AML / KYC Policy

Platform: Geniuz Exchange (VDA Facilitation Platform) · Company: TRADEGENIUZ CAPITAL PRIVATE LIMITED

Effective Date: 14 April 2026 · Last Updated: 14 April 2026

🏢 TRADEGENIUZ CAPITAL PRIVATE LIMITED📋 CIN: U65999TN2022PTC151226🧾 GST: 33AAJCT2975M1ZS📍 ROC: Chennai✅ Incorporation Date: 08 April 2022⚖️ Governing Law: India📍 Registered Office: No.9/311, Hajiyar Street, Kumbakonam, Thanjavur, Tamil Nadu - 612001, India

Summary. This policy explains our risk-based AML/KYC controls, customer verification standards, sanctions and fraud screening, monitoring, record keeping, and account restrictions where required by law or compliance.

Regulatory disclosure. The Company has applied for registration with FIU-IND as a Virtual Digital Asset Service Provider. Approval is pending.

1. Purpose and scope

This policy sets out controls used by the Company to prevent misuse of the Platform for money laundering, terrorist financing, sanctions evasion, fraud, and other unlawful activity.

2. Regulatory approach

We apply a risk-based framework consistent with applicable Indian law and prudent compliance practice, including relevant requirements under the Companies Act, Information Technology Act, FEMA, PMLA, and related rules.

3. Customer due diligence (CDD)

Identity verification may be required before account activation, higher limits, or transactions. Users may be asked for PAN, Aadhaar or other government ID where legally permissible and operationally necessary. Corporate users may be asked for incorporation records, board authorization, authorized signatory proof, and beneficial owner information.

4. Enhanced due diligence (EDD)

EDD may be applied for high-value, high-risk, unusual, or cross-border-related activity. We may request additional information on source of funds, source of wealth, business profile, entity structure, and transaction purpose.

5. PEPs, sanctions, and watchlist screening

We may screen users, counterparties, and wallet indicators using sanctions lists, PEP checks, fraud alerts, and blockchain analytics tools. Matches or risk triggers may result in restrictions, holds, decline, or reporting where required.

6. Ongoing monitoring

Transactions and account behavior may be monitored using automated and manual controls for unusual activity, velocity patterns, structuring attempts, suspicious wallet exposure, and inconsistent onboarding information.

7. Suspicious activity and reporting

Where required by law, the Company may file reports or disclosures with competent authorities. To the extent legally restricted, users may not receive prior notice of such reporting.

8. Record keeping

KYC, transaction, communication, and compliance records may be retained for periods required by law, AML obligations, audits, fraud prevention, legal process, or dispute resolution.

9. User obligations

Users must provide accurate and current information, promptly provide documents requested for lawful verification, and cooperate with compliance reviews. Failure to cooperate may lead to account restrictions.

10. Restrictions, holds, and account action

Transactions may be delayed, refused, frozen, reversed where legally permitted, or otherwise restricted for legal, compliance, sanctions, fraud, or risk reasons. These controls apply even after account creation.

11. Third-party service providers

We may rely on third-party verification providers, banking and payment partners, fraud tools, and blockchain screening systems. Subject to applicable law, the Company is not liable for third-party outages or failures beyond reasonable control.

12. Policy updates and contact

This policy may be amended from time to time. Contact: support@geniuzexchange.com | grievance@geniuzexchange.com