Meridian S.A. ("Meridian", "Company", "we", "our", or "us") is committed to maintaining a secure and compliant platform through appropriate customer identification and verification procedures.
This Know Your Customer ("KYC") Policy explains how Meridian verifies the identity of Users, business customers, beneficial owners, and other persons where verification is required.
This Policy forms part of Meridian's legal framework and should be read together with the:
- Terms of Service
- Privacy Policy
- AML & Compliance Policy
- Custody Policy
2. Scope
This Policy applies to:
- individual Users
- business customers
- merchants
- API customers
- beneficial owners
- authorized representatives
- directors
- officers
- controlling persons of legal entities
Verification requirements vary according to:
- applicable law
- product used
- jurisdiction
- transaction risk
- customer risk profile
- operational requirements
3. Risk-Based Verification
Meridian applies a risk-based approach when determining verification requirements. Verification measures are proportionate to the assessed level of risk.
Factors considered may include:
- jurisdiction
- transaction size
- transaction frequency
- customer type
- source of funds
- blockchain exposure
- sanctions exposure
- delivery channel
- intended use of the Platform
- previous compliance history
Meridian reserves the right to increase verification requirements where additional risk is identified.
4. Customer Identification
Before providing certain Services, Meridian may require Users to establish their identity.
Depending on the circumstances, Users may be required to provide:
- full legal name
- residential address
- nationality
- date of birth
- telephone number
- email address
- government-issued identification
- tax residency
- additional information reasonably required for compliance purposes
Information provided must be complete, accurate, and current.
Providing false or misleading information may result in immediate suspension or termination of Services.
5. Individual Verification
Individual Users may be required to complete identity verification using one or more verification methods.
Verification may include:
- government-issued passport
- national identity card
- residence permit
- driver's license where accepted
- selfie verification
- liveness detection
- facial comparison
- proof of address
- additional supporting documentation
Meridian determines which documents are accepted.
6. Business Verification
Legal entities may be required to provide documentation demonstrating their legal existence and ownership.
Business verification may require:
- certificate of incorporation
- articles of incorporation
- shareholder register
- register of directors
- certificate of good standing
- beneficial ownership information
- constitutional documents
- tax registration documents
- proof of business address
Additional documentation may be requested depending on the jurisdiction and risk profile.
7. Beneficial Ownership
Where Services are provided to legal entities, Meridian may identify the natural persons who ultimately own or control the organization.
Meridian may request:
- ownership structure
- shareholder information
- ownership percentages
- director information
- authorized signatories
- supporting corporate documents
Meridian reserves the right to request clarification where ownership structures are unusually complex.
8. Identity Verification Providers
Meridian may use independent third-party verification providers to assist with identity verification.
Such providers may perform:
- document authentication
- biometric verification
- facial comparison
- liveness detection
- identity validation
- fraud detection
- sanctions screening
Use of third-party verification services does not reduce Meridian's ability to request additional documentation.
9. Ongoing Verification
Identity verification is not limited to onboarding. Meridian may request updated documentation:
- periodically
- following material account changes
- after unusual activity
- before high-value transactions
- where required by law
- following changes in risk assessment
Failure to complete ongoing verification may result in restrictions, suspension, or termination of the Account.
10. Identity Documents
Meridian may request one or more identity documents to verify the identity of a User.
Accepted documents may include:
- passport
- national identity card
- residence permit
- driver's license, where accepted
- government-issued travel documents
- corporate identification documents
- tax registration certificates
- other official documentation deemed acceptable by Meridian
Documents must:
- be valid and unexpired
- contain sufficient identifying information
- be clearly legible
- be complete
- not appear altered or manipulated
Meridian reserves the right to reject documentation that cannot be satisfactorily verified.
11. Proof of Address
Where appropriate, Meridian may request documentation confirming a User's residential or business address.
