KYC/AML Policy

RummyTreasure is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our procedures for customer identification, monitoring, and reporting.

We comply with international standards including:

• Financial Action Task Force (FATF) recommendations
• International AML/CFT standards
• Payment processing regulations
• Local jurisdictional requirements

2.1 Basic Verification (Tier 1)

Required for account creation:

• Full name
• Date of birth
• Email address
• Country of residence

Limits: Deposits only, no withdrawals

2.2 Standard Verification (Tier 2)

Required for withdrawals up to $10,000/month:

• Government-issued ID (passport, driver's license, national ID)
• Proof of address (utility bill, bank statement, less than 3 months old)
• Selfie with ID document
• Phone number verification

2.3 Enhanced Verification (Tier 3)

Required for withdrawals exceeding ₹10,00,000/month:

• All Tier 2 requirements
• Source of funds documentation
• Proof of wallet/account ownership
• Enhanced due diligence interview
• Bank account verification

3.1 Risk Assessment

We assess customer risk based on:

• Geographic location
• Transaction patterns
• Source of funds
• PEP (Politically Exposed Person) status
• Sanctions screening results

3.2 Ongoing Monitoring

• Continuous transaction monitoring
• Periodic review of customer information
• Behavioral analysis
• Update requests for expired documents

3.3 Enhanced Due Diligence (EDD)

Applied to high-risk customers including:

• PEPs and their associates
• High-risk jurisdictions
• Large transaction volumes
• Complex ownership structures

4.1 Transaction Monitoring

• Real-time transaction screening
• Automated suspicious activity detection
• Pattern recognition algorithms
• Threshold-based alerts
• Manual review of flagged transactions

4.2 Red Flags

We monitor for suspicious activities including:

• Rapid deposit and withdrawal patterns
• Structuring transactions to avoid thresholds
• Multiple accounts from same IP/device
• Unusual geographic patterns
• Mixing service usage
• Connection to known illicit addresses

4.3 Reporting Obligations

• Suspicious Activity Reports (SARs)
• Currency Transaction Reports (CTRs)
• Law enforcement cooperation
• Regulatory reporting

5.1 Transaction Analysis

• Payment source verification and screening
• Transaction pattern analysis
• Risk scoring of incoming payments
• Suspicious activity detection

5.2 Travel Rule Compliance

For transactions exceeding ₹83,000:

• Originator information collection
• Beneficiary information verification
• Information transmission to receiving VASP
• Record retention for 7 years

5.3 Wallet Verification

• Proof of wallet ownership
• Message signing requirements
• Whitelist-only withdrawals option

6.1 Sanctions Lists

We screen against:

• UN Sanctions List
• OFAC SDN List
• EU Consolidated List
• UK HM Treasury List
• Local jurisdiction lists

6.2 PEP Database

• Global PEP screening
• Family and close associates
• Enhanced monitoring for PEPs
• Senior management approval required

6.3 Restricted Countries

Services not available in:

• FATF high-risk jurisdictions
• Sanctioned countries
• Countries with payment processing restrictions
• Specific Indian states (as per local law)

We maintain records for:

• Customer identification documents: 5 years after relationship ends
• Transaction records: 7 years
• Suspicious activity reports: 5 years
• Risk assessments: Duration of relationship + 5 years
• Communication logs: 3 years

All records are securely stored and available for regulatory inspection.

As our customer, you must:

• Provide accurate and complete information
• Update information when it changes
• Respond to verification requests promptly
• Not use the platform for illegal activities
• Report suspicious activities you observe
• Comply with your local regulations

Failure to comply with KYC/AML requirements may result in:

• Account restrictions or suspension
• Withdrawal limitations
• Account termination
• Reporting to authorities
• Fund freezing (as required by law)
• Legal action

Our compliance program includes:

• Regular staff training on AML/CFT
• Compliance officer designation
• Internal audit procedures
• External compliance reviews
• Continuous improvement processes

For KYC/AML related inquiries:

Compliance Team: compliance@rummytreasure.com

MLRO (Money Laundering Reporting Officer): mlro@rummytreasure.com

Response time: 1-3 business days