ANTI-MONEY LAUNDERING & KNOW-YOUR-CUSTOMER POLICY

This Anti-Money Laundering & Know-Your-Customer Policy ( "AML & KYC Policy") describes the policies and procedures relating to prevention of money laundering, financing of terrorism, and related illegal activities by individuals and corporate entities. The Company has prepared AML & KYC Policy to ensure the highest possible voluntary compliance under national and international AML standards.

This AML & KYC Policy applies uniformly to any User desirous of availing the Services or otherwise using or benefitting from the use the Website. It is imperative that you read this AML & KYC Policy before using the Website. By using the Website, you are expressly consenting to be bound by the Terms of Use and consequently this AML & KYC Policy. You must stop using our Services and/or the Website if your use results in committing/attempting to commit any criminal offences.

For the purposes of relevant national and international laws and standards applicable from time to time, the Chief Officer in charge of AML can be reached at: [email protected]

This AML & KYC Policy has been duly approved by our independent auditor and advisors, which are empowered to oversee compliance with applicable AML Laws and Standards. We may regularly furnish regulators or law enforcement agencies the details of any transactions taking place on the Website and such other information as deemed necessary by us. We will undertake a risk assessment based on (a) sufficiency and adequacy of identification documents submitted by you; (b) your social and/or financial status; (c) nature and other similar information about your business/vocational activities; or (d) guidance notes circulated by various governmental and inter- governmental organizations. We may internally categorize you as a low-risk, medium-risk, or a high-risk User on the basis of the aforementioned assessment. We will always keep your risk categorization and related data confidential, subject to any requests received from a competent law enforcement authority. In order to maintain the integrity of the risk assessment process, the results of your risk assessment and/or categorization will not be disclosed to you either

1. Customer Due Diligence/KYC

You may either at the time of registering as a User; upon execution of any transactions; while requesting access to additional Services (such as increased buy and sell limits, requests to transfer any funds to your linked bank account or third-party digital asset wallets, etc.); or periodically for purposes of updating records and on-going due-diligence (as specified under the AML Laws and Standards, or upon being directed by appropriate enforcement authorities), be required to take part in the User identification and verification process. For this purpose, we will follow the procedure prescribed under this Article.

2. Required Customer Information

2.1. We may collect the following information for the purposes of verification of identification:

(a) From Individual. Name; date of birth; email address; phone number and residential address; photograph; copies or certified copy of any Valid Documents; documents pertaining to business/financial status of such User (if prescribed by the Company);

(b) From Business/Enterprise. Business name; name, contact-details, photograph, and copy of Valid Documents of the authorized representative, one certified copy each of the certificate of incorporation/registration Certificate (as the case may be); memorandum and articles of association/partnership deed (as the case may be); board resolution/other authorization documents giving authority to the representative chosen to execute transactions on the Website;

2.2. You must promptly update us of any changes to the customer information provided to us within three days of effecting such changes. You must file a fresh proof of address within three (3) months of effecting any changes to the address mentioned as per the 'proof of address' submitted by you

3. Additional Assistance for extended verification

3.1. We may require you to furnish such other details as may be deemed necessary to verify your identity if we either (i) cannot verify your identity, or (ii) have a reason to believe that you are a person or entity whose details are provided in any official, governmental or intergovernmental sanction list. For the purpose of this AML & KYC Policy and our Terms of Use, "Sanction Lists" are lists maintained by us for the purposes of anti-money laundering compliance and include those circulated by the Financial Action Task Force ( "FATF"), and the United Nations Security Council, including without limitation, the ISIL and Al-Qaida Sanctions List and the 1988 Sanctions List.

3.2. We reserve the right to refuse registration to, or to bar transactions from or to, or terminate any relationship with, any customer for any reason (or for no reason) at any time.

3.3. If we believe any information obtained from the User hereunder is (a) inadequate or incomplete; (b) false or misleading; (c) insufficient resulting in an inability to readily verify the same; or (d) appearing on any Sanctions Lists, we may in our sole discretion either refuse or terminate (as the case may be) the registration of such Account or require such User to verify the valid documents submitted by it again. We may also, in our sole discretion, refuse to open any new accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Website if we are unable to verify any information due to non-cooperation by the User, or if such transactions are likely to have an material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.

