Rize Exchange – Customer Identification Policy (CIP)

Company Name: Fingoole Technologies Pvt. Ltd.
Platform: Rize Exchange
Jurisdiction: India
Regulatory Framework: PMLA, 2002; FIU-IND Guidelines; RBI KYC Directions; IT Act, 2000

The Customer Identification Policy (CIP) of Rize Exchange establishes a robust framework for identifying, verifying, and authenticating customers before permitting access to the platform. This policy is designed to prevent identity fraud, impersonation, money laundering, terrorist financing, and other financial crimes.

1. Purpose

The purpose of this Policy is to ensure that Rize Exchange identifies and verifies the identity of every customer in a secure, reliable, and legally compliant manner prior to enabling platform access.

2. Scope

• All individuals and entities seeking registration on Rize Exchange
• All existing users of the platform
• All onboarding and re-verification processes
• All employees, officers, and agents involved in customer onboarding
• All third-party KYC and verification service providers

3. Regulatory Framework

• Prevention of Money Laundering Act, 2002 (PMLA)
• PMLA Rules and Amendments
• FIU-IND Guidelines
• RBI KYC Master Directions (as applicable)
• Information Technology Act, 2000
• Digital Personal Data Protection Act, 2023

4. Definitions

• Customer: Any individual or legal entity registered or seeking registration on the platform.
• CIP: Customer Identification Policy.
• CDD: Customer Due Diligence.
• EDD: Enhanced Due Diligence.
• UBO: Ultimate Beneficial Owner.
• PEP: Politically Exposed Person.
• Verification: Process of validating identity information using reliable sources.

5. Customer Identification Standards

Rize Exchange adopts a risk-based approach to customer identification and verification. No customer shall be permitted to trade, deposit, or withdraw funds unless identity verification has been successfully completed.

6. Identification Requirements – Individual Customers

• Full legal name
• Date of birth
• PAN (mandatory)
• Aadhaar (mandatory)
• Residential address
• Nationality
• Mobile number and email address
• Live selfie / liveness verification
• Bank account details (same-name account only)

7. Identification Requirements – Corporate / Institutional Customers

• Certificate of incorporation
• Memorandum and Articles of Association
• CIN, PAN, and GST registration
• Registered office address
• Board resolution authorizing account opening
• Authorized signatory details
• Director identification documents
• UBO identification and declaration
• Ownership and control structure
• PEP declaration for directors and UBOs

8. Verification Methods

• Government-issued identity documents
• Approved KYC APIs
• Bank account verification tools
• Liveness detection technology
• Address verification tools

9. Risk-Based Approach

Customers are classified as Low Risk, Medium Risk, or High Risk based on business profile, transaction behavior, geography, source of funds, PEP status, and behavioral patterns.

10. Enhanced Due Diligence (EDD)

• Additional document collection
• Source of funds verification
• Source of wealth verification
• Senior management approval
• Periodic re-verification

11. Ongoing Identification & Re-Verification

Rize Exchange conducts periodic re-verification when customer details change, suspicious activity is detected, risk classification changes, or regulatory requirements mandate re-verification.

12. Failure or Refusal to Provide Information

• Reject onboarding
• Suspend the account
• Restrict trading activity
• Report the matter to authorities

13. Record Maintenance

Rize Exchange maintains identity documents, verification results, risk classifications, and re-verification history for a minimum period of five (5) years.

14. Confidentiality & Data Protection

All customer identity data is treated as confidential, protected using industry-standard security controls, processed in compliance with the DPDP Act, 2023, and disclosed only when required by law.

15. Roles & Responsibilities

• Compliance Team: Conducts verification, risk review, EDD, and record maintenance.
• Principal Officer: Oversees CIP implementation, regulatory communication, and high-risk approvals.

16. Audit & Review

The CIP is subject to periodic internal and external audits and updated in line with regulatory changes.

17. Enforcement

Non-compliance with this Policy may result in account suspension, termination, regulatory reporting, or legal action.

18. Policy Review

This Policy shall be reviewed annually or earlier if required by changes in law or regulatory requirements.

Disclaimer: This policy is for compliance and governance purposes only and does not constitute legal advice.