KYC / AML Policy

REI Capital Management the fund manager of REI Capital Growth and REI Capital Income (individually and collectively, “REI Capital”) all organized under the laws of the State of Delaware offers investment securities through an internet based, Investor management portal, enabling an investor on-boarding process for the purchase and sale of its own digital securities.

As part of REI Capital’s Compliance policies, Know Your Customer (“KYC”) and Anti Money Laundering (“AML”) policies and procedures for individuals and entity investors have been implemented to enable REI Capital to establish the reasonable belief that it knows the true identity of its investors. The policy applies to all investors in its funds and is followed by all of REI Capital’s employees, consultants, officers, owners and directors.

Using a risk based approach as part of KYC & AML Compliance; REI Capital has contracted with http://netki.com who provides an automated process with the most technically advanced service in the industry.  Every single investor will have to successfully complete this process in order to invest with REI Capital.

Netki provides the most advance ID Validation technology available.

  • It reads over 5000 global ID documents,
  • It automatically detects the applicant’s local language.
  • It can read ID documents in native character sets,
  • Uses advanced biometrics and pixel-by-pixel ID analysis to defeat fraudulent account creation.

Netki meets GDPR, IVMS 101, BIP75, and CCPA standards

 

Process Flow

  1. The Netki mobile application is initiated by the customer, typically by clicking a deep link on their phone. The mobile app is used to ensure that Netki has secure access to the mobile device camera as well as to allow for computer vision and machine learning algorithms to be run on the device to both improve photo capture as well as reduce opportunities for fraud.
  2. The Netki mobile app checks in with the Netki back end to ensure that the version being run is up to date and a part of an authorized application and is running on a real physical device.
  3. The Netki mobile application will coach the user through taking clear photos of their ID, as well as a live selfie. The images are then secured to ensure that they cannot be tampered with or substituted during the remainder of the process.
  4. The images of the identity documents and selfie are securely transferred in encrypted format to the Netki backend using the Netki API. Images are pre-checked and enhanced in preparation for the image analysis in subsequent steps.
  5. Backend Know Your Customer analysis is initiated.
  6. Document validation includes detailed visual inspection of the document using Computer Vision technology.  Doing a pixel by pixel analysis of high resolution photos Netki’s service is able to:
        • Determine that the document is a real official document by examining the security features on the document itself such as holograms, microtext, and other visual features, as well as doing data crosschecks and checksum analysis on the data presented in the document. This examination is done using computer vision and machine learning and we can analyze as many as 60 security features on a high quality document.
        • Examine the document for tamper evidence around the photo or data areas, as well as edges of the document. This examination is done using computer vision and machine learning, and can zoom in to find things that could not be seen with a naked human eye on a physical document.
        • Read the data off of the document such as name, birthdate, document number, etc that can be used for screening purposes in step 8.
  7. Match the document to the selfie using FaceMatch analysis. Netki returns to REI a FaceMatch confidence score.  Scores above the preset confidence threshold automatically pass while those below the threshold are sent to REI Capital’s internal compliance team for manual review/approval in either the Netki dashboard or within the REI Capital Administrative portal.
  8. Sanctions, watch-list and adverse media checks are performed using the person’s name and birthdate from their identity documents. Checks are done against a total of over 800 global law enforcement and regulatory watch-lists as well as Politically Exposed Persons lists.  Adverse media checks are run against over 2,000 global news sources.
  9. The results of the previous steps are compiled and analyzed so that the transaction state can be determined. A record will be automatically declined based on a stolen or expired or otherwise fraudulent document. A record with a low Face-Match score or with a sanctions-watch-list or media hit will be sent to a REI compliance agent for review. A record where the computers were unsure about the ID will be sent to a human compliance agent at Netki for review and will then either be approved or declined as appropriate. All of this is updated in real time both in the Netki dashboard and directly to the REI Capital portal in step 10.
  10. A real time callback is sent from Netki’s system to REI Capital’s system with the full details of the record for further processing and long term storage.
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