MARKETPLACE SELLER VERIFICATION & KYC POLICY

1. Purpose

This Policy establishes procedures for collecting, verifying, and maintaining information about Marketplace Sellers in compliance with the INFORM Consumers Act and related regulations.

2. Scope

Applies to all Marketplace Sellers offering goods or services through [MARKETPLACE NAME], including domestic and international sellers shipping to U.S. customers.

3. Key Definitions

• Marketplace Seller: Any person or business that has entered into an agreement with [MARKETPLACE NAME] to sell goods or services.
• High-Volume Third-Party Seller: Sellers with 200 or more discrete sales and $5,000+ in aggregate revenue over a 12-month period.
• Verify/Verification: Confirmation of seller identity through reliable data sources or documentation.

4. Data Collection Requirements

4.1 Baseline Data (All Sellers). Collect name, business entity type, contact information, tax identification number, and bank account details.
4.2 High-Volume Sellers. Obtain additional information: government-issued ID, business tax filings, bank statements, working email and phone, and business address.
4.3 Certified Statements. Require sellers to attest that information is accurate and updated within [10] days of changes.
4.4 Sensitive Data Handling. Store sensitive documents in encrypted systems with access limited to authorized personnel.

5. Verification Procedures

5.1 Initial Verification. Conduct verification within [10] days of reaching High-Volume threshold using third-party services or manual review.
5.2 Annual Certification. Send automated reminders [ANNUAL DATE] requiring sellers to certify information accuracy. Suspend accounts that fail to respond within [10] days.
5.3 Discrepancies. Investigate discrepancies identified through consumer complaints, law enforcement requests, or automated monitoring. Document findings in Appendix B.
5.4 Reverification. Trigger reverification when sellers exceed [REVENUE THRESHOLD], change ownership, or exhibit suspicious behavior.

6. Seller Disclosure Requirements

• Display seller name and contact information on product listing pages consistent with legal requirements.
• Provide additional disclosures (phone, email, address) to consumers after purchase or upon request.
• Maintain a process for consumers to report suspicious activity via [CONTACT CHANNELS].
• Offer a prominently labeled “Report Suspicious Seller” channel (email, phone, and webform) and document response timelines consistent with the INFORM Act.

7. Suspension & Termination

• Suspend sellers that fail to provide required information within [10] days of request.
• Terminate sellers engaging in fraud, counterfeit goods, or repeated policy violations.
• Document actions taken and retain records for at least [YEARS] years.

8. Recordkeeping & Audit

• Retain seller verification records, communications, and certifications for a minimum of [YEARS] years.
• Provide records to the Federal Trade Commission or state attorneys general within [DAYS] days of request.
• Conduct quarterly audits to confirm compliance and identify process gaps.

9. Consumer Notice & Support

• Provide consumer education materials on identifying verified sellers.
• Maintain a dedicated support queue for INFORM-related complaints.
• Track resolution times and escalate issues exceeding [DAYS] days.

10. Law Enforcement Cooperation

• Establish a process to respond to law enforcement subpoenas or information requests within [DAYS] days.
• Verify authenticity of requests before disclosure.
• Document all disclosures in Appendix C.

11. Training & Oversight

• Train compliance, risk, and support teams annually on INFORM requirements.
• Assign a Marketplace Compliance Officer responsible for policy enforcement and reporting to leadership.
• Report metrics (verification completion rates, suspensions, consumer complaints) quarterly.

12. Policy Review

Review and update this Policy annually or when regulations change. Obtain executive approval for significant updates.

Appendices

• Appendix A: Verification Workflow Diagram
• Appendix B: Investigation Report Template
• Appendix C: Law Enforcement Request Log
• Appendix D: Seller Communication Templates (Email/SMS/In-App)

[// GUIDANCE: Integrate this Policy with anti-money laundering and sanctions screening requirements when applicable.]