Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policy
1. Introduction:
This Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policy outlines the comprehensive framework and practical measures adopted by ‘Unicas Digital Labs LLP’ or hereby referred to as ‘Unicas’ to prevent and detect activities related to money laundering and terrorist financing within the context of cryptocurrency operations in India.
2. Compliance with Applicable Laws and Regulations:
The Company is committed to strict adherence to all relevant laws, regulations, and guidelines pertaining to the Prevention of Money Laundering Act (PMLA) 2002, Prevention of Money Laundering (Maintenance of Records) Rules, 2005, and the pertinent guidelines provided by the Financial Intelligence Unit-India (FIU-IND).
3. Customer Due Diligence (CDD):
- Identification and Verification: Prior to engaging in any business relationship with customers, the Company shall conduct thorough due diligence to verify the identity of customers using reliable and independent documentation, data, or information sources.
- Risk Assessment: Enhanced due diligence measures will be applied to high-risk customers, transactions, and jurisdictions as per the risk-based approach. The Company shall establish risk profiles for customers based on factors such as transaction volume, geographic location, and source of funds.
- Ongoing Monitoring: The Company shall continuously monitor customer transactions, behaviour patterns, and account activity to identify any unusual or suspicious activities indicative of money laundering or terrorist financing. Any discrepancies shall be promptly investigated and appropriate actions taken.
4.Transaction Monitoring:
- Automated Systems: The Company shall implement robust transaction monitoring systems equipped with advanced analytics and machine learning algorithms to detect patterns and anomalies associated with suspicious activities.
- Risk Assessment: Enhanced due diligence measures will be applied to high-risk customers, transactions, and jurisdictions as per the risk-based approach. The Company shall establish risk profiles for customers based on factors such as transaction volume, geographic location, and source of funds.
- Manual Review: Additionally, trained personnel shall conduct manual reviews of flagged transactions to assess their legitimacy and determine the need for further investigation or reporting to the relevant authorities.
5. Reporting Obligations:
- Suspicious Transaction Reports (STRs): The Company shall promptly file Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit-India (FIU-IND) upon identifying any transactions suspected of being related to money laundering or terrorist financing.
- Cash Transaction Reports (CTRs): Cash transactions exceeding the prescribed threshold shall be reported to the appropriate authorities.
6. Training and Awareness:
- Employee Training: All employees shall undergo comprehensive training on AML and CFT policies, procedures, and relevant legal requirements. Training sessions shall cover topics such as recognizing suspicious activities, conducting customer due diligence, and fulfilling reporting obligations.
- Awareness Programs: Regular awareness programs and updates shall be conducted to keep employees informed about the latest developments in AML and CFT regulations and emerging risks in the cryptocurrency sector.
7. Record keeping:
The Company shall maintain detailed records of all customer due diligence measures, transaction monitoring activities, and reports filed with regulatory authorities. Records shall be securely stored and made available for inspection by competent authorities upon request.
8. Internal Controls and Compliance Oversight:
- Internal Controls: The Company shall establish robust internal controls and procedures to ensure compliance with AML and CFT regulations. This includes segregation of duties, regular audits, and independent reviews of compliance activities.
- Compliance Oversight: A dedicated compliance officer or team shall be responsible for overseeing the implementation of AML and CFT measures, monitoring their effectiveness, and reporting any deficiencies to senior management.
9. Review and Updates:
This policy shall be subject to periodic review and updates to ensure alignment with changes in regulatory requirements, technological advancements, and evolving risk landscapes in the cryptocurrency industry.
10.Non-Retaliation:
The Company strictly prohibits retaliation against employees who report suspected instances of money laundering or terrorist financing in good faith. Confidential reporting mechanisms shall be in place to encourage whistleblowing and ensure the protection of whistleblowers.
Please note: These terms may undergo periodic review and revision. Updated terms will be posted on the Unicas website. Users are advised to regularly visit the website and review the terms, including any updates.
The continued utilization of Unicas’ services implies the user's acceptance of the terms outlined herein and any subsequent modifications.