Acceptable documents may include:
- utility bills
- bank statements
- government correspondence
- tax notices
- residence certificates
- other documents approved by Meridian
Proof of address documents may be subject to maximum age requirements determined by Meridian.
12. Enhanced Due Diligence (EDD)
Enhanced Due Diligence may be applied where increased legal, regulatory, operational, or financial crime risks are identified.
EDD measures may include:
- additional identity documentation
- supplementary proof of address
- source of funds verification
- source of wealth verification
- business activity verification
- beneficial ownership verification
- senior compliance approval
- additional interviews
- enhanced transaction monitoring
Completion of EDD does not guarantee continued access to the Platform.
13. Source of Funds
Meridian may request information regarding the lawful origin of Digital Assets or fiat funds used in connection with the Platform.
Examples may include:
- employment income
- business income
- investments
- inheritance
- sale of assets
- mining activities
- lending
- dividends
- other lawful sources
Supporting documentation may be requested where appropriate.
14. Source of Wealth
Where appropriate, Meridian may request information concerning the origin of a User's overall wealth.
Examples include:
- employment history
- business ownership
- investments
- inheritance
- sale of businesses
- sale of real estate
- other lawful economic activity
Meridian evaluates Source of Wealth using a risk-based approach.
15. Wallet Ownership Verification
To protect Users and maintain Platform integrity, Meridian may request evidence that a User controls an external blockchain wallet.
Verification methods may include:
- signing a blockchain message
- micro-transaction verification
- wallet challenge-response verification
- blockchain ownership confirmation
- other technically appropriate methods
Failure to complete wallet ownership verification may result in restrictions on certain Services.
16. Biometric Verification
Meridian or its authorized verification providers may use biometric technologies to assist in identity verification.
Such technologies may include:
- facial comparison
- facial recognition
- selfie verification
- biometric similarity analysis
- liveness detection
Biometric verification is used solely for identity verification, fraud prevention, and Platform security.
Biometric data is processed in accordance with the Meridian Privacy Policy and applicable data protection laws.
17. Liveness Detection and Anti-Spoofing
Meridian may require Users to complete liveness detection procedures to confirm that identity verification is performed by a real person.
Liveness verification may include:
- facial movement analysis
- video verification
- device integrity checks
- challenge-response verification
- anti-spoofing controls
Meridian may reject verification attempts where manipulation, impersonation, or fraudulent activity is suspected.
18. Artificial Intelligence and Fraud Detection
Meridian may use automated technologies, including artificial intelligence and machine learning, to assist with identity verification and fraud prevention.
Such technologies may be used to:
- detect forged identity documents
- identify image manipulation
- detect deepfake content
- identify duplicate identities
- detect identity theft
- identify unusual verification behavior
- support risk assessment
Automated systems assist Meridian's compliance personnel and do not necessarily replace human review.
19. Video Verification
Where Meridian determines that additional verification is appropriate, Users may be required to participate in a live or recorded video verification process.
Video verification may be used to:
- confirm identity
- compare identity documents
- verify liveness
- investigate suspected fraud
- complete Enhanced Due Diligence
Meridian reserves the right to refuse verification where identity cannot be established with reasonable confidence.
20. Failure to Complete Verification
Meridian may refuse, suspend, restrict, or terminate access to the Platform where a User:
- fails to complete required verification
- provides false information
- submits fraudulent documentation
- refuses reasonable compliance requests
- cannot be satisfactorily identified
- presents unacceptable compliance risks
Meridian is not obligated to disclose internal compliance methodologies or fraud detection criteria.
Where permitted by Applicable Law, Meridian may decline to explain the specific reasons for a verification decision.
21. Record Keeping
Meridian maintains records relating to identity verification, customer due diligence, enhanced due diligence, beneficial ownership, and compliance activities in accordance with applicable legal obligations and internal compliance procedures.
