KYC/AML/CFT POLICY

Version 3.0

Last revised date: September 20, 2025

Introduction

Pursuant to the recommendations made by the Financial Action Task Force (formed for combating money laundering), the Government of India had notified the Prevention of Money Laundering Act in 2002. The Central Government vide notification F.No. P-12011/12/2022-ES Cell-DOR dated March 07, 2023, has notified the following activities, when carried out for or on behalf of another natural or legal person in the course of business as an activity for the purposes of sub-clause (vi) of clause (sa) of sub-section (1) of section 2 of the Prevention of Money-laundering Act, 2002 (15 of 2003):

(i) exchange between virtual digital assets and fiat currencies;
(ii) exchange between one or more forms of virtual digital assets;
(iii) transfer of virtual digital assets;
(iv) safekeeping or administration of virtual digital assets or instruments enabling control over virtual digital assets; and
(v) participation in and provision of financial services related to an issuer’s offer and sale of a virtual digital asset.
Explanation:—For the purposes of these guidelines, ‘virtual digital asset’ shall have the same meaning assigned to it in clause (47A) of section 2 of the Income-tax Act 1961 (43 of 1961).

Further, FIU-IND, vide its communication dated July 4, 2023, issued guidelines regarding the registration of VASPs as Reporting Entities

In order to combat the menace of money-laundering, terror financing, proliferation financing and other related serious crimes, Rule 7(3) of the PMLR casts an obligation on every reporting entity to evolve an internal mechanism in respect of these guidelines to detect transactions as specified under Rule 3(1) and furnishing information about such transactions to FIU-IND.

The obligation of reporting entities to effectively serve to prevent and impede money laundering and terrorist financing and to observe such internal controls not only by them but also by their Designated Director, officers and employees is a legal requirement under Rule 7(4) of the PMLR.

In order to discharge the statutory responsibility to detect possible attempts of money laundering, financing of terrorism or proliferation financing, every VASP must have a robust AML/CFT/CPF program in place. The AML/CFT/CPF program must include Internal policies, procedures, and controls signed off by the Board and Senior Management.

Prevention of Money Laundering Act, 2002

The Prevention of Money Laundering Act, 2002 (PMLA 2002), forms the core of the legal framework put in place by India to combat money laundering. PMLA 2002 and the rules notified under it came into force with effect from July 1, 2005. The PMLA 2002 and Rules notified thereunder impose an obligation on intermediaries (including stockbrokers and sub-brokers) to verify the identity of clients, maintain records and furnish information to the Financial Intelligence Unit (FIU)—INDIA.

Object of PMLA 2002

The main object of India is to prevent money laundering, which involves disguising illegally obtained funds as legitimate money. To achieve this, the Act also aims to confiscate property derived from or involved in money laundering, penalize offenders, and strengthen India's financial ecosystem by requiring reporting and monitoring of financial transactions.

Financial Intelligence Unit (FIU)—INDIA

The Government of India set up Financial Intelligence Unit-India (FIU-IND) on November 18, 2004 as an independent body to report directly to the Economic Intelligence Council (EIC) headed by the Finance Minister. FIU-IND has been established as the central national agency responsible for receiving, processing, analyzing and disseminating information relating to suspect financial transactions. FIU-IND is also responsible for coordinating and stretching efforts of national and international intelligence and enforcement agencies in pursuing the global efforts against money laundering and related crimes. SunCrypto is FIU-registered No. VA00031314, required to share all the relevant data with authorities, making it harder for their users to evade taxes.

Responsibility of Angelic Infotech Private Limited (SunCrypto or Company)

Angelic Infotech Private Limited, hereinafter referred to as 'SunCrypto' or 'the Company,' is Virtual Digital Assets Service Provider and Reporting Entity in terms of the aforementioned notification dated March 7, 2023. Being a Reporting Entity under PMLA 2002, it is mandatory on the part of SunCrypto to comply with PMLA 2002, rules made there under, and FIU-IND directives issued from time to time.

