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Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Last Updated: January 2025

Zero-Tolerance Statement

GROWUPP ABH SECUIRTY PRIVATE LIMITED maintains a strict and uncompromising zero-tolerance approach toward money laundering, terrorist financing, fraud, sanctions evasion, market abuse, identity manipulation, and any form of financial misconduct. The COINZII platform shall not, under any circumstances, be used as a vehicle for unlawful financial activity or regulatory circumvention.

Purpose & CommitmentCustomer Due DiligenceTransaction MonitoringProhibited ActivitiesSanctions ScreeningRecord Keeping

1. Purpose, Business Model Context & Regulatory Commitment

1.1 Policy Objective

This Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") Policy is adopted by GROWUPP ABH SECUIRTY PRIVATE LIMITED (operating under the brand name COINZII) to establish a comprehensive compliance and risk-management framework. The objective of this Policy is to:

  • Prevent the misuse of the platform for money laundering, terrorist financing, fraud, tax evasion, or financial crime;
  • Protect the integrity of the Indian financial ecosystem and associated banking channels;
  • Implement a risk-based compliance structure tailored to the Company's controlled, non-P2P operational model;
  • Ensure transparency, traceability, and accountability in all INR-denominated transactions facilitated through the platform.

The Company adopts a compliance-first approach and integrates AML safeguards into its technological infrastructure, operational procedures, and governance mechanisms.

1.2 Business Model Alignment

COINZII operates as a technology-enabled digital asset facilitation platform with the following structural characteristics:

  • Users onboard strictly through verified KYC procedures;
  • Funding is accepted only in Indian Rupees (INR) through regulated banking and payment gateway channels;
  • The platform does not permit peer-to-peer (P2P) trading between users;
  • Direct cryptocurrency deposits from external blockchain wallets are not supported;
  • Liquidity access and order execution may be facilitated through secured third-party exchange APIs;
  • All user activities remain subject to centralized monitoring and compliance controls.

1.3 Legal & Regulatory Framework

The Company is committed to complying with applicable Indian regulatory requirements, including but not limited to:

  • The Prevention of Money Laundering Act, 2002 (PMLA);
  • Applicable reporting obligations to Financial Intelligence Unit – India (FIU-IND), where required;
  • Income Tax Act provisions relating to Virtual Digital Assets;
  • Information Technology Act, 2000;
  • Any notifications, circulars, or regulatory directives issued by competent authorities.

1.4 Governance & Oversight

The AML framework is implemented through:

  • Structured Customer Due Diligence (CDD) processes;
  • Ongoing transaction monitoring and risk scoring mechanisms;
  • Internal compliance review procedures;
  • Escalation protocols for suspicious activity detection;
  • Secure record-keeping and audit trails.

Senior management maintains oversight responsibility for AML implementation and reserves authority to suspend, restrict, or terminate user access where risk exposure is identified.

1.5 Zero-Tolerance Commitment

GROWUPP ABH SECUIRTY PRIVATE LIMITED maintains a strict zero-tolerance stance toward any activity that attempts to:

  • Conceal the origin of unlawful funds;
  • Facilitate terrorist financing or sanctioned activity;
  • Bypass regulatory safeguards;
  • Exploit technological systems for financial crime.

Where suspicious activity is detected, the Company may:

  • Temporarily freeze transactions;
  • Restrict account access;
  • Conduct enhanced due diligence;
  • Report the matter to competent authorities in accordance with law.

2. Scope of Application

This Policy applies to all operations, services, systems, personnel, and users associated with GROWUPP ABH SECUIRTY PRIVATE LIMITED. This includes:

  • Individual retail users, corporate and institutional clients
  • Authorized signatories and beneficial owners
  • Directors, senior management, compliance officers, employees
  • Third-party service providers (payment gateways, KYC agencies, API liquidity providers)

The Policy applies to all users accessing the platform from within India and permitted jurisdictions. Access from sanctioned or restricted jurisdictions may be denied.

3. Risk-Based Approach (RBA) & Risk Assessment Framework

The Company adopts a structured Risk-Based Approach (RBA) to identify, assess, monitor, and mitigate risks. Enterprise-level risk assessment covers:

Customer Risk

Based on identity verification, occupation, PEP status, source of funds, and historical behavior. Users classified as Low, Medium, or High-Risk.

Geographic Risk

Assessment of country of residence, sanctions exposure, regulatory advisories, and IP/device location inconsistencies.

Transactional Risk

Monitoring for unusual velocity, structuring patterns, rapid deposit-withdrawal cycles, and layering attempts.

Product & Channel Risk

Assessment of INR onboarding channel misuse, API execution timing exploitation, and high-frequency trading anomalies.

