Anti Laundering
A. Introduction
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.
B. Policy Statement
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.
C. Background
"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.
D. Purpose and Statement of Object
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.
E. Applicability
The provisions of this policy shall apply to all branches and offices of the Company, except where specifically mentioned otherwise.
F. Definitions
In this policy, unless the context otherwise requires, the terms herein shall bear the meanings assigned to them below:
G. Internal Approvals
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.
H. Scope
This KYC AML CFT policy shall include following four key elements:
Customer Acceptance Policy;
Risk Management;
Customer Identification Procedures (CIP); and
Monitoring of Transactions
I. Compliance
The Company shall ensure compliance with AML, CFT, CPF AND KYC Policy through:
Specifying as to who constitute ‘Senior Management’ for the purpose of KYC compliance.
Allocation of responsibility for effective implementation of policies and procedures.
Independent evaluation of the compliance functions of Company policies and procedures, including legal and regulatory requirements.
Concurrent/internal audit system to verify the compliance with KYC/AML policies and procedures.
Submission of quarterly audit notes and compliance to the Audit Committee.
J. Chief Compliance Officer and Designated Director
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.
K. Independent Testing
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.
L. Periodic Review
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.
M. Policy Review
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.
N. Client Due Diligence (CDD)
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.
O. Know Your Customer (KYC)
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:
Identification: The Company will obtain Officially Valid Documents (OVD) to identify the customer.
Verification: The Company will verify the identity or the beneficial owner using OVD. The personal information of users are governed by the Privacy Policy.
On-going Due Diligence: The Company shall perform on-going due diligence throughout the course of the business relationship to ensure the transactions are consistent with the risk profile of the customer.
P. Enhanced Due Diligence
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:
A system of periodic review of risk categorisation of accounts, with such periodicity being at least once in six months, and the need for applying enhanced due diligence measures shall be put in place basis RBA.
All accounts with unusually large volumes of complex transactions and unusual patterns inconsistent with a normal user without any economic rationale or legitimate purpose will be flagged.
The transactions in accounts of customers who are high-risk customers or politically exposed persons (PEPs) shall be closely monitored.
Q. Counterparty Due Diligence
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.
R. Sanctions screening for VDA transfers
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;
on the onboarding stage when the user is submitting the application;
on each anti-fraud and AML alerts manually by Compliance Officer;
monthly by running automatically with a script to re-check all DB of customers.
S. Suspicious Transaction Reporting
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:
Failure to provide a OVD or other documents which maybe necessary for the company or its partners to verify the identity of the user or the beneficiary.
Failure to update KYC information despite of reminders.
If, even after taking required steps, the company continues to question the genuineness, legitimacy, and/or completeness of the user's identity details
In cases where a transaction cannot be thoroughly investigated within a specified timeframe, the case is escalated to senior management for a final decision.
Where the user fails to submit legitimate KYC details to conceal or withhold their identity.
Where the user fails to provide legitimate reasons if transactions are flagged as high risk based on RBA.
Such additional scenarios as maybe deemed necessary based on continuous RBA and EDD.
T. Employee Due Diligence and Risk Awareness Training
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.
U. Record Retention
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.
V. Anti-Bribery And Anti-Corruption Policy and Prohibition of Tipping off
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.
W. Travel Rule
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.
Y. Communication of Policy
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.
Z. Enforcement
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.
AA. Conclusion
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.
A. Introduction
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.
B. Policy Statement
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.
C. Background
"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.
D. Purpose and Statement of Object
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.
E. Applicability
The provisions of this policy shall apply to all branches and offices of the Company, except where specifically mentioned otherwise.
F. Definitions
In this policy, unless the context otherwise requires, the terms herein shall bear the meanings assigned to them below:
G. Internal Approvals
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.
H. Scope
This KYC AML CFT policy shall include following four key elements:
Customer Acceptance Policy;
Risk Management;
Customer Identification Procedures (CIP); and
Monitoring of Transactions
I. Compliance
The Company shall ensure compliance with AML, CFT, CPF AND KYC Policy through:
Specifying as to who constitute ‘Senior Management’ for the purpose of KYC compliance.