Need for this KYC/AML Policy

As a Reporting Entity under the Prevention of Money Laundering Act, 2002 (PMLA), it is mandatory for SunCrypto to establish and maintain a robust Anti-Money Laundering (AML) policy. This policy is essential to ensure the identification of suspicious transactions, execution of freezing actions where required, and prohibition of transactions with designated individuals and entities. It also places obligations similar to those applicable to ordering and beneficiary Service Providers (SPs)—or other obliged entities facilitating Virtual Digital Asset (VDA) transfers—with the objective of preventing money laundering, terrorist financing, and related illicit activities.

This policy is in accordance with PMLA Guidelines on Virtual Digital Assets ("VDA"), March 10, 2023 ("The Guidelines") issued by FIU-India. In this context, the key regulations and laws applicable to the company are

1. Prevention of Money Laundering Act, 2002, and its amendments;
2. PML (Maintenance of Records) Rules, 2005, and its amendments; and
3. AML & CFT Guidelines for Reporting Entities Providing Services Related to Virtual Digital Assets issued by FIU-IND.

By virtue of the Policy, the Company intends to establish a robust and strong KYC/AML/CFT framework that will be adhered to while interacting with the relevant stakeholders

Objective of KYC/AML Policy

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

Scope of KYC/AML Policy

The Policy is applicable to all functions of the Company dealing with customers, third-party agents/vendors, and other relevant stakeholders.

Definitions of KYC/AML Policy

1. “Applicable Law” shall mean any applicable statute, law, regulation, ordinance, rule, judgement, order, decree, by-law, approval from the concerned authority, government resolution, order, directive, guideline, policy, requirement, or other governmental restrictionin applicable in India, and regulations thereunder, Prevention of Money Laundering Act 2002(“PMLA“), PML (Maintenance of Records) Rules 2005 (“PMLR“), AML & CFT Guidelines For Reporting Entities Providing Services Related To Virtual Digital Assets (“AML Guidelines“), as issued by the Financial Intelligence Unit – India (“FIU-IND“), and various applicable guidelines, rules and regulations of the Computer Emergency Response Team, India (“CERT-In“), replaced and updated from time to time;
2. “Designated Director” means a person designated by Company to ensure overall implementation of the obligations imposed under chapter IV of the PMLA and the PMLR;
3. “Principal Officer” means an officer designated by Company to ensure compliance with the obligations imposed under chapter IV of the PMLA and the PMLR;
4. “Crypto(s)” are Virtual Digital Assets (“VDA”) and refer to a cryptographically secured digital representation of value or contractual rights that uses distributed ledger technology and can be transferred, stored or traded electronically using the Platform, including but not limited to bitcoin and ether;
5. “Customer“/”User” shall mean any person/entity using/accessing the platform or interacting with it in any manner for buying, selling, depositing or withdrawing Crypto(s);
6. “Customer Due Diligence” (CDD) means identifying the Customer and verifying their identity by using a reliable, independent source of documents, data, or information, and checking if there are any sanctions or adverse media matches against them;
7. “Officially Valid Document” (OVD) means the Passport, the Driving License, proof of possession of an Aadhaar Number, or the Voter’s Identity Card issued by the Election Commission of India. For the purpose of this definition, ‘Aadhaar Number’ means an identification number as defined under the Aadhaar (Targeted Delivery of Financial and other Subsidies, Benefits and Services) Act, 2016
8. “Person” means an individual who is above eighteen (18) years of age and an Indian citizen.
9. “Organization” means any entity registered in India that carries out the function of a business and has a separate legal existence from the individuals associated with it.
10. “Politically Exposed Persons” (PEPs) are individuals who are or have been entrustedwith prominent public functions by a foreign country, including the Heads of state/government, senior politicians, senior government or judicial or military officers, senior executives of state-owned corporations, and important political party officials. A User could also qualify as a PEP if the User is a family member or a close relative/associates of a PEP.
11. "Third party" is an external entity that assists with verifying customer identities and conducting due diligence on behalf of a company. This could include PAN verification Service providers, payment processors, or specialized service providers. Although third parties help fulfill these compliance tasks, the company remains ultimately responsible for meeting all regulatory requirements.
12. “Virtual Digital Assets” (VDA) means any information or code or number or token (not being Indian or foreign currency), a non-fungible token, or any digital asset as defined under Section 2(47A) of the Income Tax Act, 1961.
13. “Permanent Account Number” (PAN) is issued by the Indian Income Tax Department to help uniquely identify taxpayers. e-PAN is an electronically issued PAN that is digitally signed.

