🚨 AML Policy

1. Introduction

TradeDear Technologies is committed to preventing our platform from being used for money laundering, terrorist financing, or other illicit activities. This Anti-Money Laundering (AML) Policy establishes our framework for detecting and preventing financial crime.

Core Objectives:

• Prevent money laundering and terrorist financing
• Detect and report suspicious activities to FIU-IND
• Maintain robust KYC and customer due diligence
• Comply with Indian and international AML standards
• Protect the integrity of the cryptocurrency ecosystem

2. Legal and Regulatory Framework

This AML Policy complies with:

• Prevention of Money Laundering Act, 2002 (PMLA)
• Prevention of Money Laundering (Maintenance of Records) Rules, 2005
• Prevention of Money Laundering (Reporting Entity) Rules, 2023
• Unlawful Activities (Prevention) Act, 1967 (UAPA)
• Financial Action Task Force (FATF) Recommendations
• Information Technology Act, 2000
• Digital Personal Data Protection Act, 2023

2.1 Reporting Authority

TradeDear reports all suspicious transactions and cash transactions to:

3. Risk Assessment

We conduct comprehensive risk assessments for:

3.1 Customer Risk Factors

Risk Level	Characteristics	Due Diligence
Low Risk	Salaried employees, small traders, verified identity	Simplified Due Diligence
Medium Risk	Self-employed, moderate volumes, established history	Standard Due Diligence
High Risk	PEPs, cash-intensive businesses, high volumes, foreign nationals	Enhanced Due Diligence (EDD)

3.2 Geographic Risk

High-Risk Jurisdictions (FATF Watchlist):

• Countries with weak AML/CFT controls
• Sanctioned countries (North Korea, Iran, Syria)
• Jurisdictions associated with money laundering
• Tax havens with insufficient transparency

Action: Users from high-risk countries face Enhanced Due Diligence or service denial.

3.3 Product/Service Risk

Higher Risk Activities:

• Large cryptocurrency deposits from unknown sources
• Peer-to-peer (P2P) trading with anonymous counterparties
• Privacy coins (Monero, Zcash) - currently NOT supported
• Mixing/tumbling services - strictly PROHIBITED

4. Transaction Monitoring

Our automated AML system monitors:

4.1 Real-Time Monitoring

• Deposit Screening: All incoming crypto deposits analyzed for illicit origins
• Withdrawal Screening: Destinations checked against sanctioned addresses
• Trading Patterns: Unusual trading behavior (wash trading, layering)
• Velocity Checks: Rapid movement of funds (potential layering)

4.2 Automated Alerts

Transactions triggering alerts are flagged for manual review:

• Transactions exceeding ₹10 lakhs (CTR threshold)
• Multiple transactions just below reporting thresholds (structuring)
• Unusual patterns inconsistent with customer profile
• Transactions involving high-risk countries or sanctioned entities
• Rapid deposit and withdrawal (no trading activity)

4.3 Blockchain Analysis

We use blockchain analytics tools to:

• Trace cryptocurrency transaction history
• Identify connections to darknet markets, ransomware, scams
• Detect mixing/tumbling service usage
• Monitor for sanctioned wallet addresses

5. Suspicious & Cash Transaction Reporting

5.1 Suspicious Transaction Report (STR)

When we file STR with FIU-IND:

• Transactions with no apparent economic purpose
• Customer refuses to provide KYC documents
• Suspected structuring (smurfing) to avoid reporting
• Transactions linked to known criminal activity
• Use of multiple accounts for layering
• Crypto received from sanctioned addresses

Timeline: STR filed within 7 days of detecting suspicious activity

5.2 Cash Transaction Report (CTR)

Mandatory reporting for:

• All cash transactions (or equivalent crypto) above ₹10 lakhs
• Multiple linked transactions totaling above ₹10 lakhs in a month
• All suspicious transactions (regardless of amount)

Timeline: CTR filed within 15 days of end of month

5.3 Non-Profit Organization Transaction Report (NTR)

Any transactions involving registered NGOs/charities above ₹10 lakhs

6. Red Flags & Warning Signs

7. Sanctions Screening

All customers and transactions are screened against:

7.1 International Sanctions Lists

• OFAC SDN List: US Office of Foreign Assets Control Specially Designated Nationals
• UN Security Council: Consolidated sanctions list
• EU Sanctions List: European Union restrictive measures
• FATF High-Risk Jurisdictions: Countries with weak AML/CFT controls

7.2 Domestic Watchlists

• UAPA Schedule 4 (Banned Organizations)
• NIA Most Wanted List
• Enforcement Directorate watchlist
• State law enforcement databases (where accessible)

7.3 Cryptocurrency-Specific

• Chainalysis sanctions oracle
• Elliptic sanctioned wallet addresses
• TRM Labs high-risk addresses

8. Politically Exposed Persons (PEPs)

Definition: Individuals holding prominent public functions (current or former):

• Senior government officials
• Members of Parliament/Legislative Assemblies
• Supreme Court/High Court judges
• Senior military/police officers
• Heads of state-owned enterprises
• Leaders of major political parties
• Family members and close associates of above

PEP Due Diligence:

• Enhanced KYC verification
• Source of wealth declaration mandatory
• Senior management approval required
• Ongoing enhanced monitoring
• Annual KYC refresh (vs 3 years for low-risk)

9. Employee Training & Awareness

Our AML compliance program includes:

• Mandatory Training: All employees complete AML training within 30 days of joining
• Annual Refresher: Yearly AML compliance updates
• Role-Specific Training: Enhanced training for compliance, customer support, and operations teams
• Red Flag Recognition: Training on identifying suspicious activities
• Reporting Procedures: Internal escalation and STR filing processes

10. Record Keeping

As per PMLA requirements, we maintain:

• KYC Records: 5 years after account closure
• Transaction Records: 5 years from transaction date
• STR/CTR Reports: 5 years
• Internal Investigation Reports: 5 years
• Correspondence: 5 years

11. Consequences of Non-Compliance

For Users:

• Account suspension or permanent ban
• Funds freezing pending investigation
• STR filing with FIU-IND
• Report to law enforcement
• Legal action for money laundering (PMLA penalties: up to ₹10 lakh + 7 years imprisonment)

For TradeDear (if non-compliant):

• Penalties: ₹10,000 per day of non-compliance
• Criminal liability for directors/officers
• Business license revocation
• Reputational damage

12. Customer Cooperation

All users must:

• Provide accurate KYC information
• Respond to additional verification requests within 7 days
• Declare source of funds when requested
• Update KYC information when circumstances change
• Cooperate with investigations

Failure to cooperate may result in account suspension.

13. Contact Information

14. Policy Review

This AML Policy is reviewed and updated:

• Annually (or more frequently if needed)
• Upon changes in Indian or international AML regulations
• After significant money laundering incidents
• Following internal audits or regulatory examinations