Business Verification

At Orum, we make risk management a priority by maintaining a comprehensive Customer Due Diligence (CDD) program throughout the entire customer relationship. Our program involves two methods of identification: Know Your Customer (KYC) for persons and Know Your Business (KYB) for businesses.

KYB involves identity verification of a business in addition to ensuring that customers are not on any government-sanctioned lists. At Orum, we provide two options for verification: BYO-KYB and Orum-KYB.

BYO-KYB

BYO-KYB is an offering that allows you to conduct your own KYB process. To qualify for this partnership, you must provide Orum with your BSA/AML Policy and/or procedure detailing your internal KYB process, in addition to a virtual walkthrough of the process with Orum Compliance. Our compliance team reviews and verifies the adequacy of your KYB process with regard to Orum's financial partner agreements and Federal Financial Institutions Examination Council (FFIEC) compliance.

For BYO-KYB, you are responsible for performing adequate identity verification on your individual customers. Specifically, Orum must verify that you obtain and screen for the following, at a minimum, at onboarding and on an ongoing basis:

• Full legal business name
• Physical address
• Tax ID (TIN/EIN)
• Incorporation date

Orum will still perform watchlist screening on all businesses, regardless of use case, at the time of onboarding and on an ongoing basis. Orum reserves the right to reject or restrict any customer from utilizing Orum's products or services regardless of the use case.

Orum-KYB

Orum-KYB is an additional service that we provide if you do not have an existing CIP process established and do not plan to set one up for your own platform. This service removes the complexities of having to create and manage your own CIP in-house and puts the onus on Orum to verify the identities and ensure none of your customers are sanctioned individuals or business entities. We use third-party vendors to perform KYB verification on all Orum customers to verify their true identity prior to transacting with Orum's product.

For Orum-KYB, we obtain the following information, at a minimum, and screen it through our third-party vendor at onboarding and on an ongoing basis:

• Full legal business name
• Physical address
• Tax ID (TIN/EIN)
• Incorporation date

All businesses in Orum-KYB are enlisted to watchlist screening, which provides constant monitoring and updates to various sanctioned lists (OFAC-SDN, OFAC NON-SDN, etc.).