A. Introduction

We, Indra Capital ZTE Ltd. (“Airavat”, “we”, “us” or “our”) actively endeavor to detect, manage and mitigate the risks associated with money laundering and the financing of terrorism. We have employed this anti money-laundering policy (“AML Policy”) to detect, prevent and mitigate any suspicious activities or transaction executed by the users (“user”, “customer”, “you” or “your”) on our Online Platforms. We will cooperate with Law enforcement Agencies and Courts and will obey their orders relating to reporting suspicious accounts or transactions and sharing the identity details, KYC documents, transaction details and other details of specified users if required under applicable law.

B. Customer Due Diligence

Airavat takes effective Customer Due Diligence (”CDD”) measures to manage money laundering and terrorist financing risk. We identify and attempt to verify true identity on the basis of documents, data, or information at the time of registering the account of the customers and also on an ongoing basis at periodic intervals.

  1. Collecting customer details
    We collect the following identification information from the customers at the time of opening their account:
    • Full name of the customer;
    • Customer’s date of birth / date of incorporation;
    • Full address of the customer;
    • Mobile number and e-mail.

    We request the customer to provide us appropriate documents to allow us to verify the information submitted by the customer. These documents include, but are not limited to:

      1. For an individual customer: A high resolution scanned copy or photo of relevant pages of their passport or any other National Identification document issued by their government as per applicable laws, indicating name(s), date and place of birth, full address, passport or Identification document number, issue and expiry dates, country of issue, and customer’s signature.;
      2. For a corporate customer: a high-resolution copy of documents showing the existence of the entity, such as Certificate of Incorporation, and, where applicable, Certificate of Good Standing, Articles of incorporation and a government-issued business license (if applicable). For verifying the details of the beneficial owners, users are also required to submit details of all majority shareholders (holding more than 25% of shares) including their name, address, contact details and any unique director number, if applicable.

    To verify proof of address of the customer, we require one of the following to be provided, in the same correct name of the customer:

    • A high-resolution copy of a utility bill (fixed-line phone, water, electricity, gas connection etc.) issued within the last 3 months;
    • A copy of a tax return or payment receipt from a local authority;
    • A copy of a bank passbook or statement (for a current account, deposit account or credit card account);
  2. Verification of customer details
    We will, ourselves and/or through any third party, verify the information submitted by the customers while signing up on our Online Platforms by scrutinizing and matching them with the documents submitted by the customers and/or through any other independent source of information. Users are required to verify their email address and mobile number through one time password (OTP). We reserve our right to suspend, block and close any customer account if the details submitted by them are found to be incomplete or incorrect.
    We examine various factors such as customers’ background, country of origin, public or high profile position, linked accounts, business activities or other risk indicators before accepting a potential user. “Sanctioned Persons” or users from “Sanctioned Countries” as defined under our Terms of Service (collectively referred to as “Restricted persons”) are not eligible to access our Online Platforms. We will not verify and onboard any Restricted persons to open an account on our Online Platforms and if the account of any Restricted person gets verified by mistake or for any other reasons, we will close their account at our sole discretion. We also reserve our right to refuse on-boarding of any customer based on our independent verification of user details and sole discretion. We will endeavor to communicate the reason for not on-boarding a particular customer to the extent practical.
    We also ask the clients to provide the information on the source of the funds and may ask for further documents to verify such details depending on our initial risk-assessment of the customer. We may initiate enhanced due diligence procedure for a user requiring the user to submit additional details and documentation.
    • If the customer is a Politically Exposed Person (PEP)
    • The beneficial ownership structure of the company appears unusual or excessively complex, or opaque
    • If the legal entity is an NGO, charitable institution, trust or multi national company having entities and operations in multiple jurisdictions
    • Persons or entities who are engaged in cash intensive business or are from countries having weak AML/CFT requirements or have anonymous transactions or business relationships

    Customer identification and information of existing clients should be updated and/or amended at least once every four (4) years. This includes change of residential or business name or address, new identification cards, new passport, additional business information, new business investment/venture, and similar details.

