Functions of identifying the initial purchasers of INS tokens, verifying the tokenholders’ identity and screening of the tokenholders were delegated to Onfido Limited.
Onfido performs identity record checks, cross-references users’ details against a range of verified global databases and credit reference agencies, as well as performs a document check and ensures that users’ identity documents have not been forged, digitally tampered with, lost or stolen. Onfido also identifies whether an applicant is listed on any global watchlists including:
- Government Sanctions
- Politically Exposed Persons
- Anti-Terrorism watchlists
- Anti-Money Laundering watchlists
- CIA and other government agency wanted/watchlists
- Disqualified directors (global)
Due diligence was performed in strict adherence to the requirements of internal AML and KYC policies. 1,343 individuals from restricted countries were denied purchase of INS tokens, including 1,148 US citizens, US residents, US companies (US Persons) and companies controlled by US Persons.