Key Appointments

The PMLA and PML rules require the regulated entities to appoint two key personnel in order to ensure overall compliance specified in the applicable regulations. Our company is duly registered with the Financial Intelligence Unit - India (FIU-IND) with registration number VA00031314 dated 29/03/2023 and adheres to all regulatory requirements stipulated by the FIU-IND. The company has appointed the following key individuals:

Designated Director

The company has nominated a person as the designated director to ensure overall compliance with regard to PMLA and PML rules. The Designated Director has been nominated by the Board and will be responsible for various functions listed in this policy.

Principal Officer

The company has appointed a principal officer, other than the person appointed as designated director, who is a senior management officer. The Principal Officer is responsible for ensuring implementation of the transaction monitoring provisions of the policy and will report to the Financial Intelligence Unit – India (FIU-IND).

Key Elements

Customer Acceptance Policy

The Customer Acceptance Policy (CAP) outlines the criteria and procedures for accepting customers, focusing on managing risks associated with different customer profiles in accordance with FIU-IND guidelines. The CAP includes:

i. Prohibition of Anonymous Accounts: The Company shall not open or maintain accounts under anonymous, fictitious, or benami names.
ii. Documentation Requirements: At the time of account opening and during periodic updates, the Company shall collect all required documents and information from different categories of customers, as specified in the KYC checklist.

The list of documents required for individuals:
1. Permanent Account Number (PAN)

One Officially Valid Document (OVD):
1. Aadhaar Card
2. Driving License
3. Passport
4. Voter Identity Card

In case of discrepancy in Address Verification (if OVD doesn't contain current address), documents required:
1. Utility bills (not more than 2 months old)
2. Property/Municipal tax receipts
3. Bank statements
4. Government accommodation letters
The List of Documents Required for KYB of a Legal Entity/Corporate/Company:
*Note: SunCrypto does not onboard trusts, non-governmental organizations (NGOs), or unincorporated associations of individuals (e.g., bodies like BCCI). This exclusion is in place to maintain strict adherence to risk-based KYC/AML standards and regulatory compliance protocols.

A. Company (Private/Public Limited)

1. Certificate of Incorporation
2. PAN card of the company
3. Memorandum & Articles of Association (MOA & AOA)
4. Board Resolution authorizing opening of the account and Authorized Signatory
5. List of directors with Director Identification Number (DIN)
6. Identification documents (PAN + Aadhaar/Passport) of All the Directors, Authorized Signatories and Beneficial Owners
7. Shareholding pattern to identify Beneficial Owners
8. Name of principal place of business, registered office and nature of business
9. If Registered Office different than Current address proof of the company (utilitybill/lease agreement not older than 3 months)
10. Beneficial Ownership details for anyone holding ≥10% ownership/control
11. GST certificate

B. Partnership Firm / LLP

1. PAN card of the Partnership/LLP
2. Registered Partnership/LLP Deed
3. Certificate of Incorporation
4. Identification documents of all partners (PAN + Aadhaar/Passport)
5. Authorization letter signed by all partners authorizing one or more partners to act behalf of the firm
6. Registered office address of the firm and nature of business
7. If the registered office is different than the current address, proof of the company (utility bill/lease agreement not older than 3 months)
8. Declaration of Beneficial Ownership (if applicable)
9. All partner KYC details
10. Beneficial owner declaration
11. Financials or income proof
12. GST certificate

