AML & KYC Policy

1. POLICY STATEMENT
   
   Casper Digital Inc. and its employees, third parties, its customers, and clients are at all times committed to the highest standards of anti-money laundering (AML) and counter-terror financing (CTF), including anti-fraud, anti-corruption, and taking measures to mitigate against financial crime.
   
   The terms "We", "Our", "Company", “BitSave” and "Us" refer to Casper Digital Inc., and the terms "User", "You" and "Your" refer to a User of our Online Platforms (Website and/or Mobile Application).
    

2. BACKGROUND
   
   BitSave is a Company registered as per the Laws of Seychelles. This Policy describes the Company's procedures instituted to ensure that the services offered by the Company are not being used by the users to facilitate the commission of any criminal offences, including but not limited to those under the AML - CFT Act, 2020 and other relevant applicable laws. The Company has prepared this AML Policy to ensure the transparency of transactions and to ensure the prevention of money laundering and other illegal activities.
    

3. PURPOSE & STATEMENT OF OBJECT
   
   In order to mitigate its risks relating to money laundering and other illegal activities, BitSave intends to put in place this policy, the KYC and Due Diligence Procedure including Risk Management Procedure, Customer Verification Procedure, Transaction Monitoring Terms and other relevant processes as defined below.
    

4. KEY TERMS
   
   4.1 What is Money Laundering and Terrorist Financing?
    

• Money laundering is the illegal process of making large amounts of money generated by criminal activity, such as drug trafficking or terrorist funding, appear to have come from a legitimate source. 

• Terrorism financing is the provision of funds or providing financial support to individual terrorists or non-state actors. The objective of such financing is to support terrorist acts or support terrorist organizations that commit terrorist acts.

 

4.2. Data Protections 

 

In designing procedures and measures to mitigate AML/CTF risk, regard will be given to the rights and freedoms of citizens as regard to the protection of personal data. The measures designed will be proportionate and in compliance with the regulations of the geographies where BitSave operates.

 

1. KYC & DUE DILIGENCE PROCEDURES
   
   BitSave adheres to and complies with the principles of the Know Your Customer (KYC) policy which aims to prevent financial crime and money laundering through client identification and due diligence.
    

If the Company finds any user information obtained in accordance with the procedure described under this clause to be inadequate, insufficient, or sanction screened, the Company will in its discretion either refuse or terminate (as the case may be) the registration of such user account or require verification of such user’s identification documents again.
 

All customers/clients, who are new to the organization will undergo procedural due diligence checks prior to opening an account, as laid out below.

5.1. Primary Verification Identification

ID Proof of every new individual will be obtained and recorded on a New Customer Application. The very first step when transacting on the Platform would be to produce documentation that would verify Identification, Address, and Selfie/ Liveness checks. 

Identification & Address Proof: Documents for Identification and  address are required with the name of the person on them.

Acceptable forms of ID can include:

Drivers Licence, Passport, Bank Statement, Utility Bill (in all markets except India). For India, PAN Card and/or AADHAAR Card details are required for KYC. The Company reserves all the rights to get the verification of your PAN and/or Aadhaar done from the government authorities.

Selfie-check/ Liveness Check: As part of the selfie-taking/ liveness check process the user is asked to turn to both sides and blink. The company takes its KYC procedures seriously however, the process of selfie/ liveness check is subject to the technical issues faced by the company. 

5.2. Secondary Verification

The company conducts a secondary verification in the following scenarios: 

 

• For transactions over 100 Thousand USD by the Individual;

• For users having a large number of outward transactions on the app, as the company deems alarming;

• For any suspicious activity as per the company’s policies, rules and regulations, and laws of the land;

• For any user or transaction of the user having a high negative score from any of our third-party compliance tools, etc.

• In the above-mentioned scenarios, the users would require a subsequent step after those mentioned under Clause 5.1. In such a case a user will be asked to undergo a Video KYC and provide additional proofs as required by the company. 

Herein, a Source of the Funds and verification of the above point, KYC ought to be mentioned and only upon the verification of the same will the Platform allow for further transactions to take place.

5.3. Due Diligence Checks

As we understand the importance of due diligence checks and ongoing due monitoring; we will conduct background checks prior to account acceptance, details of which will be kept on file as evidence of due diligence and anti-money laundering checks.
 

Due diligence checks will be conducted as per the regulations and requirements. All documents, accounts, and transactions associated with clients/customers will be retained based on the laws and regulations of the country that the user signs up.

5.4. Monitoring & Auditing Due Diligence
 

The Company has appointed a Money Laundering Reporting Officer (“MLRO”) who is responsible for ensuring that due diligence checks and anti-money laundering measures are being completed and are fit for purpose. Regular audits are conducted on due diligence forms, company checks, and ongoing monitoring.
 

Team will conduct ongoing due diligence checks for client/customer accounts. This will ensure we keep up-to-date information and data and will also keep a check that no adverse information has arisen since the last due diligence was performed.
 

A risk-based approach will be followed while conducting due diligence and no transactions will be conducted with sanctioned or banned individuals. 

5.5. Screening
 

As part of our on-boarding process as well as ongoing due diligence process, all the individual customers, connected parties of the customer, ultimate beneficial owners of the customer will undergo the screening process. No business or transactions will be conducted with the sanctioned individuals.

The company will be screening the names against all the relevant lists (Sanctions, PEP and adverse media, regulatory and law enforcement lists) on a monthly basis.

 

5.6.Enhanced Due Diligence (EDD)
 

Where a customer is assessed as higher risk either internally by the Company, then Enhanced Customer Due Diligence (EDD) measures are applied by the company. That includes senior management review and sign-off of new business relationships. The Company follows a process that allows for the identification of potential red flags as well as checks on behaviour, pattern, and volume of the transactions.
 

