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Doc 15 — KYC / AML / Identity Verification Notice

  • Document: 15 — KYC / AML / Identity Verification Notice
  • Version: 15-kyc-aml-notice-2026-08 (in force on publication)
  • Party / entity: issued by Upvue Pte Ltd (UEN 201201846Z), 10 Bukit Batok Crescent, The Spire, #10-05B, Singapore 658079, providing services on the Platform under the name "UpVue" (the "Firm") — a registered Corporate Service Provider in Singapore — as the professional responsible for client due diligence, with platform tooling provided by DPW Pte. Ltd. (UEN 202017982R, 247B Victoria St, Singapore 188033) ("DPW"). This Notice (the "KYC Notice") is an information notice, not a contract: the obligations it describes arise under the Singapore Terms of Business (Doc 03) and the Client Authorisation and Representation Terms ("Client Authorisation Terms") (Doc 14).
  • Audience: Customers and any individuals (directors, shareholders, beneficial owners, authorised representatives) whose identity is verified in connection with an Engagement

1. Why we must verify your identity

1.1 The Firm is a registered Corporate Service Provider. Before it can incorporate a company, act as corporate secretary, provide a registered office or nominee arrangement, or make filings for you, Singapore law — the Corporate Service Providers Act 2024 and the Corporate Service Providers Regulations 2025 — requires it to perform client due diligence ("CDD"): identifying and verifying you and related persons, understanding your ownership and control structure, and assessing money-laundering, terrorism-financing and proliferation-financing risk.

1.2 This is not optional for the Firm or for you. Verification is a legal precondition to the services, and the Firm must decline or stop work where it cannot be completed.

1.3 Collection of your NRIC, FIN or passport number is done because these laws require it. Consistent with the PDPC's Advisory Guidelines on the NRIC, the legal basis for collecting your national identification number is that collection is required under law; it is never used to authenticate you or as a password.

2. Who is responsible for verification

2.1 The Firm performs and owns CDD. Every CDD decision — verifying your identity, determining beneficial ownership, assigning a risk rating, requesting further information, and accepting, declining or exiting a relationship — is made by the Firm's own authorised personnel.

2.2 The Platform is tooling only. DPW provides the Firm with the technology used to collect documents, run screening and manage the workflow. DPW is not a Corporate Service Provider and does not make CDD decisions. No result produced by the Platform or by any third-party provider approves anything by itself: a "clear" screening result is an input to the Firm's decision, never the decision.

3. What we collect

3.1 Depending on your role and the service, the Firm collects through the Platform:

  • (a) identity documents (e.g. NRIC, FIN card or passport, and where relevant proof of address);
  • (b) NRIC/FIN or passport number, full name, date of birth, nationality and residential address;
  • (c) declarations on politically exposed person ("PEP") status;
  • (d) information on source of funds and source of wealth, where the risk assessment requires it;
  • (e) beneficial-ownership information — who ultimately owns or controls the company; and
  • (f) for corporate parties, corporate documents and the identities of relevant officers and controllers.

3.2 Details of retention and of the service providers involved are in Doc 17 — Document Retention / Records Notice ("Retention Notice") and Doc 06 — Subprocessor and Service Provider Notice.

4. How verification works

4.1 Document upload. You upload identity documents through the secure portal. The Firm's staff review them; automated tooling assists with extraction and checking, but a person always reviews before any approval.

4.2 Screening. Names (with date of birth and nationality where provided) are checked against international sanctions, PEP and adverse-media databases through a specialist screening provider (see Doc 06). Screening is name-and-date-of-birth based; your NRIC/FIN or passport number is not sent to the screening provider.

4.3 Video identity verification. Where offered for your case, you may be asked to complete a short video identity verification step with an identity-verification provider (see Doc 06).

4.4 No government identity integration. The Platform does not currently verify your identity through MyInfo, Singpass or any other government identity service. Verification relies on the documents and information you provide, plus the checks above.

5. Automated assistance — and human decisions

5.1 To help the Firm work efficiently, the Platform automatically classifies some results. Where screening returns no match at all, the record is automatically marked and given an assisting risk classification. Any potential match, discrepancy or system error is automatically routed to a person and must be resolved by human review; the automated step never resolves it.

5.2 Whatever the tooling suggests, every KYC decision is made by the Firm's authorised personnel, and certain roles require approval by two people. No automated step approves anything: no engagement is approved, and no filing is made, without a human professional decision (see Doc 20 Section 2 for the full decision chain).

6. What happens if something needs a closer look

6.1 If screening returns a possible match, or the Firm's review raises questions, the Firm may ask you for more information or documents — for example to distinguish you from someone else with a similar name, or to evidence source of funds. This is routine and does not mean you are suspected of anything.

6.2 The Firm may decline to act, or exit an existing relationship, where its legal obligations require it. No filing is submitted to ACRA until every person required to be screened has been screened and approved by the Firm. This can affect timing; neither the Firm nor DPW guarantees any incorporation or processing timeframe.

7. Your duties

7.1 You must: give truthful and complete declarations (including PEP, source-of-funds and beneficial-ownership information); provide authentic, unaltered documents; respond to requests within the time asked; and tell the Firm promptly if any information you gave changes.

7.2 If you do not, the consequences can include: delay to your matter; the Firm declining to act or exiting the Engagement; and, where the law requires, a report to the authorities. Providing false information in connection with corporate filings can also be an offence. Your contractual obligations are set out in Doc 03 and Doc 14.

8. People you nominate

8.1 If you nominate directors, shareholders, beneficial owners or other participants, each of them will be verified and screened in the same way. It is your duty to inform each of them, before you submit their details, that their personal data will be collected, verified and screened as described in this Notice and in Doc 04 — Privacy Notice, and to have the authority to provide their details (see Doc 14 — Client Authorisation Terms).

9. How your verification data is protected

9.1 Identity documents are held in private storage with access through short-lived links; sensitive fields such as NRIC/passport numbers, date of birth and address, and raw screening results, are encrypted at the field level; access is restricted to authorised personnel of the Firm and, for platform operation, DPW.

9.2 CDD records are kept for at least five years after the end of the business relationship, because the Corporate Service Providers Act 2024 requires it — even if you ask for earlier deletion (see Doc 17 — Retention Notice). How personal data is handled generally, including overseas service providers, is described in Doc 04 — Privacy Notice and Doc 06 — Subprocessor and Service Provider Notice.

10. Reporting duties override confidentiality

10.1 Where the law requires, the Firm must file reports (including suspicious transaction reports) with the Singapore authorities. The law prohibits "tipping-off": the Firm may be legally unable to tell you that a report has been made, or to explain the real reason for a delay or a declined engagement. Silence or delay in these situations is a legal constraint, not discourtesy.

11. Questions

11.1 Questions about this Notice or about a verification request: contact support through the portal, or the Data Protection Officer at dpo@csfile.ai. Requests about your personal data (access, correction) follow Doc 04 — Privacy Notice and Doc 19 — Data Subject Request Procedure.

Version: 15-kyc-aml-notice-2026-08 · Approval: management-attested