In terms of the Notification F. No. P-12011/12/2022-ES Cell-DOR dated 07 March 2023, the Central Government has notified that businesses dealing with Virtual Digital assets to undertake mandatory compliance of the provisions of Prevention of Money-Laundering Act, 2002 and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, as amended from time to time by the Government of India as notified by the Government of India.
At "GRADE CAPITAL" i.e., "ATLANTEASE VENTURES INC", we are committed to maintaining the highest standards of integrity, transparency, and security in all our financial transactions and interactions with customers. To uphold these principles and fulfill our regulatory obligations, we have established comprehensive policies and procedures related to AML, CFT, CPF, and KYC based on guidelines issued by the Government of India.
"GRADE CAPITAL" i.e., ATLANTEASE VENTURES INC is an entity incorporated under the Delaware General Corporation Law, having its registered address at 8 The Green A, Dover, DE 19901, United States.
In this document, we outline the key components of our AML, CFT, CPF, and KYC policies, explaining their significance and the procedures we follow to implement them effectively.
The provisions of this policy shall apply to all branches and offices of the Company, except where specifically mentioned otherwise.
In this policy, unless the context otherwise requires, the terms herein shall bear the meanings assigned to them below:
This AML, CFT, CPF AND KYC Policy is duly approved by the Board of Directors of the Company. The policy will be reviewed by the Board and/or any committee of the Board to which power has been delegated, at yearly intervals or as and when considered necessary by the Board.
This KYC AML CFT policy shall include following four key elements:
The Company shall ensure compliance with AML, CFT, CPF AND KYC Policy through:
The Company has appointed and ensures the availability of a Chief Compliance Officer and a Designated Director responsible for the orientation, implementation and reporting under this Policy.
The Company may on its own accord may conduct independent third-party testing for the purposes of evaluation of this Policy. The Policy and measures taken hereunder are meant to be dynamic and shall evolve in accordance with the commensurate risk.
The Company will conduct periodic reviews of all its users. All high-risk users will be subject to revalidation of KYC every year and all low and medium risk users will be subject to revalidation KYC every 3 years.
This policy will be subject to periodic review in the light of various factors including regulatory changes, changes in business, market intelligence, and industry standard.
We are under a regulatory obligation to collect, verify and maintain this information about our customers. We also strive to maintain up to date details on our customers in order to serve you better. If we are not able to successfully update our records after a certain time, we will have to unfortunately suspend your account(s) until you have shared the required details.
For undertaking Customer Due Diligence (CDD) procedure in case of Individuals, the Company may obtain the following from an individual while establishing an account-based relationship or while dealing with the individual who is a beneficial owner, authorised signatory or the power of attorney holder related to any legal entity. The following are the principles followed by the Company:
The Company shall categorise accounts into 3 categories i.e. i) Low, ii) Medium and iii) High based on RBA. Whereas, high risk accounts are subjected to more intensified monitoring. The workflow for the purposes of EDD is as under:
Since the customers are investing in the product of the company are on-boarded through an “on-ramp” partner or exchange it is pertinent to note that the KYC and Due Diligence is conducted by both i.e. the Company and its “on-ramp” partner or exchange in order to ensure due compliance of the rules and regulations as maybe notified from time to time.
Individuals and legal entities will be screened against economic sanctions programs administered or enforced by any country or government or international authority, including the United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC), the Hong Kong Monetary Authority or the Monetary Authority of Singapore and sanctions lists in all jurisdictions we operate;
The company is authorized to take actions, including but not limited to suspending suspicious transactions, declining transaction requests, reversing transactions, freezing suspicious accounts, and informing relevant authorities if the Company identifies any of the specified behaviours from its user:
The Company screen all employees and conduct additional background checks on entrusted employees. We provide training for all relevant employees both while joining and on an ongoing basis.
The Company will maintain records for a period of five years after the business relationship between a client has ended or the account has been closed, whichever is later, in order to ensure that such documents are not destroyed.
The Company is committed to setting up utmost standards for transparency and accountability in all its affairs. We in attaining its mission through compliance of high legal and ethical standards. The Company does not tolerate any form of bribery, embezzlement or corruption, and will uphold all laws countering bribery, fraud and corruption in all forms. To that extent the on-ramp and off-ramp or exchanges has also developed its own Anti-Bribery and Anti-Corruption policy
The Company and their directors, officers, and employees are prohibited from disclosing (“tipping off”) that an Suspicious Transaction Report (STR) or related information is being reported or provided to the FIU-IND. This prohibition on tipping off extends not only to the filing of the STR and/ or related information but even before, during and after the submission of an STR. Thus, it shall be ensured that there is no tipping off to the client at any level.
The Company will collect information such as originator information, and beneficiary information, on transfers. The Company may also monitor transfers to detect those which lack the required originator and/or beneficiary information and screen the transactions to comply with relevant UNSCR resolutions.
The Company ensures that this Policy is communicated to all its employees, officers, and directors, and to its partners, agents, and representatives engaged in providing services to its clients. All such employees, officers, directors, partners, agents, and representatives shall be responsible for the implementation of this Policy.
The Company reserves the right to take appropriate enforcement actions, including but not limited to, termination of employment, reporting to regulatory authorities, and legal action, against any employee, officer, director, partner, agent, or representative found to have violated this Policy.
This Policy represents the Company's commitment to conducting its business with integrity, transparency, and in compliance with all applicable laws, regulations, and industry standards. The Company will continue to review and update this Policy as necessary to ensure its effectiveness and compliance with evolving legal and regulatory requirements.