1. Regulatory Basis
IEC is obligated to conduct customer due diligence (CDD) as a condition of providing financial-adjacent and marketplace services. These obligations arise under: Federal Law No. 115-FZ of 7 August 2001 'On Combating the Legalisation (Laundering) of Proceeds from Crime and the Financing of Terrorism' (as amended); FATF Recommendation 10 (Customer Due Diligence); and, for EU/EEA member activity, Directive (EU) 2018/843 (AMLD5). IEC applies a risk-based approach, conducting enhanced due diligence (EDD) where risk indicators are elevated.
2. KYC — Individual Members
Individual applicants must provide:
- (a) A valid government-issued photo ID — passport (preferred) or national identity card. Documents must be unexpired, clearly legible, and show all data fields.
- (b) Proof of address — a utility bill, bank statement, or official government letter dated within the last 3 months showing your legal name and residential address. P.O. box addresses are not accepted.
- (c) A selfie or live video check where required by our automated verification system or where risk indicators require additional assurance.
- (d) A professional reference letter from a current IEC member (required for applicants from higher-risk jurisdictions as determined by FATF grey/black list status).
3. KYB — Organisational Members
Organisations must provide:
- (a) Certificate of incorporation or state registration extract dated within 12 months
(b) Articles of association or equivalent constitutional document
(c) Corporate registry excerpt showing current directors and shareholders
(d) Beneficial ownership declaration identifying all ultimate beneficial owners (UBOs) holding 25% or more, with supporting evidence
(e) Each UBO must complete an individual KYC process as described in Clause 2
(f) A signed authorisation confirming that the signatory has authority to bind the entity
(g) For PEP-linked entities: additional documentation as requested by the compliance team.
4. Sanctions Screening and PEP Checks
All applicants, their UBOs, and key counterparties are screened against: UN Security Council sanctions lists; EU Consolidated Financial Sanctions List; OFAC SDN and other restricted party lists; HM Treasury Consolidated List; Russian Federal Service for Financial Monitoring (Rosfinmonitoring) lists; and Politically Exposed Persons (PEP) databases. A positive match triggers an Enhanced Due Diligence process requiring additional source of wealth documentation and senior compliance officer review. IEC will not onboard or retain members who are subject to applicable sanctions. PEP status does not automatically disqualify an applicant but requires EDD completion.
5. Ongoing Monitoring and Re-Verification
Verification is not a one-time event. IEC conducts periodic re-verification (minimum every 2 years for standard risk, annually for enhanced risk) and triggers re-verification upon: a change in beneficial ownership; a change in the member's country of residence or registered address; detection of a new sanctions match; or a material change in transaction profile. Members are required to notify IEC of any change in the information provided during verification within 14 calendar days of the change.
6. Data Retention
KYC/KYB documentation is retained for 5 years after the end of the business relationship, in accordance with FATF Recommendation 11 and Article 7 of Federal Law 115-FZ. Documentation is stored encrypted and access is restricted to authorised compliance team members on a need-to-know basis. After the retention period, documents are securely deleted. You may request information about your retained KYC/KYB data by contacting compliance@internationalenergyclub.org.
Document versioning and re-acceptance
This document was last updated on Nov 1, 2025. IEC maintains a versioned archive of all prior versions. Where a material change affects the rights or obligations of existing members, affected members are notified by email at least 14 days before the change takes effect. Continued use of the platform after the effective date constitutes acceptance of the updated terms. To request a prior version, contact legal@internationalenergyclub.org.