ANTI-MONEY LAUNDERING (AML) / COUNTERING THE FINANCING OF TERRORISM (CFT) & KYC POLICY

Company Name: CRYPEXCH TECHNOLOGIES PRIVATE LIMITED

Brand Name: SIKKAA EXCHANGE

CIN: U63999PN2025PTC241988

Registered Address: S No 14/10, SAI PARK, SHOP NO 02, HAVELI, NANDED, PUNE 411041, MAHARASHTRA, INDIA

Compliance Contact: compliance@sikkaaexchange.com

Designated Compliance Officer: Mr. Pranav Barade

1. Introduction and Objective

The purpose of this Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Know Your Customer (KYC) policy is to establish a clear, structured, and legally compliant framework that ensures all business activities of CRYPEXCH TECHNOLOGIES PRIVATE LIMITED, operating as SIKKAA EXCHANGE, adhere to the highest standards of integrity, transparency, and regulatory compliance.

In line with the Prevention of Money Laundering Act, 2002 (PMLA), Prevention of Money Laundering (Maintenance of Records) Rules, 2005, FIU-IND guidelines, Reserve Bank of India (RBI) circulars, Securities and Exchange Board of India (SEBI) notifications, and the Ministry of Finance’s Virtual Digital Assets (VDA) Regulations, this policy provides detailed guidance on customer onboarding, transaction monitoring, suspicious activity detection, reporting obligations, record-keeping, and internal governance.

This policy ensures that the platform cannot be misused for illicit purposes such as money laundering, terrorist financing, fraud, or other illegal activities. The objective is also to create a risk-aware culture among employees and stakeholders, mitigate operational, reputational, and legal risk, and align SIKKAA EXCHANGE’s operations with international best practices as recommended by the Financial Action Task Force (FATF).

2. Regulatory Compliance Framework

SIKKAA EXCHANGE strictly operates under Indian laws and regulations that govern financial transactions, anti-money laundering, and virtual digital assets. These include:

Prevention of Money Laundering Act, 2002 (PMLA): Legal framework for identifying, preventing, and punishing money laundering activities.

Prevention of Money Laundering Rules, 2005: Specifies records to be maintained including KYC and transactions.

FIU-IND Guidelines: Includes STR, CTR, and NTR reporting.

RBI and SEBI Guidelines: Ensures alignment with broader financial regulations.

Ministry of Finance VDA Regulations: AML measures specific to digital assets.

International Compliance: Alignment with FATF recommendations.

3. Governance and Compliance Structure

Board of Directors: Oversight of AML/CFT policies.

Compliance Officer: Mr. Pranav Barade manages AML operations.

AML Committee: Reviews compliance and risk.

Employee Responsibility: Mandatory adherence to AML policy.

Internal Audit: Independent audits ensure compliance effectiveness.

4. Know Your Customer (KYC) Procedures

Individuals: Aadhaar, PAN, Passport verification.

Corporates: Company documents, UBO verification.

PEPs: Enhanced due diligence.

Watchlist Screening: UN, OFAC, FIU checks.

Ongoing Monitoring: Periodic updates and alerts.

5. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

Risk-based classification into Low, Medium, High.

EDD for high-risk customers including source of funds verification.

High-risk scenarios include unusual transactions and sanctioned regions.

6. Transaction Monitoring and Suspicious Activity Detection

Automated and manual monitoring of all transactions.

Monitoring includes:

Suspicious transactions are escalated and reported to FIU-IND.

7. FIU-IND Reporting Obligations

STR: Suspicious Transaction Reports

CTR: Cash Transaction Reports

NTR: Non-Profit Transaction Reports

Reports are submitted via FINnet 2.0 portal.

8. Record Keeping and Retention

KYC, transaction, audit, and training records maintained.

Retention period: Minimum 10 years.

Stored securely with audit trails.

9. Technology and API Integration

Use of blockchain analytics, APIs, AI monitoring.

Real-time alerts and risk scoring.

10. Risk-Based Approach (RBA)

Customer, product, and jurisdiction risk profiling.

High-risk accounts get enhanced scrutiny.

11. Employee Training and Awareness

Mandatory AML training and annual refreshers.

Includes case studies and simulations.

12. Cooperation with Regulators

Full cooperation with FIU-IND, RBI, SEBI, and law enforcement.

13. Independent Audit and Review

Annual audits of AML systems and compliance.

14. Non-Compliance and Disciplinary Measures

Violations lead to termination, legal action, and reporting.

15. Policy Review and Approval

Reviewed annually and updated as per regulations.

16. Annexures

KYC checklists, STR templates, monitoring rules, risk matrix, glossary.

Approval and Signature

Authorized Signatory: Tushar Sonar

Designation: Director & Co-Founder

Date: 1 Oct 2025

Place: Pune, Maharashtra, India