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AML Policy for SunCrypto

SunCrypto aims to prevent, detect and not knowingly facilitate money-laundering, terrorism financing and/or any other criminal activities. SunCrypto does this to comply with relevant laws, have transparency in trading activities and to be a good corporate citizen. In pursuance to the foregoing, SunCrypto collects certain relevant User identification information and documents for opening of Client Asset Account and for monitoring transactions.

This Anti-Money Laundering Policy ("AML Policy") describes the SunCrypto's policies and procedures instituted to ensure that the SunCrypto Platform or SunCrypto Services are not being used by the Users to facilitate money laundering or terrorism financing or any other criminal activities, including but not limited to those under the Prevention of Money Laundering Act, 2002 and the Notifications and Rules thereunder (“PMLA”).

The terms "We", "Our", "Company" and "Us" refer to SunCrypto, and the terms "User", "You" and "Your" refer to a User of our SunCrypto Platforms.

This AML Policy is a part of and incorporated within and is to be read along with the Terms of Use.

This AML Policy applies uniformly to any User desirous of using the SunCrypto Platform or availing the SunCrypto Services or otherwise using or benefitting from the use the SunCrypto Platform and may be read as a part of the Terms of Use. It is imperative that you read this AML Policy before using the SunCrypto Platform or SunCrypto Services or submitting any personal information. By using the SunCrypto Platform or or SunCrypto Services, you are expressly consenting to be bound by the Terms of Use, Privacy Policy and consequently this AML Policy.

The purpose of this AML Policy is to: 1. have a system in place for preventing any money laundering financial transaction, terrorism financing and/or any other criminal activities through the SunCrypto Platform;
2. make SunCrypto staff and management aware of the meaning of anti-money laundering and counter-terrorism financing and their responsibilities towards the same pursuant PMLA and relevant guidelines; and
3. document requirements under the PMLA and relevant guidelines and also to identify, monitor, report any relevant transaction to appropriate authorities.

KYC is the guiding principle behind the Anti-Money Laundering (AML) measures. SunCrypto aims to have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent the SunCrypto Platform or availing the SunCrypto Services from being used, intentionally or unintentionally, for money laundering purposes. KYC of a User enables SunCrypto to know/ understand its Users and their financial dealings better which in turn will help SunCrypto to manage its risks prudently.

The main aspect of this AML policy is the User due diligence process which means:

1. Obtaining sufficient information about to the User in order to identify who is the actual beneficial owner of the crypto assets or on whose behalf transaction is conducted;
2. Verify the User identity using reliable independent source document, data or information;
3. Conduct on-going due diligence and scrutiny of the Client Asset Account/ User to ensure that the transactions conducted are consistent with the Users’ background/ financial status, its activities and risk profile.

SunCrypto collects the documents and information as per the Terms of Use.

SunCrypto ensures the availability of a Compliance Officer at all times. The Compliance Officer is responsible for managing the day-to-day operations of this AML Policy. This includes, but is not limited to:

1. ensuring compliance of the provisions of the PMLA and relevant guidelines;
2. act as a central reference point and play and active role in identification & assessment of potential suspicious transactions;
3. ensure that SunCrypto discharges its legal obligation to report suspicious transactions to concerned authorities; and
4. ensuring the maintenance of a continually high level of staff AML awareness even between training sessions.

SunCrypto is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance with respect to all relevant legal requirements.

We implement ongoing employee training programmes so that SunCrypto’s staff is completely aware of the provisions of the PMLA and guidelines and amendments thereof. These training programmes focus on frontline staff, back office staff, compliance staff, risk management staff and staff dealing with customers. It is very crucial that all those concerned fully understand the rationale behind these guidelines, obligations and requirements, implement them consistently and are sensitive to the risks of their systems being potentially misused by unscrupulous elements, if there is any lapse on their part.