The Watch Aficionado Know Your Customer (KYC) Policy

Know Your Customer (kyc) Policy – The Watch Aficionado

Know Your Customer (KYC) Policy

1. Purpose

The purpose of this Know Your Customer (KYC) Policy is to establish clear standards and procedures for verifying the identity of customers of The Watch Aficionado, including its retail location(s) and its website thewatchaficionado.com. This policy supports compliance with Anti-Money Laundering (AML) laws and helps prevent fraud, money laundering, terrorist financing, and other financial crimes.

2. Scope

This KYC Policy applies to:

  • All customers of The Watch Aficionado

  • In-store and online transactions

  • One-time and repeat customers

  • High-value and high-risk transactions

  • All employees, contractors, and management involved in sales, payments, or customer onboarding

3. Regulatory Framework

This policy is designed to align with applicable U.S. laws and regulatory expectations, including:

  • Bank Secrecy Act (BSA)

  • USA PATRIOT Act

  • FinCEN guidance

  • Applicable state and local regulations

4. Risk-Based Customer Identification Approach

The Watch Aficionado follows a risk-based approach when applying KYC measures. The level of customer verification depends on factors such as:

  • Transaction value

  • Payment method

  • Customer location

  • Transaction frequency

  • Delivery or shipping destination

5. Customer Identification Program (CIP)

5.1 When Identification Is Required

Customer identification may be required in the following circumstances:

  • High-value transactions

  • Cash transactions

  • Wire transfers

  • Online purchases requiring shipment

  • Transactions deemed unusual or high risk

5.2 Information Collected

When applicable, The Watch Aficionado may collect and verify:

  • Full legal name

  • Government-issued photo identification

  • Date of birth (for individuals)

  • Residential or business address

  • Contact information (email and phone number)

  • Payment method details

6. Verification Methods

Customer identity may be verified using one or more of the following methods:

  • Review of government-issued photo ID

  • Matching customer information to payment details

  • Third-party identity verification services

  • Confirmation of billing and shipping addresses

7. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be conducted for higher-risk customers or transactions, including:

  • High-value or repeat luxury watch purchases

  • Cash-intensive transactions

  • International customers or shipping

  • Politically Exposed Persons (PEPs)

  • Requests for third-party payments or anonymity

EDD measures may include requesting additional documentation, source of funds information, or management approval prior to completing the transaction.

8. Ongoing Monitoring

The Watch Aficionado conducts ongoing monitoring of customer activity to identify:

  • Unusual or inconsistent purchasing behavior

  • Attempts to structure transactions

  • Changes in customer risk profile

  • Repeated high-value transactions without clear economic purpose

9. Online Sales and Website KYC Procedures

For transactions conducted via thewatchaficionado.com:

  • Customer identity verification may be required before order fulfillment

  • Orders may be delayed, declined, or canceled pending verification

  • IP address, payment data, and shipping information may be reviewed for fraud and compliance purposes

10. Recordkeeping and Data Retention

The Watch Aficionado maintains KYC-related records, including:

  • Customer identification documents

  • Verification results

  • Transaction history

  • Internal risk assessments

Records are retained for a minimum of five (5) years or longer if required by law.

11. Data Protection and Privacy

All customer information collected under this KYC Policy is handled securely and in accordance with applicable privacy and data protection laws. Access to KYC information is limited to authorized personnel only.

12. Refusal of Service

The Watch Aficionado reserves the right to refuse or discontinue business relationships when:

  • Required identification is not provided

  • Information cannot be verified

  • A transaction presents unacceptable risk

  • Suspicious activity is identified

13. Training and Awareness

Employees involved in customer onboarding and transactions receive periodic training on:

  • KYC requirements

  • Identifying red flags

  • Escalation and reporting procedures

  • Confidentiality obligations

14. Compliance Oversight

Oversight of this KYC Policy is the responsibility of the designated AML/KYC Compliance Officer, who ensures:

  • Proper implementation of procedures

  • Periodic review and updates

  • Alignment with AML policies and regulations

15. Policy Review and Updates

This KYC Policy is reviewed at least annually and updated as needed to reflect regulatory changes or business developments.

16. Acceptance

By engaging in transactions with The Watch Aficionado, customers acknowledge and agree to comply with applicable identification and verification requirements.

The Watch Aficionado

Effective Date: 1/20/2026