Records may include:
- identity verification documents
- proof of address documentation
- biometric verification records
- liveness verification results
- source of funds documentation
- source of wealth documentation
- beneficial ownership information
- corporate verification documents
- compliance communications
- verification audit logs
- fraud investigation records
Verification records are retained only for as long as reasonably necessary to:
- comply with Applicable Law
- satisfy regulatory obligations
- support internal investigations
- resolve disputes
- enforce Meridian's legal rights
- protect Platform security
Upon expiration of the applicable retention period, records may be securely deleted, anonymized, or otherwise disposed of in accordance with Meridian's internal retention procedures.
22. Protection of Verification Information
Meridian implements administrative, technical, and organizational safeguards designed to protect identity verification information.
Security measures may include:
- encryption
- secure document storage
- role-based access controls
- multi-factor authentication
- audit logging
- secure transmission protocols
- restricted internal access
- continuous security monitoring
Verification information is accessible only to authorized personnel and approved service providers with a legitimate business need.
23. Fraud Prevention
Meridian continuously evaluates verification activity for indicators of fraud or identity abuse.
Fraud prevention measures may include:
- duplicate identity detection
- forged document detection
- document authenticity analysis
- biometric comparison
- liveness verification
- device risk analysis
- IP address analysis
- behavioral analytics
- blockchain risk indicators
- account linkage analysis
- sanctions screening
- adverse media screening
Meridian reserves the right to suspend or terminate verification where fraudulent activity is reasonably suspected.
24. Third-Party Verification Providers
Meridian may engage independent third-party providers to assist with identity verification and compliance.
Such providers may perform services including:
- document authentication
- biometric verification
- facial comparison
- liveness detection
- sanctions screening
- politically exposed person screening
- fraud detection
- blockchain analytics
- address verification
- identity validation
Meridian seeks to engage providers that maintain appropriate security, confidentiality, and operational standards.
Use of third-party providers does not limit Meridian's ability to request additional information directly from Users.
25. User Responsibilities
Users are responsible for:
- providing accurate information
- maintaining up-to-date identification information
- responding to verification requests promptly
- protecting their Account credentials
- notifying Meridian of material changes to their personal information where relevant
Users must not:
- submit false documentation
- alter identity documents
- impersonate another individual
- conceal beneficial ownership
- use stolen identities
- attempt to circumvent verification procedures
Providing false or misleading information may result in immediate restriction or termination of Services and, where required by law, reporting to competent authorities.
26. Reverification
Meridian may require Users to complete reverification at any time where reasonably necessary.
Reverification may be required due to:
- expiration of identity documents
- changes in customer information
- unusual transaction activity
- changes in risk assessment
- enhanced regulatory requirements
- introduction of new Services
- security incidents
- periodic compliance reviews
Failure to complete reverification may result in temporary or permanent restrictions on the Account.
27. Refusal of Verification
Meridian reserves the right to refuse identity verification where:
- identity cannot be established with reasonable confidence
- documentation appears fraudulent or altered
- inconsistent information is provided
- legal or regulatory restrictions apply
- unacceptable compliance risks are identified
- verification requirements are not satisfied
Meridian is not obligated to disclose internal verification methodologies, fraud detection criteria, or compliance thresholds.
Where permitted by Applicable Law, Meridian may decline to provide specific reasons for a verification decision.
29. Policy Updates
Meridian may amend this KYC Policy from time to time to reflect:
- changes in Applicable Law
- regulatory developments
- technological improvements
- operational changes
- security enhancements
- new verification methods
- business developments
Updated versions become effective upon publication unless a later effective date is specified.
Continued use of the Platform following publication constitutes acceptance of the updated Policy.
30. Contact Information
Questions regarding this KYC Policy or identity verification procedures may be submitted through Meridian's official communication channels published on the Platform.
Requests relating to identity verification, compliance reviews, or KYC documentation should be directed to the designated compliance contact published by Meridian.
31. Effective Date
This KYC Policy is effective from the date stated above and remains in force until amended or replaced by Meridian S.A.
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