Allocation of responsibility for effective implementation of policies and procedures.
Independent evaluation of the compliance functions of Company policies and procedures, including legal and regulatory requirements.
Concurrent/internal audit system to verify the compliance with KYC/AML policies and procedures.
Submission of quarterly audit notes and compliance to the Audit Committee.
J. Chief Compliance Officer and Designated Director
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.
K. Independent Testing
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.
L. Periodic Review
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.
M. Policy Review
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.
N. Client Due Diligence (CDD)
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.
O. Know Your Customer (KYC)
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:
Identification: The Company will obtain Officially Valid Documents (OVD) to identify the customer.
Verification: The Company will verify the identity or the beneficial owner using OVD. The personal information of users are governed by the Privacy Policy.
On-going Due Diligence: The Company shall perform on-going due diligence throughout the course of the business relationship to ensure the transactions are consistent with the risk profile of the customer.
P. Enhanced Due Diligence
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:
A system of periodic review of risk categorisation of accounts, with such periodicity being at least once in six months, and the need for applying enhanced due diligence measures shall be put in place basis RBA.
All accounts with unusually large volumes of complex transactions and unusual patterns inconsistent with a normal user without any economic rationale or legitimate purpose will be flagged.
The transactions in accounts of customers who are high-risk customers or politically exposed persons (PEPs) shall be closely monitored.
Q. Counterparty Due Diligence
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.
R. Sanctions screening for VDA transfers
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;
on the onboarding stage when the user is submitting the application;
on each anti-fraud and AML alerts manually by Compliance Officer;
monthly by running automatically with a script to re-check all DB of customers.
S. Suspicious Transaction Reporting
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:
Failure to provide a OVD or other documents which maybe necessary for the company or its partners to verify the identity of the user or the beneficiary.
Failure to update KYC information despite of reminders.
If, even after taking required steps, the company continues to question the genuineness, legitimacy, and/or completeness of the user's identity details
In cases where a transaction cannot be thoroughly investigated within a specified timeframe, the case is escalated to senior management for a final decision.
Where the user fails to submit legitimate KYC details to conceal or withhold their identity.
Where the user fails to provide legitimate reasons if transactions are flagged as high risk based on RBA.
Such additional scenarios as maybe deemed necessary based on continuous RBA and EDD.
T. Employee Due Diligence and Risk Awareness Training
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.
U. Record Retention
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.
V. Anti-Bribery And Anti-Corruption Policy and Prohibition of Tipping off
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.
W. Travel Rule
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.
Y. Communication of Policy
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.
Z. Enforcement
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.
AA. Conclusion
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.
Registered Office (India)
Gradepro Technologies Private Limited
704, 7th Floor Sfc 16 Palm Court,
Industrial Estate,
Gurgaon - 122007 Haryana IN
Operations Office (India)
Office 530, Spaze I Tech, Sector 49, Gurugram
International Operations (USA)
8 THE GREEN STE, A
DOVER, DE, 19901
United States of America
Important Notice for Investors: Ensure the security of your transactions by verifying the URL begins with 'https://'. Grade Capital's sole official website is https://www.grade.capital. Vigilance is key to preventing fraud. Protect yourself by staying informed.
© 2025 GRADEPRO TECHNOLOGIES Pvt Ltd. All rights reserved.
Registered Office (India)
Gradepro Technologies Private Limited
704, 7th Floor Sfc 16 Palm Court,
Industrial Estate,
Gurgaon - 122007 Haryana IN
Operations Office (India)
Office 530, Spaze I Tech, Sector 49, Gurugram
International Operations (USA)
8 THE GREEN STE, A
DOVER, DE, 19901
United States of America
Important Notice for Investors: Ensure the security of your transactions by verifying the URL begins with 'https://'. Grade Capital's sole official website is https://www.grade.capital. Vigilance is key to preventing fraud. Protect yourself by staying informed.
© 2025 GRADEPRO TECHNOLOGIES Pvt Ltd. All rights reserved.