KYC Policy (Know Your Customer)
Objective:
ZEW implements a Know Your Customer (KYC) procedure to ensure that the NGOs receiving funds are properly verified and comply with applicable laws and regulations, including anti-money laundering (AML) measures. ZEW also requires detailed information from donors in accordance with legal requirements for anti-money laundering and prevent the financing of terrorism(AML).
This KYC Policy ensures that ZEW complies with legal obligations, preventing illicit practices and maintaining a high standard of integrity and transparency in fund management.
Legal Reference:
This policy is aligned with the following legal and regulatory standards:
National Legislation (Portugal):
Law No. 83/2017, of August 18 – Measures to combat money laundering (ML) and the financing of terrorism (FT), transposing Directive (EU) 2015/849.
Law No. 97/2017, of August 23 – Legal regime applicable to the supervision of compliance with preventive ML/FT obligations.
ASAE’s Regulation No. 686/2019 – Defines the specific duties to prevent and combat money laundering and the financing of terrorism of entities subject to ASAE’s supervision.
Combined Framework
This Policy should be read in conjunction with ZEW's Anti-Money Laundering (AML) Policy and ZEW’s Sanctions Policy.
Verification of Counterparts and Partner NGOs
ZEW conducts a thorough verification process for its counterparts, namely the NGOs receiving the funds raised.
This procedure ensures that all partner organizations and counterparts are properly registered and comply with the applicable legislation.
For this purpose, ZEW team members, including employees, shall collect and keep record of the following information:
Required information for Counterpart/NGO verification:
Corporate Name: (required)
Legal person identification number (or equivalent): (required)
Economic activity classification code (or equivalent): (required)
Primary Contact Person (Full Name): (required)
Job Title: (required)
Contact Email: (required)
Contact Phone Number: (required)
Official Address: (required)
Country of Registration: (required)
Required information on each of the individuals in charge of the Counterpart’s/NGO’s management:
Full name: (required)
Date of birth: (required)
Identification document: (required)
Tax identification number (or equivalent): (required)
Full address of permanent residence: (required)
Short description of professional background (e.g. Curriculum Vitae): (required)
Legal Documentation:
Official Registration Certificate: (required)
Governing Documents (Bylaws, Articles of Association): (required)
Annual Budget (current year): (required)
Bank Account Verification (official account of the Counterpart/NGO): (required)
Fund Management & Allocation Policy: (required)
Whenever objectively possible, the identification obligation set forth above must be fulfilled prior to the engagement in a business relationship or partnership.
When it is objectively not possible to fulfill the identification obligation set forth above prior to the engagement in a business relationship or partnership by ZEW, it must be fulfilled immediately afterwards.
The identification obligation set forth above must be fulfilled whenever there is a new business relationship or partnership or, when conducted within the scope of an ongoing relationship, must be updated annually.
Whenever there are changes in the identification elements of the parties or their representatives, the elements collected for compliance with the identification obligations set out above must be updated.
Donor/Beneficiary Verification
ZEW team members, including employees, who have initial contact, in-person or remotely, with individuals or entities that:
(a) donate funds or goods free of charge to ZEW; or
(b) receive funds or goods free of charge from ZEW;
must obtain and verify the identity of these individuals or entities whenever the funds or goods have a value equal to or greater than €100.00 (one hundred euros).
For this purpose, ZEW team members, including employees, shall collect and keep record of the following information:
In the case of individuals:
Full Name: (required)
Date of Birth: (required)
Identification document: (required)
Tax Identification Number (NIF or VAT Number): (required)
Full Address of permanent residence: (required)
In the case of legal persons :
Corporate Name: (required)
Registered office: (required)
Legal person identification number (or equivalent): (required)
Economic activity classification code (or equivalent): (required)
Whenever objectively possible, the identification obligation set forth above must be fulfilled prior to the receipt or delivery of the funds or goods by ZEW.
When it is objectively not possible to fulfill the identification obligation set forth above prior to the acceptance or delivery of funds or goods by ZEW, it must be fulfilled immediately afterwards.
Whenever there are changes in the identification elements of the parties or their representatives, the elements collected for compliance with the identification obligations set out above must be updated.
Crowdfunding
If in the context of ZEW’s crowdfunding projects, before engaging in a given project, ZEW team members, including employees, shall always, irrespective of the amounts involved, collect and keep record of the information set out above as well as the following:
(a) Amounts of funding granted, itemized by supporter and by transaction; and
(b) Payment method.
Whenever objectively possible, the identification obligation set forth above must be fulfilled prior to the receipt or delivery of the funds or goods by ZEW.
When it is objectively not possible to fulfill the identification obligation set forth above prior to the acceptance or delivery of funds or goods by ZEW, it must be fulfilled immediately afterwards.
Whenever there are changes in the identification elements of the parties or their representatives, the elements collected for compliance with the identification obligations set out above must be updated.
Record Conservation
The documents, information and other referenced elements required by this Policy must be kept for a period of 7 years.
The retention of the documents, information, and other referenced elements is done on a durable computerized form that ensures conditions for their proper preservation and easy retrieval, as well as immediate access to them.
Awareness
All members of the ZEW team are informed and made aware of this Policy.
Policy Review
This KYC Policy will be reviewed annually or whenever there are:
Significant legislative changes affecting KYC or anti-money laundering (AML) regulations.
Changes in ZEW's operational risks, including new types of donors, partners, or regions of operation.
New compliance requirements, such as new payment methods or expansion into new countries with different legal frameworks.
Updates to sanctions lists or regulations affecting financial transactions.
The KYC Policy will be updated to ensure continued compliance with applicable laws and to address emerging risks in fund management and donor relations. All updates will be communicated to relevant team members, and training will be provided where necessary to ensure compliance.
[ 1]As per national legislation, specifically Law no. 83/2017, the authority responsible for overseeing compliance with the ZEW's AML-related duties and obligations is not the Bank of Portugal. ZEW is under ASAE's supervision. Consequently, this regulation does not apply directly to ZEW.