C. Proprietorship Firm

1. Proof of the Name and Address
2. Registration certificate (Shop & Establishment or MSME)
3. PAN in the name of the business/proprietor
4. GST registration
5. Income tax return in the name of proprietorship
6. Utility bill/lease agreement in business name
7. Identity & address proof of the proprietor (PAN + Aadhaar/Passport)

D. HUF (Hindu Undivided Family)

1. PAN Card of HUF
2. Declaration from Karta—A signed declaration by the Karta stating they are the head and authorized signatory of the HUF.
3. PAN of Karta – (individual managing the HUF).
4. Proof of National Identity of Karta—Any officially valid document (OVD) like Aadhaar*, Passport, Voter ID, or Driving License.
5. Proof of Address of Karta—Recent utility bill, Aadhaar, Passport, etc. (as per OVDs).
6. Bank Statement or Utility Bill—For address verification of the HUF (if different from Karta’s personal address, not older than 3 months).
7. HUF Deed/Affidavit—A notarized HUF declaration or HUF creation deed signed by all coparceners
8. List of Coparceners—Names and details of all coparceners (with relation to Karta); often included in the HUF deed.
9. Recent Photograph of Karta
10. Declaration of Ultimate Beneficial Ownership (UBO)
The company may ask for any additional document and/or information from a legal entity or individual considering KYC/CDD/EDD requirements. Furthermore, additional documents/information may be asked for when opening an account of VDAS.

iii. Refusal of High-Risk Relationships: The Company shall not establish or maintain any relationship where it is unable to perform appropriate customer due diligence (CDD). This includes scenarios where the company cannot verify the customer’s identity or obtain necessary documents due to non-cooperation or unreliability. In such cases, the company may also terminate an existing relationship.

iv. Collection of Additional Information: In certain cases, additional information, documents, or declarations—beyond those outlined in the KYC Policy—may be requested from the customer, with their explicit consent, to support a more accurate and risk-informed due diligence process.

v. Screening Against Sanction Lists: The Company has a system in place to ensure that customers’ identities do not match those on any sanction lists defined in Annexure 1. If a match is found, the relationship will not be initiated or will be terminated if already established. Such name screening checks are performed before establishment of the relationship with the customers

vi. Risk-Based Approach: The Company shall adopt a risk-based approach to customer acceptance, which includes enhanced due diligence (EDD) for customers presenting higher risks, such as politically exposed persons (PEPs) or those from high-risk jurisdictions. We have a risk-based approach mechanism to rate customers as high or low; the risk score is calculated on the basis of the weighted average method on the parameters as defined in the Internal Process document.

Customer Identification Procedure

The Customer Identification Procedure (CIP) establishes the process for verifying customer identities and ensuring compliance with FIU-IND guidelines, including:

i. Customer Due Diligence (CDD): The Company shall verify the identity of all customers through appropriate customer due diligence measures. This includes obtaining and verifying information such as identification documents, proof of address, and other relevant data, in line with internal KYC policies.

ii. Enhanced Due Diligence (EDD): For customers identified as posing a higher risk, the company shall apply enhanced due diligence measures. EDD may involve gathering additional information, conducting more frequent reviews, and performing closer monitoring of transactions.

iii. Third-Party Reliance: The Company may rely on third parties for customer identification, provided that:
- The third party is regulated, supervised, or monitored for compliance with customer due diligence and record-keeping requirements under the Prevention of Money Laundering Act, 2002 (PMLA).
- The third party is not based in a high-risk jurisdiction.

iv. Timely Provision of Information: Third parties must provide customer information to the company promptly upon request.

