Rize Exchange – KYC & AML Policy

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

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy establishes a comprehensive framework for Rize Exchange to prevent, detect, and report money laundering, terrorist financing, fraud, and other financial crimes, in compliance with applicable Indian laws.

1. Purpose

The purpose of this Policy is to ensure regulatory compliance with the Prevention of Money Laundering Act, 2002 (PMLA), rules thereunder, and guidelines issued by the Financial Intelligence Unit – India (FIU-IND).

2. Scope

• All users of the Rize Exchange platform
• All employees, directors, officers, and contractors
• All INR-based derivative trading activities
• All onboarding, monitoring, and reporting functions
• All third-party service providers involved in compliance

3. Regulatory Framework

• Prevention of Money Laundering Act, 2002 (PMLA)
• PMLA Rules and Amendments
• FIU-IND Guidelines for Reporting Entities
• Information Technology Act, 2000
• Digital Personal Data Protection Act, 2023
• Applicable RBI, SEBI, and Government of India notifications

4. Definitions

• Customer: Any individual or entity registered on Rize Exchange.
• CDD: Customer Due Diligence.
• EDD: Enhanced Due Diligence.
• PEP: Politically Exposed Person.
• STR: Suspicious Transaction Report.
• UBO: Ultimate Beneficial Owner.
• Reporting Entity: Rize Exchange as defined under PMLA.

5. Governance Structure

Designated Director: Appointed by the Board to oversee overall AML compliance.

Principal Officer: Acts as the nodal point for FIU-IND communication and regulatory reporting.

Compliance Team: Responsible for KYC verification, monitoring, investigations, and internal escalations.

6. Customer Due Diligence (CDD)

Rize Exchange follows a risk-based approach to customer onboarding.

6.1 Individual Customers

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

6.2 Corporate / Institutional Customers

• Certificate of incorporation
• CIN, PAN, GST
• Memorandum & Articles of Association
• Board resolution authorizing account opening
• Authorized signatory details
• Director KYC
• UBO identification
• PEP declarations

7. Risk-Based Classification

• Low Risk
• Medium Risk
• High Risk

Risk classification is based on transaction volume, source of funds, trading behavior, geography, occupation, and PEP status. Profiles are reviewed periodically.

8. PEP & Sanctions Screening

• Indian PEP databases
• UN Sanctions Lists
• RBI caution lists
• SEBI debarred entities

9. Enhanced Due Diligence (EDD)

• Source of funds verification
• Source of wealth verification
• Additional identity documents
• Senior management approval

10. Ongoing Monitoring

• Wash trading
• Circular trading
• Layering and structuring
• Unusual trading volumes
• Third-party fund usage
• Abnormal margin behavior

11. Suspicious Transaction Reporting (STR)

• Internal investigation of suspicious activity
• STR filing with FIU-IND within prescribed timelines
• Retention of supporting documents
• Cooperation with law enforcement agencies

12. Record Retention

KYC records, transaction data, screening results, STRs, and investigation reports are retained for a minimum of five (5) years.

13. Employee Training

• Mandatory AML training
• Periodic refresher programs
• Specialized compliance training

14. Audit & Review

• Independent AML audits
• Internal compliance reviews
• Policy updates based on regulatory changes

15. Confidentiality

All AML-related processes, reports, and investigations are treated as confidential and disclosed only when required by law.

16. Enforcement

• Account suspension
• Account termination
• Disciplinary action
• Regulatory reporting

17. Policy Review

This Policy shall be reviewed annually or earlier if required by law.

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