KYC and AML Policy

This know your customer and anti-money laundering policy is a part of the Terms of Use. All terms of the Terms of Use are included in this policy by reference.

 

1. CUSTOMER VERIFICATION

 

1.1 The User will provide the following information/documents for verification of the User Account. Information/documents for verification may include:

 

(a) Name as in the permanent account number ("PAN") card or bank account;

(b) Self-attested copy of PAN card;

(c) Self-attested copy of Aadhaar card/valid driver’s license/passport;

(d) Duly certified copy of incorporation documents and constitutional documents;

(e) Duly certified resolutions authorizing the entity to transact on the Platforms and identification documents containing identification and address details of the individual authorised to transact;

(f) Valid phone number;

(g) Valid email address;

(h) Details of bank account linked to the Fiat Wallet including the account number; and

(i) Any additional information/documents as may be required by the Company for User verification or re-verification from time to time or as may be required by law enforcement, governmental or judicial authorities.

 

1.2 The Company may, at its sole discretion activate the User Account upon verification of the information provided by the User. For the purposes of verification of any User’s identity, the Company may rely on appropriate and licensed third party service providers to authenticate the documents and other incidental information provided by the User.

 

1.3 In case of any change in contact details, the User will update the details on the Platforms and submit documentary evidence for re-verification within 7 days of such change.

 

1.4 The User permits the Company to retain the above documents and information as long as the Company deems necessary. The Company will be entitled to retain the above details and documents even for of those Users whose registration has been rejected by the Company.

 

2. ANTI-MONEY LAUNDERING

 

2.1 The Company may regularly monitor and keep records of all transactions executed and/or attempted to be executed on the Platforms both manually and through use of software based algorithms in order to promptly identify and highlight certain kinds of transactions. The Company may, from time to time, undertake necessary investigation in order to identify and examine transactions inconsistent with any User’s risk profile, as may be determined by the Company, sophistication, and expected usage patterns. The Company may share, from time to time, this monitoring information regarding identified transactions, identification information of such Users, or any other information mandated under the applicable law with the appropriate law enforcement, governmental or judicial authorities.

 

2.2 In order to improve the integrity and transparency of transactions on the Platforms, the User is encouraged to report any information that the User is privy to regarding any Suspicious Transactions or transactions which the User believes are dubious in nature, to our compliance officers by writing to them at support@qoinup.com. "Suspicious Transactions" refers to the following activities, whether attempted or executed: (a) terrorist financing: transactions which to a person acting in good faith appear to be any funds collected to be used, 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) unusually complex: transactions which to a person acting in good faith appear to have been structured in a manner of unusual or unjustified complexity; (c) malafide purpose: transactions which to a person acting in good faith appear to have not been transacted for bonafide purpose or have a sound economic rationale; or (d) money laundering: transactions which to a person acting in good faith appear to involve proceeds of any offence listed in the schedule to the Prevention of Money Laundering Act, 2002.

 

2.3 Notwithstanding anything contained in this policy or the Terms of Use, amounts lying in any User Account suspected of being associated with any activity that contravenes any applicable law will not be released in favour of any User until an appropriate order is received from a governmental, regulatory, judicial or quasi-judicial body that is competent to pass such an order.

 

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