| Document Version: 1.1 |
| Effective Date: 21 December, 2025 |
| Last Reviewed: 11 January, 2026 |
1. Purpose and Scope
This Customer Identification Program (CIP) establishes the policies and procedures that NEO Global Pty Ltd (“NEO”) uses to verify the identity of its Customers and Partners before establishing a business relationship and processing payments through the NEO platform.
This program is designed to comply with applicable anti-money laundering (AML) regulations and to mitigate the risk of NEO being used for money laundering, terrorist financing, fraud, or other illicit activities.
This policy applies to:
Customers: Businesses that use the NEO platform to engage In-Country Partners and process payments (e.g. tech start ups, professional services, venture capital, staffing agencies, MSPs, EOR providers, enterprises).
Partners: In-Country Partners and service providers who receive payments through the NEO platform.
2. Customer and Partner Identification Requirements
2.1 Know Your Business (KYB) — Business Verification
Before onboarding any Customer or Partner, NEO collects and verifies the following information:
Business Information:
• Legal business name
• Trading name (if different)
• Business registration number (e.g., ABN, ACN, EIN, Company Number)
• Country and date of incorporation
• Registered business address
• Principal place of business (if different)
• Business type and industry classification
Supporting Documentation:
• Certificate of Incorporation or equivalent registration document
• Business license (where applicable)
• Proof of registered address (utility bill, bank statement, or government correspondence dated within 3 months)
2.2 Beneficial Ownership Identification
NEO identifies and verifies all individuals who own or control 25% or more of the business entity. For each beneficial owner, NEO collects:
• Full legal name
• Date of birth
• Nationality
• Residential address
• Percentage of ownership or nature of control
• Government-issued photo identification (passport, driver’s license, or national ID)
2.3 Know Your Customer (KYC) — Authorised Representatives
NEO verifies the identity of individuals authorised to act on behalf of the business. For each authorised representative:
• Full legal name
• Job title and role
• Business email address
• Phone number
• Government-issued photo identification
3. Sanctions and Watchlist Screening
NEO screens all Customers, Partners, beneficial owners, and authorised representatives against applicable sanctions and watchlists at the time of onboarding and on an ongoing basis. Screening includes:
• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Consolidated List
• EU Consolidated Sanctions List
• UK HM Treasury Sanctions List
• DFAT Consolidated List (Australia)
• Other relevant local sanctions lists based on jurisdiction
Any potential match is escalated to the Compliance Officer for review. No business relationship will be established, and no payments will be processed, until a potential match has been cleared or confirmed.
4. Risk Assessment
NEO assigns a risk rating to each Customer and Partner based on the following factors:
• Country of incorporation and operation (high-risk jurisdictions)
• Industry and business type
• Ownership structure complexity
• Politically Exposed Person (PEP) status of beneficial owners
• Expected transaction volumes and frequency
• Source of funds
Risk Categories:
| Low Risk | Standard verification; periodic review annually |
| Medium Risk | Enhanced due diligence; review every 6 months |
| High Risk | Enhanced due diligence; senior approval required; review quarterly |
5. Ongoing Monitoring
NEO conducts ongoing monitoring of Customer and Partner activity to detect and report suspicious transactions. Monitoring includes:
• Transaction monitoring for unusual patterns, volumes, or destinations
• Periodic re-screening against sanctions and watchlists
• Review of changes to business information or ownership
• Adverse media screening
Any suspicious activity is escalated to the Compliance Officer for investigation and, where required, reported to the relevant financial intelligence unit (e.g., AUSTRAC, FinCEN).
6. Record Keeping
NEO maintains records of all identification and verification documents, transaction records, and compliance decisions for a minimum of seven (7) years from the date of the last transaction or termination of the business relationship, whichever is later.
Records are stored securely and made available to regulatory authorities upon lawful request.
7. Prohibited Clients
NEO will not establish or maintain a business relationship with:
• Shell companies with no legitimate business purpose
• Gambling or gaming operators
• Adult entertainment businesses
• Cannabis-related businesses
• Entities or individuals on any applicable sanctions list
• Any business engaged in illegal activities
8. Training
All NEO employees involved in customer onboarding, transaction processing, or compliance functions receive AML/CIP training upon hire and annually thereafter. Training covers:
• CIP policies and procedures
• Red flags for money laundering and fraud
• Sanctions compliance
• Escalation and reporting procedures
9. Compliance Officer
NEO has designated a Compliance Officer responsible for:
• Implementing and maintaining this CIP
• Reviewing and resolving escalated compliance matters
• Filing suspicious activity reports (SARs) as required
• Liaising with regulatory authorities
• Conducting periodic reviews and updates of this policy
Designated Compliance Officer: Martin Konrad, CEO & Founder, compliance@neohr.io
10. Policy Review
This CIP is reviewed at least annually, or more frequently if required due to regulatory changes, changes in NEO’s business model, or identified compliance gaps.
