Person Verification

Risk management is a priority and Orum maintains a comprehensive Customer Due Diligence (CDD) program throughout the customer relationship. Our program involves two identification methods:

• Know Your Customer (KYC) for persons
• Know Your Business (KYB) for businesses

KYC involves identity verification of a person in addition to ensuring that customers are not on any government-sanctioned lists. We provide two options for verification:

• BYO-KYC (bring your own)
• Orum-KYC

BYO-KYC

BYO-KYC (bring your ow-KYC) allows you to conduct your own KYC process. To utilize this option, you must provide Orum with your BSA/AML Policy and procedures detailing your internal KYC process, in addition to a virtual walkthrough of the process with our compliance team. Orum reviews and verifies the adequacy of your KYC process in conjunction with our financial partner agreements and Federal Financial Institutions Examination Council (FFIEC) compliance.

For BYO-KYC, you need to conduct adequate identity verification on your individual customers. At a minimum, you must verify the following information:

• Full legal name
• Physical address
• Tax ID (SSN)
• Date of birth

Orum performs watchlist screening on all individuals during onboarding and on an ongoing basis. Orum reserves the right to reject or restrict any customer from utilizing our services.

Orum-KYC

Orum-KYC is an additional service we provide if you don't have a Customer Identification Program (CIP) established and don't plan to set one up for your platform. This option manages the complexities of creating and maintaining your own CIP in-house. We use third-party vendors to perform KYC verification on all Orum customers to verify their true identity before transacting with our product.

For Orum-KYC, we obtain and screen the following information through our third-party vendor at onboarding and on an ongoing basis.

• Full legal name
• Physical address
• Tax ID (SSN)
• Date of birth

All individuals in Orum-KYC undergo watchlist screening, which provides constant monitoring and updates to various sanctioned lists (OFAC-SDN, OFAC NON-SDN, etc.).