3.4. We may also require you to certify that your linked bank account is held only with a scheduled commercial bank which is compliant with all know your customer (KYC) procedures mandated under the applicable laws. For this purpose, we may require you to furnish this certification in such format as may be prescribed by us.

4. Identity Verification Procedure

We may, at our sole discretion, at the time of initiation of your User registration process, request one or more appropriate third-party service provider to assist us in authentication and verification of the valid documents and other incidental details provided by you. In addition to the above, we reserve the right to verify customer identity through non-documentary means or both. We may also use non-documentary means if we are still uncertain about whether we know the true identity of a User. We will use the following non-documentary methods of verifying identity: (a) confirming validity of email; (b) confirming validity of telephone number or bank account number; and (c) confirming your location using, among others, your IP address; all of which may be carried out by an automated or manual process.

5. Monitoring and mitigating Suspicious Activity

We may monitor and flag for review all transactions where the amounts involved exceed limits specified by local or applicable laws, official guidelines, or industry best practices. In addition to the above, we may regularly monitor, through both manual screening and use of software-based algorithms, all transactions executed and/or attempted to be executed on our Website, in order to promptly identify and highlight any suspicious activity, which includes without limitation, activities that:

(a) appear, to a person acting in good faith, akin to collection of funds to be used, either in full or in part, by any terrorist or related organization, or in order to carry out any of the activities relating to terrorism, or terrorist acts;

(b) appear, to a person acting in good faith, to have been structured in a manner of unusual or unjustified complexity in order to avoid triggering any reporting requirements;

(c) appear, to a person acting in good faith, to have been transacted for a malafide purpose or where a sound economic rationale cannot be

(d) appear, to a person acting in good faith, to signal possible 'money-laundering' activities, as defined under applicable laws.

(e) appear to be unusual due to the reason of being inconsistent with any User's risk profile, expected usage pattern or sophistication. The extent of monitoring shall depend on various factors including upon each User's risk

On detection of any suspicious activity, we reserve the right to take appropriate actions without any prior notification to the User, which includes, without limitation, (i) terminating the Account, (ii) restricting and/or blocking further access to our Website, and (iii) notifying the appropriate enforcement authorities regarding the suspicious activities of any User.

6. Maintenance of Records

You are required to:

(a) Records of all transactions executed by you on our Website, for a period of at least 8 (eight) years from the date of each such Transaction;

(b) Records of all suspicious transactions, trans-national transactions, and transactions wherein the amounts involved exceed USD 10000 whether executed or attempted, for a period of at least 10 (Ten) years, including but not limited to the information about the nature and value of the transactions, parties involved in such transactions, and information about the date of remittance, in addition to reporting the same

(c) Identification records of Users (including but not limited to the valid documents submitted pursuant to above Article 1), during the subsistence of and for a period of at least 5 (Five) years from the date of termination of such User's Account.

7. Disclosure and Notices

In order to improve the integrity and transparency of transactions on the Online Platforms, you are encouraged to report, to our Chief Compliance Officer, any information which you are privy to or become privy to, regarding any suspicious transactions, or transactions you find or have reason to believe are dubious in nature. In order to ensure compliance with this AML & KYC Policy and/or the applicable laws, the Company may be required to send you notices from time to time. All such notices will be sent to such address as provided by you. Where you are required to share any information according to the procedures contained in this AML & KYC Policy, such communication may be made by you electronically by sending an email to our Chief Compliance Officer.

8. Amendments

We have the right, at any time, to change or modify the terms and conditions applicable to your use of our Services, or any part thereof, or to impose new conditions, including, but not limited to, adding fees and charges for use. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof. This notice may be given by means including, but not limited to, updating the "Last Updated" field at the top of this document with the date of the current revision.

Any use of our Services by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. Any amended Terms will apply prospectively to use of the Services after such changes become effective. It is important therefore that you review these Terms on a regular basis to ensure that you are familiar with the terms in force from time to time and/or any changes made to them. If you do not agree to any amended Terms, you must discontinue using our Services and contact us to terminate your account.