Senior management approval;

  • Ongoing monitoring;

  • Independent background checks.

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13. SANCTIONS & WATCHLIST SCREENING

The Company shall screen applicants against:

  • International sanctions lists;

  • Terrorism watchlists;

  • Politically exposed persons databases;

  • Regulatory enforcement databases;

  • Adverse media sources.

The Company reserves the right to reject or suspend applicants flagged as high-risk or prohibited.

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14. COMPLIANCE REVIEW PROCEDURES

All KYC applications shall undergo compliance review prior to approval.

14.1 Compliance Review Stages

Stage 1 — Initial Verification

  • Document collection;

  • Identity verification;

  • Basic risk screening.

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Stage 2 — Compliance Assessment

  • AML screening;

  • Beneficial ownership review;

  • Risk scoring.

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Stage 3 — Enhanced Review (if required)

  • Additional documentation;

  • Senior compliance approval;

  • Enhanced due diligence.

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Stage 4 — Approval or Rejection

The Company may:

  • Approve onboarding;

  • Request additional information;

  • Reject applications;

  • Escalate suspicious cases for investigation.

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15. ONGOING MONITORING

The Company shall continuously monitor customer and investor relationships to identify:

  • Unusual activity;

  • Changes in ownership;

  • Suspicious transactions;

  • Regulatory risks;

  • Material compliance changes.

Periodic KYC refreshes may be required.

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16. RECORDKEEPING REQUIREMENTS

The Company shall maintain accurate records of:

  • Verification documents;

  • Compliance reviews;

  • Risk assessments;

  • Investor communications;

  • Regulatory reports.

Records shall be retained in accordance with applicable laws and regulatory requirements.

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17. DATA PROTECTION & CONFIDENTIALITY

All KYC information shall be:

  • Stored securely;

  • Accessed only by authorized personnel;

  • Processed lawfully;

  • Protected against unauthorized disclosure.

The Company shall implement:

  • Encryption systems;

  • Access controls;

  • Cybersecurity safeguards;

  • Secure document storage procedures.

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18. REPORTING OF SUSPICIOUS ACTIVITIES

Where suspicious activity is identified, the Company may:

  • Escalate internally;

  • Conduct investigations;

  • File regulatory reports;

  • Suspend onboarding;

  • Freeze transactions where permitted by law.

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19. NON-COMPLIANCE & ACCOUNT RESTRICTIONS

Failure to provide satisfactory KYC information may result in:

  • Rejection of onboarding;

  • Suspension of services;

  • Restricted transactions;

  • Shareholder limitations;

  • Termination of business relationships.

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20. EMPLOYEE RESPONSIBILITIES

Employees involved in onboarding and compliance must:

  • Follow KYC procedures;

  • Report suspicious activities;

  • Maintain confidentiality;

  • Participate in compliance training.

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21. AUDITS & POLICY REVIEW

The Company shall periodically review and audit its KYC framework to ensure:

  • Regulatory compliance;

  • Operational effectiveness;

  • Risk mitigation improvements.

This Policy may be updated periodically.

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22. GOVERNING LAW

This Policy shall be governed by the laws of:

The Republic of Kenya and applicable international financial compliance regulations.

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23. POLICY APPROVAL

Approved by:

Gamezon Space Corporation

Authorized By: Wycliffe Wejuli
Title: The Company President
Date: 1st May, 2026

Signature: ________________

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OPTIONAL ADVANCED KYC CONTROLS

The Company may additionally implement:

  • AI-powered identity verification

  • Blockchain identity authentication

  • Real-time sanctions monitoring

  • Biometric investor onboarding

  • Video KYC procedures

  • Continuous transaction monitoring

  • Digital shareholder verification systems

  • Cross-border compliance analytics

  • Risk-based automated approvals

  • Multi-factor identity authentication

  • Enhanced cyber-fraud detection systems

  • ESG and reputational risk assessments

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