The KYC obligations commence the moment the ICO firm invites expressions of interest from the public and must be completed before receipt of proceeds from the token sale.
The KYC requirements under POCA would include;
Verification if person is a PEP, family member or close associate; determining that the applicant is not a designated person for TF, etc, or whether there are linked transactions with previous ICO.
Determining that the applicant is not a designated person for TF, etc,or;
whether there are linked transactions within the same ICO, regardless if this is during pre-sale or public sale stage.
It is generally accepted by the GFSC, that unless tokens can be withheld, due diligence is required to be collected on potential contributors before a public token sale takes place (a ‘white listing’ process).The extent of the captured due diligence would then be reviewed and adjusted under a risk based approach to ensure appropriateness on an offering by offering basis. Nonetheless, the FSC will consider alternative arrangements as long as the KYC obligations are met before receipt of proceeds.