v. Suspicious Activity Reporting: If the Company suspects money laundering or terrorist financing and believes that continuing with the CDD process may alert the customer, it shall discontinue the CDD process and file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with FIU-IND. In case transactions, including onboarding of clients, are abandoned or aborted by clients on being asked to give some details or to provide documents, the company shall report all such attempted transactions in STRs, even if not completed by clients, irrespective of the amount of the transaction, provided there is reasonable ground for suspiciousness.

vi. Ultimate Responsibility: Despite reliance on third parties, the ultimate responsibility for customer identification, due diligence, and the execution of enhanced due diligence measures lies with the Company. All processes must be meticulously followed to mitigate the risks of money laundering or terrorist financing

Risk Management

The risk profiling of the customer will be conducted based on the information and documents collated from the customer. The company will implement a framework for risk-based classification based on their business information, social financial status, background, jurisdiction/location, etc. The company will categorize customers into high, medium, and low risk based on the following parameters:

For Individuals

1. Customer’s background
2. Place of residence
3. Nature of business/service/Occupation
4. Any other relevant information

For Entities

1. Type of Entity
2. Nature of Business
3. Source of Funds and Wealth
4. Ownership Structure
5. Any other relevant information

The risk assessment will consider all the relevant factors before determining the risk category of the customer. In addition to this, based on the identified risk category, the company will also ensure to adopt appropriate risk mitigation measures. The risk assessment framework will be documented and reviewed regularly, and it will be made available to authorities as and when required.

The Company will not onboard customers who are associated with the following activities:

1. Customers who are believed to be associated with money laundering or terrorist financing.
2. Customers who have associations with high-risk countries.
3. Customers associated with the illegal business.
4. Customers who are PEP or associated with PEP having associations in high-risk locations.
5. Customers with UBO whose identity matched with entity/Individual mentionedinsanctions list such as UNSC, OFAC, UAPA etc..

High-risk customers need careful evaluation due to the risky nature of their occupation, which could cause financial or reputation loss or any other compliance issue for the company. The company would be evaluating the high-risk customers or associations of the customer and will adopt EDD (enhanced due diligence) for such customers.

Monitoring of Transactions

The company shall have in place a comprehensive transaction monitoring process from a KYC/AML perspective. The company shall put in place strong transaction alerts, which will provide proactive signals on suspicious transactions and possible money laundering.

The company AML monitoring team shall endeavor to update the list based on the current understanding of the market scenario and trading patterns followed by customers. In addition to the alerts from internal sources, the transaction monitoring team shall also monitor the transactions that are red-flagged by the law enforcement agencies.

The company will use in-house or vendor-based AML/CFT tools for screening and transaction monitoring. Alerts are generated on these panels, and further monitoring is performed by the AML Compliance team with the L1-L2-L3 approach.

Periodic Re-KYC Update

In line with our commitment to strong Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) practices, periodic KYC reviews of existing customers shall be conducted at least once every year, given the high-risk nature of Virtual Digital Assets (VDAs).

These periodic Re-KYC reviews are essential for maintaining the integrity of our customer records and ensuring KYC/AML compliance.

Travel Rule

In accordance with guidelines, our company shall comply with the "Travel Rule" by ensuring that specific identifying information about the originator and beneficiary is transmitted with every transfer of virtual assets or funds. This includes details such as the name, account number, and address or identification number of the parties involved. This information will accompany the transaction throughout the payment chain to ensure traceability and transparency. All intermediaries involved in the transfer must maintain and share this

information as required, facilitating effective oversight and compliance with anti-moneylaundering and counter-terrorist financing regulations. Furthermore, Company is committedto comply with Travel Rule related guidelines issued by FIU-IND from time to time.

Audit and Compliance

In alignment with the direction, our company will ensure robust audit and compliance mechanisms are in place to regularly review and assess the effectiveness of our KYC/AML policies and procedures. This includes conducting periodic internal audits to verify adherence to regulatory requirements and identify any potential weaknesses in the AML/CFT framework. The audit findings will be reviewed by senior management and the designated director, and necessary corrective actions will be implemented to address any identified issues. These measures are designed to maintain regulatory compliance, enhance our AML/CFT practices, and ensure the integrity of our operations.

