KYC & PMLA Policy
Know Your Customer & Prevention of Money Laundering Act Compliance
Last updated: December 2024
Policy Overview
MitraGlobal is committed to preventing money laundering and terrorist financing in compliance with the Prevention of Money Laundering Act (PMLA), 2002, and rules framed thereunder. This policy outlines our Know Your Customer (KYC) requirements and procedures.
Every user of MitraGlobal must complete KYC verification to access our platform's features. The level of verification determines your trading limits and available features.
1. Legal & Regulatory Framework
Our KYC program is designed in accordance with:
- Prevention of Money Laundering Act (PMLA), 2002 and amendments
- Prevention of Money Laundering (Maintenance of Records) Rules, 2005
- Reserve Bank of India (RBI) Master Direction on KYC
- Financial Action Task Force (FATF) Recommendations
- Information Technology Act, 2000 for digital verification
- Aadhaar Act, 2016 for biometric authentication (where applicable)
2. Core KYC Principles
Customer Acceptance Policy
Clear criteria for customer acceptance, including risk categorization. We reserve the right to refuse services to high-risk individuals or entities.
Customer Identification
Robust procedures to identify and verify customer identity using reliable, independent source documents, data, or information.
Ongoing Monitoring
Continuous monitoring of transactions and periodic review of customer risk profiles to ensure information remains current.
Risk Management
Risk-based approach to categorize customers and apply appropriate levels of due diligence based on risk assessment.
3. KYC Verification Levels
MitraGlobal offers three tiers of KYC verification, each with progressively higher limits and features:
Level 1: Basic Verification
Trading Limit: ₹1,00,000 per day | $1,000 per day
Required Documents:
- Valid email address (verified via OTP)
- Mobile number (verified via OTP)
- Full name as per government ID
- Date of birth
- Country of residence
Features Available:
- ✓ Browse marketplace
- ✓ Limited P2P trading (up to ₹1L/day)
- ✓ Deposit cryptocurrency
- ✗ Withdraw fiat currency
- ✗ Advanced trading features
Level 2: Verified (Standard KYC)
Trading Limit: ₹10,00,000 per day | $10,000 per day
Required Documents (in addition to Level 1):
- Identity Proof (any one):
- Passport
- Driving License
- Aadhaar Card
- Voter ID Card
- PAN Card with photograph
- PAN Card: Mandatory for Indian residents (for tax compliance under Section 139A of Income Tax Act)
- Selfie with ID: Live photo holding your ID document next to your face
Verification Process:
- Upload clear, colored copies of documents (all four corners visible)
- Documents must be valid (not expired)
- AI-powered document verification (instant preliminary check)
- Manual review by compliance team (within 24 hours)
- Facial recognition matching with ID photo
Features Available:
- ✓ Full P2P trading (up to ₹10L/day)
- ✓ Cryptocurrency deposits & withdrawals
- ✓ Create buy/sell orders
- ✓ Lower trading fees
- ✗ Fiat withdrawals above ₹50,000/day
Level 3: Enhanced Verification (Full KYC)
Trading Limit: Unlimited
Required Documents (in addition to Level 2):
- Proof of Address (any one, issued within last 3 months):
- Bank account statement
- Utility bill (electricity, water, gas)
- Telephone/mobile bill
- Government-issued residence certificate
- Rent agreement (registered)
- Source of Funds Declaration: For large transactions (>₹10L), explain the source of your crypto holdings
- Additional Verification (if applicable):
- Business registration documents (for business accounts)
- Income proof (for high-volume traders)
- Video KYC (live video call with compliance officer)
Features Available:
- ✓ Unlimited trading volume
- ✓ Unlimited fiat & crypto withdrawals
- ✓ Priority customer support
- ✓ Lowest trading fees (VIP rates)
- ✓ Access to premium features & promotions
- ✓ OTC (Over-the-Counter) desk access for large trades
4. Document Specifications & Requirements
Acceptable ID Documents
| Document Type | Validity | Notes |
|---|---|---|
| Passport | Must not be expired | All pages with stamps |
| Driving License | Must not be expired | Both sides required |
| Aadhaar Card | No expiry | Masked Aadhaar accepted (last 4 digits hidden) |
| PAN Card | No expiry | Mandatory for Indians, must have photo |
| Voter ID | No expiry | EPIC card, both sides |
Document Upload Guidelines
✓ DO
- • Upload clear, colored scans or photos
- • Ensure all text is legible and readable
- • Show all four corners of the document
- • Use good lighting (no shadows or glare)
- • Upload recent documents (address proof < 3 months)
- • File formats: JPG, JPEG, PNG, PDF
- • File size: Max 10 MB per document
- • Resolution: Minimum 300 DPI recommended
✗ DON'T
- • Upload black & white or grayscale copies
- • Submit blurry or low-quality images
- • Crop out parts of the document
- • Use edited or photoshopped documents
- • Upload expired documents
- • Submit documents belonging to someone else
- • Hide or cover any information (except Aadhaar masking)
- • Upload files larger than 10 MB
5. KYC Verification Process & Timeline
Step-by-Step Verification Process
- 1
Submit Application
Upload required documents via Settings > KYC Verification. Ensure all information matches exactly across documents.