4. Customer Due Diligence (CDD) & Know Your Customer (KYC) Framework

All users must complete mandatory KYC verification before accessing transactional features. Anonymous, fictitious, benami, or pseudonymous accounts are strictly prohibited.

Individual Customer Verification

  • Full legal name (as per government-issued ID)
  • Permanent Account Number (PAN)
  • Aadhaar or government-recognized identity proof
  • Mobile number linked to identity credentials
  • Valid email address
  • Bank account details in user's own name

Corporate & Entity Verification

  • Certificate of Incorporation
  • Corporate PAN
  • Memorandum & Articles of Association
  • Board Resolution authorizing account opening
  • Director and authorized signatory KYC documents
  • Ultimate Beneficial Owner (UBO) declaration
  • Source of Funds declaration

Prohibition of Third-Party Funding

Deposits must originate only from bank accounts held in the registered user's name. Third-party transfers are strictly prohibited. Mismatched bank details may trigger compliance review and transaction rejection.

5. Enhanced Due Diligence (EDD) Framework

EDD may be initiated under circumstances including:

  • High-value or high-frequency transaction activity
  • Rapid deposit and withdrawal patterns inconsistent with user profile
  • Structuring behavior to avoid monitoring thresholds
  • Identification of Politically Exposed Persons (PEPs)
  • Complex corporate ownership structures
  • Adverse media or sanctions watchlist alerts
  • Inconsistencies between declared income and transaction volume

Additional verification measures may include:

  • Detailed Source of Funds documentation
  • Income proof (salary slips, ITR filings, business financials)
  • Bank statements for specified periods
  • Video re-verification or compliance interview
  • Written declarations regarding transaction purpose

6. Sanctions Screening & Watchlist Controls

The Company maintains a zero-tolerance policy toward sanctioned persons, terrorist organizations, or prohibited entities. Screening is conducted against domestic regulatory watchlists, government-issued sanctions lists, terrorist financing and anti-proliferation lists, and adverse media databases.

When a potential sanctions match is identified:

  1. The account may be immediately restricted
  2. Internal compliance review shall be initiated
  3. Enhanced documentation may be requested
  4. Funds may be temporarily frozen pending verification
  5. Reporting to competent authorities may occur where required by law

7. Transaction Monitoring & Suspicious Activity Detection

The Company employs automated risk-scoring algorithms, rule-based monitoring triggers, behavioral analytics tools, and manual compliance oversight.

Red Flag Indicators

  • Rapid deposit and withdrawal cycles without reasonable economic purpose
  • Structuring transactions to avoid internal thresholds
  • Sudden spikes in transaction volume inconsistent with declared income
  • Repeated high-velocity trading patterns designed to obscure fund origin
  • Multiple account access from shared devices or IP addresses
  • Attempted third-party funding or mismatched bank accounts
  • Circular trading or self-matching behavior

8. Suspicious Activity Reporting (SAR/STR)

Where suspicious activity is identified, the Company may file Suspicious Transaction Reports (STR) with competent authorities including FIU-IND. Users shall not be informed of reporting due to anti-tipping-off obligations.

9. Record Keeping & Data Retention

The Company maintains comprehensive records of customer identification, transactions, compliance reviews, and monitoring activities. Records are securely stored in encrypted systems and retained for the legally prescribed period under PMLA requirements.

10. Employee Training & Internal AML Awareness

All personnel receive mandatory AML training at onboarding and periodic refreshers. Training covers identification of suspicious patterns, reporting procedures, anti-tipping-off rules, and consequences of non-compliance.

11. Third-Party API & Exchange Integration Controls

Before integrating with any exchange or API partner, due diligence is conducted on regulatory standing, AML framework, operational security, and data protection practices. All trades executed through third-party APIs are logged, monitored, and included within customer risk profiling systems.

12. Prohibited Activities

Users are strictly prohibited from:

  • Depositing funds from illegal activities
  • Using third-party bank accounts
  • Providing false or forged KYC documentation
  • Creating multiple accounts to bypass limits
  • Engaging in market manipulation or circular trading
  • Attempting to reverse engineer platform systems
  • Accessing platform from sanctioned jurisdictions

Violations may result in immediate account suspension, fund freezing, regulatory reporting, and legal action.

13. Policy Review & Updates

This Policy is formally reviewed at least annually, upon material regulatory developments, and after significant compliance incidents. Amendments require Compliance Officer review and Senior Management approval.

Contact Information

Company: GROWUPP ABH SECUIRTY PRIVATE LIMITED

CIN: U62010MH2025PTC445169

Address: 67 B, Gopal Mansion CHS Ltd, Gurunanak Road, Bandra West, Mumbai - 400050, Maharashtra, India

Brand Name: COINZII

Email: support@coinzii.com