Know Your Customer (KYC) Policy

Introduction

VirPoint, operated by Finstar Technologies LTD, is committed to maintaining the highest standards of compliance with anti-fraud, anti-money laundering, and counter-terrorist financing measures. This KYC Policy ensures that all users of virpoint.com are properly identified and verified in line with international best practices, including MiFID II, MiCA, EU AML Directives, and FATF Recommendations.

VirPoint is not a regulated entity, but it voluntarily applies these standards to promote a secure and transparent trading environment.

Scope

This policy applies to all individual, corporate, and joint account holders on the VirPoint platform. It governs account creation, deposits, withdrawals, and ongoing use of the trading platform.

Eligibility

• Users must be at least 18 years old.

• VirPoint does not accept users who are residents of the United States, sanctioned jurisdictions, or any country where CFD trading is prohibited by law.

• Politically exposed persons (PEPs) and users from high-risk jurisdictions are subject to enhanced due diligence and may be restricted from accessing the platform.

Verification Requirements

Individual Clients

• Proof of Identity: a valid government-issued ID such as a passport, national ID card, or driver’s licence.

• Proof of Address: a recent utility bill, bank statement, or official correspondence not older than six months.

Corporate Clients

• Certificate of Incorporation or equivalent

• Articles of Association or governing documents

• Register of Directors and Shareholders

• Proof of business address

• Identity documents and verification for all beneficial owners (holding 25% or more) and directors

Joint Accounts

Each account holder must complete the full KYC process individually.

Verification Process

• KYC may be requested at account registration, before withdrawals, or when deposits exceed certain thresholds.

• Users are required to upload documents through secure channels provided on the platform.

• VirPoint employs third-party verification providers and international databases to validate documents and information.

• Verification is typically completed within 24 to 48 business hours, though delays may occur where additional checks are required.

Ongoing Verification

• VirPoint may request updated KYC documents periodically to ensure records remain accurate and compliant.

• Additional verification may be required for large transactions, suspicious activity, or cross-border transfers.

• KYC information may also be required for account recovery in the event of lost access credentials.

Source of Funds and Enhanced Due Diligence

• VirPoint may request evidence of the source of funds or wealth where activity suggests higher risk or where required under AML frameworks.

• Enhanced due diligence is applied to PEPs, users from higher-risk countries, and transactions involving significant sums or complex structures.

Data Protection

All KYC information is processed in accordance with VirPoint’s Privacy and Cookies Policy and the General Data Protection Regulation (GDPR).

• Documents are encrypted and stored securely on servers located in the EEA and other jurisdictions as required.

• Access is strictly limited to authorised compliance personnel.

• Records are retained for a minimum of five years after account closure or last transaction, in line with AML obligations.

User Responsibilities

By using VirPoint, you agree to:

• Provide complete, accurate, and valid information for verification

• Not misrepresent or falsify your identity or supporting documents

• Cooperate with requests for updated documents or clarification

• Refrain from attempting to bypass KYC requirements

Failure to comply may result in restrictions, delays in withdrawals, suspension, or account closure.

Governing Law

This KYC Policy is governed by the laws of the Marshall Islands. Disputes relating to this policy fall under the jurisdiction of the courts of the Marshall Islands.

Updates to This Policy

VirPoint may update this KYC Policy from time to time to reflect changes in law, regulation, or operational procedures. Updates will be communicated via the platform or by email.

Last Updated: 18 September 2025