Enhanced monitoring to be conducted on a risk-based approach of any business relationship or transactions involving a high-risk third country or where any potential concerns are identified during standard due diligence. 

In order to comply with applicable laws and regulations, and to help prevent fraud and money laundering, we will conduct enhanced due diligence on customers who are classified as Politically Exposed Persons (PEPs). PEPs are individuals who hold or have held high-level public positions, such as heads of state, senior politicians, senior government officials, and members of judicial bodies.

 

If you are a PEP, we will ask you to provide us with additional personal information and documentation as part of our enhanced due diligence process. This will include information about your public position and your family members, approval from relevant parties, income documents (source of funds and source wealth corroboration) as well as documentation to verify your identity and/or address, such as a copy of your passport, driver's license, or utility bill. You will also be subject to video KYC and enhanced ongoing monitoring.

 

5.7. Record Keeping
 

BitSave will ensure that records of all Customer Due Diligence (CDD) documentation and customer transactions are held for a term as mandated by the laws and regulations of the country that the user signs up from. All CDD records and documents (including transactions) are kept for at least 5 years after the business relationship has ended.

These records include but are not limited to CDD documentation, Business wide risk assessments, customer risk assessments and suspicious activity reports.


 

1. RISK MANAGEMENT PROCEDURE
    

The Company will categorize its users into low, medium, or high-risk categories, after undertaking an appropriate risk assessment of each user based on the following factors (including without limitation).
 

• Sufficiency and adequacy of identification information submitted as mentioned under this policy. 

• Their social and/or financial status; or 

• Nature of user’s business/vocational activities; or

• Guidance notes circulated by various governmental and intergovernmental organizations.
   

A user will also be categorised as high-risk based on risk factors such as sanctions hits, PEP screenings, adverse media, nationality, country of domicile, transaction volume and age.

 

You acknowledge that in order to maintain the integrity of the Risk Management Procedure, the Company will keep your risk categorization and any data related thereto confidential. You will not be entitled to seek disclosure of your risk categorization. However, the Company will disclose the user’s risk categorization data to the competent enforcement authority if it finds that a particular User has executed or is likely to execute any Suspicious Transaction.

 

 

1. TRANSACTION MONITORING
   
   We have built an in-house system to trigger unusual and suspicious transactions. Those transactions will be inspected via a 3rd party vendor - KYC Hub. BitSave will monitor the following categories of transactions, and will conduct due diligence on an ongoing basis on them:
    

• Large, complex transactions, including those with unusual patterns that are inconsistent with a User’s normal/ expected level of activity, without an apparent economic rationale or legitimate purpose; and

• Transactions that involve high account turnover, inconsistent with the size of the balance ordinarily maintained by a User.

• Once a User has participated in transactions of a total value of at least over the course of their engagement with BitSave, or deposits or transacts in an amount of at least USD 100 Thousand on BitSave, BitSave will also conduct ‘chain analysis’ to identify the relevant public address for such user and earmark such user as either as ‘high risk’, ‘medium risk’, or ‘low risk’ based on parameters such as the use of cryptocurrencies by such users at online gambling websites, darknet websites, etc.

Transaction Monitoring workflow and escalation process:

Initial Screening: All incoming and outgoing transactions are screened as per above mentioned rules and thresholds.

Risk Assessment: If a transaction raises any red flags, it undergoes a risk assessment by the AML team to determine its level of risk.

Further Investigation: High-risk transactions are subject to further investigation by the AML team to gather additional information and determine its legitimacy.

Report Generation: If the transaction is determined to be suspicious, the AML team will generate a suspicious activity report (SAR) and submit it to the relevant authorities.

Escalation: In cases where a transaction cannot be thoroughly investigated within a specified timeframe, the case is escalated to senior management for a final decision.

Monitoring and Review: The AML team continuously monitors all transactions for suspicious activity and reviews the transaction monitoring process to ensure it remains effective.

 

1. HANDLING OF SUSPICIOUS CONDUCT
   
   The company shall have the right to adopt measures such as suspending any suspicious transaction, rejecting transaction applications, reversing transactions, freezing suspicious accounts, and reporting to the competent authorities if the company uncovers any of the following conducts on the part of the user:
    

• the user refuses to provide valid identity certificates or other identification documents;

• the user refuses to update his/her profile without any justifiable reason;

• where, after necessary measures are adopted, the company still doubts the authenticity, validity and/or integrity of the user’s identity information;

• the user forges or alters his or her identification documents to deceive the company to allow it to open an account with the company; or

• the user refuses to provide a reasonable explanation for the suspicious conduct thereof, or the user’s explanation is obviously unjustifiable.
  
   

1. PERIODIC REVIEW
   
   The company will conduct periodic reviews of all its users. All high-risk users will be subject to re-KYC process every year and all low and medium risk users will be subject to re-KYC process every 3 years.  
    

 

1. TRAINING OF EMPLOYEES
   
   A general appreciation of the background to money laundering, and the subsequent need for identifying and reporting of any suspicious transactions to the appropriate designated official shall be provided to all employees who will be dealing with customers or their transactions, irrespective of the level of seniority.
   
   Refresher training at regular intervals shall be provided to ensure that staff does not dilute its approach to AML Implementation.
   
    

2. OUTSOURCING
   
   For the purposes of verification of any user’s identity and monitoring of transactions, the Company relies on appropriate and licensed third-party service providers to authenticate the identification and other incidental details provided by you.
    

 

1. REVIEW OF THE POLICY
   
   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.

 

 

For Casper Digital Inc.
 

Vishnu Vennaraparmbil Karthikeyan
Compliance Officer

Place: Bangalore, India
Date: 20 February 2023