KYC/AML Policy

Compliance With The Law

Introduction

The BitPolo (“we,” “our,” “us,” “BitPolo”) AML/KYC Policy (herein referred to as the “Policy,” “Agreement”) outlines the entire AML and KYC Agreement between BitPolo and the users (herein referred to as “Users”) of our services, which is binding on the Users. Our services (herein referred to as the “Services” shall entail the services provided by us and affiliated third parties on BitPolo.com and the associated mobile applications.

We urge our users to read this AML/KYC policy in its entirety as this sets the boundaries of usage for our users and sets the scope of our activities to comply with standard financial practices employed to prevent money laundering and financing of terrorism. This Agreement may be revised from time to time at our sole discretion. The English version of this Agreement shall prevail over all other versions.

Verification and Compliance

BitPolo’s Customer Due Diligence (CCD) and Know Your Customer (KYC) Policies, under applicable laws, requires the User to produce true, relevant, and verifiable documents that establishes them as a natural person and identifies them as a citizen of or a person residing in any particular country they claim to be residing in. These documents may include without limitation the Passport, Driving License, National Identification Number, Social Security Number, Bank Account Details (including account number, branch, IFSC code) Utility Bills, etc. This information is collected, reviewed, and verified at our sole discretion.

In addition, we may maintain either a softcopy and a hardcopy of the KYC information submitted to us and employ authorized third party verification services to verify the identity of the Users. Such third parties shall be compliant in collecting, recording, maintaining, verifying, KYC information as prescribed under the Prevention of Money Laundering Act, 2002.

Users can only open one account and cannot act on behalf of another User. In case the User is acting on behalf of another User, Company, Organization, or a Beneficiary, BitPolo is vested with the right to take every action to identify the respective User, Company, Organization, or the Beneficiary. Users are NOT permitted to open accounts under false identities.

Diligent Monitoring & Record Maintenance

BitPolo may monitor User transactions to verify whether the transaction involves prohibited or illegal activities. We may utilize transaction monitoring services and tools to track suspicious transactions based on the risk-assessment conducted by our Compliance Board. To effectively carry out this process, we may check whether the User is a designated individual or a resident of a designated jurisdiction or is on any sanctions list such as the Global Sanctions List, RBI Sanctions List and the OFAC Sanctions List.

We may maintain a record of the transactions conducted on our Services. These records may entail the date, the parties, the type, the type of fiat currency or crypto (including its denomination) of the transaction. If we discern, at our sole discretion that a transaction is of a suspicious nature, then we may investigate the transaction. If our findings evidence that the transaction is of illegal nature or requires more information, we may, as we see fit, either report the transaction to the concerned legal authorities or request the User to provide additional information pertaining to the transaction such as its purpose. We may also ask for appropriate documents supporting the need for such a transaction.

BitPolo has the right to suspend or terminate the account without prior notice, if we suspect or detect abnormal and illegal transaction activity on a User account.

Compliance Board

BitPolo Compliance Board is a board of compliance officers and executives authorized by BitPolo to enforce our AML/KYC Policy. The compliance board has the authority to investigate, suspend, freeze or terminate a User account or a transaction. The Compliance board has various roles and responsibilities such as those illustrated below:

  • i) The compliance officers verifies the authenticity of a User account (whether the account legitimately belongs to a single verified User.)
  • ii) They draft the compliance policy and enforce it on all the User accounts.
  • iii) They determine the risk associated with each transaction and take suitable actions based on their assessment.
  • iv) They keep an account of the User accounts that are deemed high-risk owing to the nature of the transactions.
  • v) The compliance board reports to law enforcement authorities and handles the legal proceedings of an illegal transaction.

Record Disclosure

a) By BitPolo
BitPolo shall act in accordance with our AML/KYC Policy and Privacy Policy when prompted by the law. BitPolo may disclose User information upon request by the Government, Judiciary or a law enforcement agency. In addition, BitPolo may disclose User information to protect the rights, safety and security of BitPolo and other Users. We may also comply with the Government, Courts, the Jury, Tribunals, and the Police to aid in their investigation.

b) By the User
The User shall disclose any and all information pertaining to an illicit or legally actionable transaction that the User is implicitly or explicitly involved in, of which BitPolo is not aware.

The User shall disclose additional information as and when required by BitPolo. Furthermore, the User is deemed responsible to prove the legality of a suspected illegal transaction.

Managing Risks

To curb the risks of money laundering and terrorist financing, we periodically assess each transaction. We may require Users to re-verify their identities. We shall ensure the availability of account and transaction information at all times and may retain it after the closure of accounts for a specific period to produce to legal authorities as and when required. BitPolo shall categorize each transaction such as high-risk, medium-risk, and low-risk so that the transactions that require the most attention are easily identified. Any transaction involving a sum of more than 10 Lakh INR will be processed after User identities are verified.

Governing Law

This Agreement shall be governed, enforced, and interpreted by the laws of India. The parties seeking or subject to legal action explicitly agree that they submit themselves to the courts in Bangalore to resolve disputes that arise out of this Agreement.

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