  3. Additional measures
    We closely and regularly monitor suspicious and high value or high volume transactions, actions or activities of our users through manual and technological interventions and mechanisms. Transactions which are repetitive, involve high value, high volume or suspected wallet addresses or users or seemingly lack any commercial logic may be subjected to additional scrutiny and the customer may be asked to re-submit supporting KYC documents and explain the nature, purpose and other details of the suspected transaction and even the source of the funds.Based on our risk assessment, we may impose the following additional measures on high risk customers:
    • Our staff or a third party service provider may call or email to the user seeking further details of the source of the funds of the customer. Such additional details may include information relating to the employment status or business/occupation of the customer and any supporting documents including employment agreements, bank statements or tax returns. The company may also check and attempt to verify the details of the information submitted by the customer through any third party sources or obtain any additional information in this regard from any other appropriate source.
    • We regularly monitor account activities to track and identify transactions involving unusual size, volume, type of transactions or geographic factors and flag such transactions for further scrutiny. Transactions lacking any financial or business sense, involving use of wallet or account in the name of any other person or transactions by customers who have not revealed current information relating to business activities, source of funds, identify details or are not cooperating with us in sharing information or have a questionable background or prior history of non-compliance with laws and regulations or appear to be acting on behalf of others or other similar type of transactions may be flagged for further scrutiny. Our Compliance officer will monitor, flag and further scrutinise such transactions and may decide to report such suspicious activities or transactions to the appropriate authorities.

C. Payments Policy

You understand and undertake that you can only deposit Digital Assets which you own as beneficial owner on our Online Platforms. You represent that the account or wallet address used to deposit Digital Assets on our Online Platforms belongs to you and in under your exclusive control and ownership. We reserve our right to suspend, block or close your account or block and forfeit any Digital assets or funds available in your Digital Wallet if we have a reasonable suspicion that you have deposited Digital Assets belonging to any other person into your Digital Wallet with our Online Platforms.

Withdrawal Process
Company will follow a strict procedure while processing any withdrawal requests from the customer to ensure that the funds are sent only to their originating source and beneficial owner. We will review all withdrawal requests from customers and verify that the funds are being withdrawn to the same account / wallet address as used for deposit and will also review history of previous transactions and activities to ensure that there is no suspicious activity in the user’s account. In case there is a difference in the details of account / wallet address used at the time of deposit and provided in the withdrawal request, the accounts team will ask for further details and clarifications to ensure that withdrawal is being sent to the originating source and beneficial owner. Withdrawals will be allowed and processed only once the customer produces satisfactory details / documents supporting the same. If a withdrawal request is flagged for suspicious activity, the request will be placed on hold, pending further investigation by the compliance team. Compliance team, in consultation with the management, will decide if the transaction should be reported to the Law enforcement authorities.

D. Record Keeping

We will maintain and retain a record of all the documents obtained for the purpose of customer identification (KYC policy requirements) and anti money laundering procedures and documentation and AML procedures. We will also retain records relating to all the transactions executed on our Online Platforms, including the details of any suspicious activities and transactions which will be flagged by the accounts or the compliance team. We will cooperate and will share all relevant details in case an inquiry is made by any court or law enforcement agency, within a reasonable time, relating to the identity, transactions, beneficial ownership or any other related details of any account or customer.

The record of all documents submitted by the customers relating to KYC or AML procedures or requirements and the transactions of the customer will be maintained for five (5) years from the date of the transaction or date of submission of the document. The record of customer identification and business correspondence shall also be stored for at least five (5) years from the closure of the account, in case the account of the customer is closed.

All the records will be maintained in electronic form in a manner as may be prescribed in the applicable laws and the period of retention as stipulated above may be extended with respect to customers, transactions or accounts which are under any ongoing investigation.

E. Compliance Officer

We shall appoint an AML Compliance Officer, who will be fully responsible for executing and complying with the AML Policy of the Company and will report to the Board of the Company, or to any person nominated by the Board in this regard, of any material breaches of the AML policy and procedures and of any applicable Regulations.

The responsibilities of the AML Compliance Officer will include:

  1. Ensuring the Company’s compliance with the AML Policy and procedures and any other requirements under any applicable Regulations;
  2. Regular monitoring and auditing of the transactions and flagging of suspicious transactions or activities of the customers;
  3. Establishing and performing audit procedures to ensure compliance with anti-money laundering and combating the financing of terrorism procedures and systems;
  4. Training employees to recognize suspicious transactions;
  5. Maintaining the records relating to AML policy and procedures;
  6. Reporting and flagging any suspicious activities or material breach of the AML policy to the Board of the Company.

F. AML Awareness

The Compliance officer will ensure that all the directors, managers and the employees of the Company are aware of this policy. Employees, managers, and directors who are engaged in AML related duties must be suitably vetted with respect to their background and any prior history of criminal activities and non-compliance with laws and regulations. Every employee who is involved in executing or complying with the AML policy and procedure will be appropriately trained in how to comply with this policy including identifying suspicious transactions, flagging and reporting of the transactions.