KYC, AML,CFT and CPF Policy [Summary]

Version 4.0

Last revised date: March 10, 2026

Our Commitment to KYC/AML/CFT Compliance

Angelic Infotech Private Limited (SunCrypto) is committed to preventing the misuse of its platform for money laundering, terrorist financing, proliferation financing, and other financial crimes.

As a Virtual Digital Asset Service Provider (VASP) and registered Reporting Entity with the Financial Intelligence Unit – India, the Company complies with the **Prevention of Money Laundering Act, 2002, applicable rules, and FIU-IND AML/CFT guidelines for Virtual Digital Asset service providers.

The Company maintains a robust Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT), and Counter-Proliferation Financing (CPF) framework.

Customer Identification and KYC

SunCrypto follows strict Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures before allowing users to access services on the platform.

Individual Customers are required to provide

• Full name and date of birth
• Permanent Account Number (PAN)
• Government-issued identity documents (such as Aadhaar, Passport, Voter ID, or Driving License)
• Address and contact details
• Bank account information
• Selfie verification and liveness detection

For accounts opened by legal entities (such as sole proprietorships, partnership firms, companies, trusts, or non-profit organizations), the Company conducts Client Due Diligence (CDD) similar to the process followed for individual customers. In addition, the Company collects the required information and documents as prescribed under Prevention of Money Laundering (Maintenance of Records) Rules, 2005. The Company also identifies and verifies the beneficial owner(s) of such entities and takes all reasonable steps to confirm their identity in accordance with regulatory requirements.

Additional technical identifiers such as IP address, device ID, geo-location, and wallet addresses may also be collected to ensure secure onboarding and regulatory compliance.

Customer Risk Assessment

The Company follows a risk-based approach to customer onboarding and monitoring.

Customers are assessed and categorized into risk levels (such as Medium or High Risk) based on factors including:

• Occupation and financial profile
• Geographic location
• Transaction behavior
• Politically Exposed Person (PEP) status
• Source of funds
• Nature and frequency of crypto transactions

Customers identified as higher risk are subject to Enhanced Due Diligence (EDD) and additional monitoring.

Sanctions and Watchlist Screening

All customers and transactions are screened against applicable national and international sanctions lists, including:

• United Nations Security Council (UNSC) sanctions lists
• Government of India lists under the Unlawful Activities (Prevention) Act (UAPA)
• FIU-IND watchlists
• Other applicable regulatory lists

Sanctions screening is conducted:

• At the time of onboarding
• During KYC updates
• When sanction lists are updated
• At the time of initiating VDA transactions

Accounts associated with sanctioned individuals or entities may be restricted, frozen, or reported to authorities.

Transaction Monitoring

SunCrypto uses automated monitoring systems and blockchain analytics tools to continuously monitor transactions conducted on the platform.

The system identifies unusual or suspicious activities such as:

• Large or complex transactions
• Rapid movement of funds
• Transactions involving high-risk jurisdictions
• Transactions involving mixers, tumblers, or anonymity-enhancing technologies

Alerts generated through monitoring systems are reviewed by the Compliance Team and Principal Officer.

Travel Rule Compliance

In accordance with regulatory requirements for Virtual Digital Asset transfers, the Company implements systems to comply with the “Travel Rule.”

For applicable transactions, the Company collects and transmits information relating to:

• Originator identity and wallet details
• Beneficiary name and wallet address
• Transaction details and relevant identifiers

This ensures transparency and traceability of digital asset transfers.

Reporting of Suspicious Transactions

Where a transaction is suspected to involve money laundering, terrorist financing, or illegal activities, SunCrypto will file a Suspicious Transaction Report (STR) with the Financial Intelligence Unit – India.

Such reports are filed promptly and confidentially in accordance with applicable laws and regulatory requirements.

Record Retention

SunCrypto maintains records relating to:

• Customer identification and KYC information
• Transaction records
• Compliance reviews and investigations

KYC and identity related records are preserved for at least 5 years from the date of closure of business relationship with client and transactions related records are preserved for at least 5 years as required under the Prevention of Money Laundering Act, 2002 and related rules.

Governance and Compliance Oversight

SunCrypto has appointed key officers responsible for AML/CFT compliance:

• Designated Director – Responsible for overall regulatory compliance and oversight.
• Principal Officer – Responsible for monitoring transactions and reporting suspicious activities to FIU-IND.

The Company also conducts periodic risk assessments, independent audits, and internal compliance reviews.

Employee Training and Awareness

SunCrypto conducts regular AML/CFT training programs for employees to ensure awareness of financial crime risks and regulatory obligations.

Employees involved in compliance, operations, and transaction monitoring receive specialized training to identify suspicious activities and implement AML controls effectively.

Prohibition of Anonymous or High-Risk Transactions

SunCrypto does not allow:

• Anonymous or fictitious accounts
• Transactions involving prohibited or sanctioned entities
• Activities related to illegal businesses
• Use of anonymity-enhancing crypto assets or services that conceal transaction origin

Cooperation with Authorities

SunCrypto cooperates fully with regulators, law enforcement agencies, and FIU-IND in the prevention and investigation of financial crimes.