- 2
Automated Screening (Instant)
Our AI system performs initial checks: document authenticity, face matching, data extraction, and sanctions screening.
- 3
Manual Review (1-24 hours)
Compliance team manually verifies documents, cross-checks information, and performs additional due diligence if required.
- 4
Decision & Notification
You'll receive email notification of approval or rejection. If rejected, resubmit with corrections. If approved, limits are immediately activated.
Typical Processing Times:
- Level 1 (Basic): Instant (automated)
- Level 2 (Verified): 2-4 hours (up to 24 hours during high volume)
- Level 3 (Enhanced): 24-48 hours (may require additional verification)
6. Common Rejection Reasons & How to Avoid Them
- Blurry or Low-Quality Images: Ensure good lighting and focus. Retake photos if text is not clearly readable.
- Expired Documents: Check expiry dates before uploading. Renew expired IDs first.
- Name Mismatch: Name on all documents must match exactly. Inform us if you've legally changed your name.
- Incomplete Documents: Upload both sides of ID cards. Don't crop or hide any part.
- Address Proof Too Old: Address proof must be dated within the last 3 months.
- Selfie Mismatch: Ensure your face is clearly visible, well-lit, and matches your ID photo. No sunglasses or face coverings.
- Tampered Documents: Never edit, photoshop, or modify documents. This results in permanent account ban.
7. Data Security & Privacy
Your personal information and KYC documents are protected with industry-leading security:
- Encryption: All documents encrypted with AES-256 encryption at rest and TLS 1.3 in transit
- Access Controls: Only authorized compliance personnel can access KYC documents (all access logged)
- Secure Storage: Documents stored in SOC 2 Type II certified data centers in India
- No Sharing: Your KYC data is never shared with third parties except as required by law
- Right to Access: You can request a copy of your KYC documents anytime
- Data Retention: KYC records retained for 7 years after account closure (as per PMLA requirements)
8. Periodic KYC Updates & Re-verification
To ensure our records remain current, periodic KYC updates are required:
- Low Risk Customers: Re-verification every 3 years
- Medium Risk Customers: Re-verification every 2 years
- High Risk Customers: Re-verification annually
- PEPs (Politically Exposed Persons): Re-verification every 6 months
You'll receive email notification 30 days before your KYC update is due. Failure to update may result in trading restrictions until re-verification is complete.
Important: If your personal information changes (name, address, phone, email), you must update your KYC details within 30 days. Major changes may require re-verification with new documents.
9. Special Cases & Exceptions
Business/Corporate Accounts
Additional documents required:
- Certificate of Incorporation
- Memorandum & Articles of Association
- Board Resolution authorizing crypto trading
- PAN card of the business entity
- KYC of all directors and beneficial owners (>25% ownership)
- Latest audited financial statements
Politically Exposed Persons (PEPs)
If you are a PEP (current or former senior government official, politician, military officer, or close relative of PEP), additional Enhanced Due Diligence applies including source of wealth verification and senior management approval.
Non-Resident Indians (NRIs)
Additional requirements:
- Passport (mandatory)
- Proof of current foreign address
- PAN card (if available, otherwise declaration)
- Visa/work permit for country of residence
10. Consequences of Non-Compliance
Failure to comply with KYC requirements or providing false information will result in:
- • Trading Restrictions: Account limited to withdrawals only (no new trades)
- • Account Suspension: Temporary suspension until KYC is completed
- • Account Termination: Permanent ban for submitting fake/forged documents
- • Fund Freezing: Funds may be frozen pending investigation
- • Legal Action: Fraudulent KYC submissions reported to law enforcement (Section 420 IPC, PMLA violations)
- • Blacklisting: Permanent ban from all future account creation
11. KYC Support & Assistance
If you face issues with KYC verification, our support team is here to help:
- KYC Helpdesk: kyc@mitrap2p.com
- Live Chat: Available 24/7 via website chat
- Help Center: https://mitrap2p.com/help (Detailed KYC guides with screenshots)
Average response time: < 2 hours for KYC queries
Important Legal Notice
This KYC policy is subject to change in accordance with regulatory requirements. MitraGlobal reserves the right to request additional documents or information at any time to comply with AML/KYC obligations. Submitting false, forged, or fraudulent documents is a criminal offense under the Indian Penal Code and PMLA, punishable with imprisonment and fines. By submitting KYC documents, you certify that all information provided is true, accurate, and complete to the best of your knowledge.