Reporting

In accordance with the requirements of PMLA and PML Rules, the following information will be reported to the FIU-IND:

1. Suspicious Transaction Report – All transactions that have been identified as suspicious in nature post-investigation will be reported to the FIU-IND no later than seven working days after being satisfied that the transaction is suspicious. In case of urgent STR, the company will follow the procedure/guidelines as prescribed or informed by FIU-IND from time to time.

Record Keeping

In accordance with Guidelines, the Company must retain records as defined in Sections 12(1)(a) and 12(1)(e) of PMLA Act for a period of five years after the business relationship between a client and the reporting entity has ended or the account has been closed, whichever is later, as mentioned in Section 12(3) of PMLA, in order to ensure that such documents are not destroyed. These records must be readily accessible for review by regulatory authorities and should be securely stored to prevent unauthorized access. Proper record-keeping ensures compliance with AML/CFT regulations and supports the effective investigation and prevention of money laundering and terrorist financing activities.

In case of a pending inquiry from a law enforcement agency or litigation, the record as mentioned above must be retained till the closure of the inquiry or litigation.

Employee Hiring/Training/Investor Education

1. Employee Hiring

The Human Resource Department of the company has an adequate screening procedure in place to ensure high standards in hiring new employees. It is ensured we are not hiring people who have a criminal or suspicious background or who does not have the requisite knowledge of how the security market functions.

2. Employee Training

The company shall provide anti-money laundering training to all its new employees at the time of joining the organization. The company on an ongoing basis shall conduct training for existing employees on the basis of their role. The training shall review applicable money laundering laws and recent trends in money laundering activities as well as the company’s policies and procedures to combat money laundering, including how to recognize suspicious transactions.

The Compliance team will monitor activities right from training to onboarding to understand that the company is complying with all regulations. The frequency of the training will be annual, and ad hoc training will be provided in case there is any change in regulation or advice from the authorities.

The training program shall cover the following:

a. Applicable money laundering laws/rules/guidelines,
b. Recent trends in money laundering activities as well as the Company’s policies procedures to combat money laundering,
c. Tipping-off related guidelines and,
d. Identification and reporting suspicious transactions,
e. Records retention requirement.

Investor Education

The company will make an effort to educate and sensitize clients regarding the requirements of gathering rationale/information w.r.t. KYC and/or transactions undertaken by the client and documents evidencing the source of funds/income tax returns/bank records, etc. for the implementation of AML/CFT measures.

Prohibition of Tipping-off

The company and its directors, officers, and employees (permanent and temporary) shall be prohibited from disclosing (“tipping off”) that an STR or related information is reported or provided to the FIU-IND. This prohibition on tipping off extends not only to the filing of the STR and/or related information but even before, during, and after the submission of an STR. Thus, there is no tipping off to the client at any level.

Complying with provisions of Section 51A of UAPA

The company shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA) and amendments thereto, they do not have any accounts in the names of individuals/entities appearing in the lists of individuals and entities suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC).

In order to ensure expeditious and effective implementation of the provisions of Section 51A of UAPA, the Government of India has outlined a procedure through an order dated February 02, 2021 (Annexure 1) for strict compliance. These guidelines have been further amended via Gazette Notification dated June 08, 2021 (Annexure 2). Corrigendums dated March 15, 2023, and April 22, 2024, have also been issued in this regard (Annexure 3 and Annexure 4). The list of Nodal Officers for UAPA is available on the website of MHA. The company will ensure compliance with the aforementioned order/guidelines/requirement

Procedure for implementation of Section 12A of the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005

