AML & CFT Policy Statement

1. Regulatory Compliance

MitraGlobal operates in full compliance with applicable AML/CFT regulations, including but not limited to:

• Prevention of Money Laundering Act (PMLA), 2002 (India)
• Financial Action Task Force (FATF) recommendations
• Reserve Bank of India (RBI) guidelines on Virtual Digital Assets
• International AML/CFT standards and best practices
• Unlawful Activities (Prevention) Act, 1967

2. Risk-Based Approach

We employ a comprehensive risk-based approach to identify, assess, and mitigate money laundering and terrorist financing risks:

Risk Assessment Criteria

3. Customer Due Diligence (CDD)

Standard CDD Measures

All users must complete the following verification steps:

• Identity Verification: Government-issued photo ID (Passport, Driving License, Aadhaar Card)
• Address Verification: Utility bills, bank statements, or government correspondence (less than 3 months old)
• Email & Phone Verification: Active email address and mobile number with OTP verification
• Selfie Verification: Live photo matching the submitted ID document
• PAN Verification: Mandatory for Indian residents (for tax compliance)

Enhanced Due Diligence (EDD)

High-risk customers are subject to Enhanced Due Diligence, including:

• Source of wealth and source of funds verification
• Detailed transaction monitoring and pattern analysis
• Senior management approval for account opening
• More frequent periodic reviews (quarterly instead of annual)
• Additional documentation and background checks

Ongoing Monitoring

We continuously monitor customer activity to detect suspicious transactions:

• Real-time transaction monitoring using AI/ML algorithms
• Periodic review of customer risk profiles (annual minimum, quarterly for high-risk)
• Update of customer information when significant changes occur
• Screening against sanctions lists and PEP databases (daily updates)

4. Transaction Monitoring & Suspicious Activity Detection

Red Flags & Indicators

Our systems automatically flag the following suspicious activities:

Reporting Obligations

MitraGlobal strictly adheres to reporting requirements:

• Suspicious Transaction Reports (STR): Filed with Financial Intelligence Unit - India (FIU-IND) within 7 days of detection
• Cash Transaction Reports (CTR): All cash transactions above ₹10 lakhs reported within prescribed timelines
• Cross-Border Wire Transfer Reports: International transactions reported as per PMLA requirements
• Counterfeit Currency Reports (CCR): Immediate reporting if detected

5. Prohibited Activities & Restricted Jurisdictions

Zero Tolerance for:

Restricted Jurisdictions

We do not serve customers from the following high-risk jurisdictions:

• FATF blacklisted countries (North Korea, Iran, Myanmar)
• Countries under comprehensive sanctions (Syria, Cuba, Crimea)
• Non-cooperative jurisdictions identified by FATF
• Jurisdictions with strategic AML/CFT deficiencies

6. Sanctions Screening & PEP Checks

All customers and transactions are screened against:

• OFAC SDN List: US Office of Foreign Assets Control Specially Designated Nationals
• UN Sanctions Lists: United Nations Security Council consolidated list
• EU Sanctions Lists: European Union financial sanctions
• HMT Sanctions: UK His Majesty's Treasury financial sanctions
• PEP Databases: Politically Exposed Persons worldwide
• Adverse Media: Negative news and reputational risk screening

Screening is performed at onboarding, daily for existing customers, and real-time for transactions. Any matches result in immediate account freeze pending investigation.

7. Record Keeping & Data Retention

MitraGlobal maintains comprehensive records as required by law:

• Transaction Records: Minimum 7 years from transaction date (including crypto wallet addresses, amounts, timestamps)
• KYC Documents: Minimum 7 years after account closure
• Correspondence: All customer communications retained for 7 years
• STR Records: 10 years from the date of filing the report
• Account Files: Complete audit trail of all account activities

All records are stored securely with encryption and access controls. Records are readily available to regulatory authorities upon request.

8. Training & Awareness

All MitraGlobal employees receive comprehensive AML/CFT training:

• Mandatory AML/CFT training during onboarding (within first week of employment)
• Annual refresher training for all staff
• Specialized training for compliance, customer service, and risk teams (quarterly)
• Updates on new typologies, regulations, and red flags
• Testing and certification to ensure comprehension

9. Governance & Compliance Structure

Compliance Oversight

• Chief Compliance Officer (CCO): Responsible for overall AML/CFT program
• Money Laundering Reporting Officer (MLRO): Designated person for STR filing
• Compliance Committee: Senior management oversight, quarterly meetings
• Independent Audit: Annual third-party AML/CFT audit
• Board Reporting: Quarterly compliance reports to the Board of Directors

Policy Review

This AML/CFT policy is reviewed and updated:

• Annually, or more frequently if required by regulatory changes
• After significant regulatory updates or enforcement actions
• Following any AML/CFT incidents or internal audit findings
• When business model, products, or risk profile changes materially

10. Customer Cooperation & Responsibilities

Customers are required to:

• Provide accurate, complete, and truthful information during KYC
• Update their information when material changes occur (address change, occupation, etc.)
• Respond promptly to requests for additional information or documentation
• Ensure all transactions are legitimate and comply with applicable laws
• Not use the platform for money laundering, terrorist financing, or other illegal activities
• Understand and accept that suspicious activities will be reported to authorities

11. Reporting Concerns

If you suspect money laundering or terrorist financing activity, please report immediately to: