AML & KYC Policy

1. Purpose & Legal Framework

1.1 This AML & KYC Policy applies to all clients, users, beneficiaries, and transacting parties on the TitanTrustee Platform. It is designed to prevent the Platform from being used for money laundering, terrorist financing, or other financial crimes.

1.2 Legal basis for this Policy includes:

• Prevention of Money Laundering Act, 2002 and PMLA (Maintenance of Records) Rules, 2005.
• Reserve Bank of India Master Direction on Know Your Customer (KYC), 2016 (as amended).
• Financial Action Task Force (FATF) Recommendations.
• Foreign Exchange Management Act, 1999 (FEMA).
• The Information Technology Act, 2000 (as amended).

2. Designated Compliance Officers

In accordance with PMLA requirements, TitanTrustee has appointed the following:

3. Know Your Customer (KYC) / Know Your Business (KYB)

3.1 Mandatory at onboarding

No client may transact on the Platform until satisfactory KYC/KYB has been completed. The following verification is mandatory:

For Individuals:

• Government-issued photo ID (PAN Card — mandatory; Aadhaar — masked last 4 digits).
• Date of birth verification.
• Address proof (Aadhaar/Voter ID/Passport/Utility Bill).
• Mobile number and email verification (OTP-based).

For Businesses (KYB):

• Certificate of Incorporation / Registration Certificate.
• PAN of the entity.
• GST Registration Certificate (where applicable).
• MOA/AOA or Partnership Deed (as applicable).
• Board Resolution / Authorisation letter for the signing representative.
• KYC of Directors / Partners / Proprietor (as per individual requirements above).
• Beneficial Owner (UBO) declaration: any individual holding ≥10% ownership or control.
• Bank account details and penny-drop validation.

3.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is conducted for:

• Politically Exposed Persons (PEPs) and their family members or close associates.
• Clients from high-risk jurisdictions (FATF grey/black list countries).
• Transactions above ₹10,00,000 (Rupees Ten Lakhs) in value.
• Clients with adverse news, negative AML screening hits, or complex ownership structures.
• Any case where standard due diligence is insufficient to mitigate risk.

EDD may include: senior management approval, source-of-funds declaration, enhanced monitoring, periodic re-verification.

3.3 Ongoing KYC Refresh

• Low-risk clients: KYC reviewed every 10 years or on material change.
• Medium-risk clients: KYC reviewed every 8 years.
• High-risk clients / PEPs: KYC reviewed every 2 years or more frequently.

TitanTrustee reserves the right to request updated KYC at any time.

4. Risk Categorisation

5. Transaction Monitoring

TitanTrustee operates an automated transaction monitoring system that flags:

• Unusual or unexplained transaction volumes inconsistent with the client's business profile.
• Rapid fund-in, fund-out patterns suggesting pass-through/layering.
• Multiple small transactions structured to avoid reporting thresholds (structuring / smurfing).
• Transactions involving counterparties in high-risk jurisdictions.
• Settlement to beneficiary accounts that differ from those used during onboarding.
• High refund rates or abnormal dispute patterns.
• Transactions flagged by sanctions/PEP screening.

Flagged transactions are reviewed by the Compliance team. TitanTrustee may suspend or delay transactions pending review.

6. Sanctions & PEP Screening

All clients, beneficial owners, directors, and beneficiaries are screened at onboarding and on an ongoing basis against:

• UN Security Council Consolidated Sanctions List.
• OFAC (US Treasury Office of Foreign Assets Control) SDN List.
• Indian Government / Ministry of Home Affairs designated entities list.
• Interpol notices.
• Politically Exposed Persons (PEP) databases.
• Adverse media screening (negative news).

Any sanctions match results in immediate account suspension and escalation to the Principal Officer.

7. Suspicious Transaction Reports (STR)

7.1 Where TitanTrustee has reason to believe a transaction involves proceeds of crime or is connected to money laundering or terrorist financing, the Principal Officer shall file a Suspicious Transaction Report (STR) with the Financial Intelligence Unit – India (FIU-IND) within 7 working days of forming such suspicion.

7.2 Tipping-off prohibition: TitanTrustee is legally prohibited from disclosing to the client that an STR has been filed or that they are under investigation. Any such disclosure (tipping-off) is a criminal offence under PMLA.

7.3 TitanTrustee may also file Cash Transaction Reports (CTRs) for cash transactions above ₹10 lakhs (where applicable) and Cross-Border Wire Transfer Reports (CCTRs) as required by PMLA.

8. Record Retention

In compliance with PMLA Rule 3, TitanTrustee retains the following for a minimum of 5 years:

• All KYC/KYB documents and verification records.
• Transaction records (date, amount, parties, nature of transaction).
• STR and CTR filings and related correspondence.
• Correspondence and business records related to clients.

Records are stored securely in encrypted form in India (AWS ap-south-1) and made available to FIU-IND or any competent authority upon lawful request.

9. Staff Training

All TitanTrustee employees with access to client or transaction data receive periodic AML/CFT training covering: recognition of suspicious activity, KYC obligations, STR filing procedures, and tipping-off prohibition.

10. Non-Cooperation & Account Termination

TitanTrustee reserves the right to refuse onboarding, suspend services, or terminate an account where a client: (a) refuses to provide required KYC/KYB documents; (b) provides false or misleading information; (c) is subject to a sanctions match; (d) triggers a high-risk AML flag that cannot be mitigated through EDD.

11. Contact — Compliance Queries

Email: legal@titantrustee.com
Address: First Floor, Plot No. 13, Nawada Housing Complex, Uttam Nagar, New Delhi – 110059, India
Phone: +91-11-4118-6363

All policies are governed by Indian law. Disputes are subject to the exclusive jurisdiction of courts at New Delhi. Latest version always at titantrustee.com/legal.