The Government of India, Ministry of Finance, has issued an order dated January 30, 2023, vide F. No. P-12011/14/2022-ES Cell-DOR (“the Order”), detailing the procedure for implementation of Section 12A of the Weapons of Mass Destruction and Their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 (“WMD Act”). The order may be accessed by clicking on DoR_Section_12A_WMD.pdf

The company shall comply with the aforementioned order/guidelines/requirements, including

a. Maintaining the list of individuals/entities (“Designated List”) and updating it, without delay, in terms of paragraph 2.1 of the order.
b. Verify if the particulars of the entities/individual party to the financial transactions match with the particulars of the Designated List, and in case of a match, shall not (page 28 of 37) carry out such transaction and shall immediately inform the transaction details withfull particulars of the funds, financial assets, or economic resources involved to the Central Nodal Officer (“CNO”), i.e., FIU-IND, without delay.
c. Run a check, on the given parameters, at the time of establishing a relationship with client and on a periodic basis to verify whether individuals and entities in the Designated List are holding any funds, financial assets or economic resources or related services in the form of bank accounts, stocks, insurance policies, etc.
d. In case the clients’ particulars match with the particulars of the Designated List, the company shall immediately inform the CNO of the full particulars of the funds, financial assets, economic resources or related services held in the form of bank accounts, stocks or insurance policies, etc., held on their books to the CNO, without delay.
e. Prevent such individual/entity from conducting financial transactions, under intimation to the CNO, without delay, in case there are reasons to believe beyond doubt that funds or assets held by a client would fall (page 29 of 37) under the purview of Section 12A(2)(a) or Section 12A(2)(b) of the WMD Act
f. File a Suspicious Transaction Report (STR) with the FIU-IND covering all transactions in the accounts covered under paragraphs 59(ii) and (iii) above, carried through or attempted through.
g. The company shall also comply with the provisions regarding exemptions from the above orders of the CNO and inadvertent freezing of accounts, as may be applicable.

Other Clauses

a. The company shall ensure compliance with procedures for determination of Beneficial Ownership of VDA Wallet specified by FIU-IND or under PMLA 2002 or PML (Maintenance of Records) Rules 2005 from time to time.
b. All employees shall ensure compliance with this policy. It shall be the duty of every employee/business associate of the company to cooperate with and provide timelydisclosure and information to any inspecting authority (either internal or external), including any relevant law enforcement authorities, with regard to the implementation of this policy. The policy shall be reviewed on an annual basis.
c. The Compliance Department shall be responsible for monitoring compliance with this policy. In the event of any non-compliance, the same shall be reported to the designated director of the company.

Review of Policy

This policy shall be reviewed once in a financial year or, in case of any regulatory change, on an ad hoc basis whenever it is identified that provision(s) of the policy is not in line with the prevailing applicable act/rule/regulation/guideline

Annexure 1: Sanctions Screening List

As per FIU India Guidelines and Prevention of Money Laundering Act (PMLA)

1. United Nations Security Council (UNSC) Sanctions List

a. Description: Consolidated list of individuals and entities subject to asset freezes, travel bans, and arms embargoes.
b. Source: UNSC Consolidated List
c. Frequency of Update: Real-time

2. Office of Foreign Assets Control (OFAC)—Specially Designated Nationals (SDN) List

a. Description: List of individuals and entities whose assets are blocked and U.S. persons are generally prohibited from dealing with.
b. Source: OFAC SDN List
c. Frequency of Update: Real-time

3. Financial Intelligence Unit – India (FIU-IND) Watchlists

a. Description: Watchlists of individuals and entities linked to money laundering or terrorist financing as per FIU-India guidelines.
b. Source: Financial Intelligence Unit – India (FIU-IND)
c. Frequency of Update: As per FIU guidelines

4. Ministry of Home Affairs – India (MHA) - UAPA Terrorist List

a. Description: List of individuals and entities designated as terrorists under the Unlawful Activities (Prevention) Act (UAPA).
b. Source: Ministry of Home Affairs Terrorist List
c. Frequency of Update: As notified by MHA