AML & CFT Policy – CoinXpe
Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy - CoinXpe
This Anti-Money Laundering and Counter-Financing of Terrorism Policy (“Policy”) sets out the principles, controls, and procedures adopted by SUPERMINT INFOTECH PRIVATE LIMITED (“Company”, “CoinXpe”, “we”, or “us”) to prevent misuse of its platform for money laundering, terrorist financing, or other unlawful activities.
This Policy is framed in accordance with:
- Prevention of Money Laundering Act, 2002 (“PMLA”)
- PML Rules, as amended from time to time
- FIU-IND AML/CFT Guidelines for Virtual Digital Asset Service Providers (VDA-SPs)
- Applicable advisories issued by RBI, and law enforcement agencies
1. Policy Objective
The objectives of this Policy are to:
- Prevent CoinXpe from being used for money laundering or terrorist financing
- Establish risk-based customer due diligence and monitoring
- Detect, investigate, and report suspicious activities
- Ensure timely compliance with FIU-IND and other regulatory authorities
- Protect the integrity of the financial system and CoinXpe platform
2. Scope & Applicability
This Policy applies to:
- All users of the CoinXpe platform
- All employees, directors, officers, and compliance personnel
- All products and services including on-ramp, off-ramp, wallets.
3. Customer Due Diligence (KYC Framework)
CoinXpe follows a risk-based KYC approach. No user is allowed to transact without completing the minimum required KYC.
3.1 KYC Levels
Level 1 – Basic KYC (Mandatory)
- Full name
- Date of birth
- PAN verification
- Mobile number & email verification
Access:
- Limited platform access
Level 2 – Full KYC (Standard Users)
- Aadhaar (offline / masked) or equivalent ID
- Live selfie / liveness check
- Bank account verification
- Address verification
Access:
- INR on-ramp and off-ramp
- Full access of CoinXpe
Level 3 – Enhanced Due Diligence (EDD)
Applicable for:
- High-value transactions
- High-risk users
- Repeated abnormal activity
May include:
- Source of funds / wealth declaration
- Additional documents
- Video KYC or manual review
CoinXpe reserves the right to ask for additional information at any time.
4. Risk Categorization of Users
Users are classified as:
- Low Risk – Regular retail users with normal behavior
- Medium Risk – Higher transaction frequency or volumes
- High Risk –
- Politically Exposed Persons (PEPs)
- Users from high-risk jurisdictions
- Users with abnormal or complex transaction patterns
Enhanced monitoring and controls apply to high-risk users.
5. Transaction Monitoring
CoinXpe maintains a continuous transaction monitoring system to identify suspicious or unusual activities.
Monitoring includes:
- Large or rapid INR deposits or withdrawals
- Structuring of transactions to avoid thresholds
- Use of multiple accounts or devices
- Sudden spikes in transaction volume
- Transfers linked to flagged or sanctioned wallets
Transactions are monitored in real-time and post-facto using automated tools and manual compliance review.
6. Suspicious Transaction Reporting (STR)
6.1 Identification of Suspicious Transactions
A transaction is considered suspicious if:
- It has no clear economic or lawful purpose
- It involves proceeds of crime
- It shows unusual patterns inconsistent with user profile
- It is linked to fraud, cybercrime, or mule activity
6.2 Reporting to FIU-IND
7. Account Freezing & Restrictions
CoinXpe may:
- Freeze accounts or wallets
- Withhold withdrawals
Without prior notice if:
- Suspicious activity is detected
- Required by FIU-IND, law enforcement, or court orders
- There is a violation of AML obligations
Funds shall remain frozen until regulatory clearance is obtained.
8. Record Keeping
In compliance with PMLA:
- KYC records, transaction logs, and STRs are retained for minimum 5–10 years.
- Records are securely stored and made available to authorities upon lawful request.
- Audit trails are maintained for all compliance actions.
9. Employee Training & Awareness
- Employees handling compliance, operations, and support are regularly trained on AML/CFT obligations.
- Training includes detection of red flags, reporting obligations, and legal consequences of non-compliance.
10. Governance & Compliance Oversight
- CoinXpe has designated a Principal Officer / Compliance Officer responsible for AML compliance.
- The Compliance Officer acts as the single point of contact with FIU-IND.
- Periodic internal audits and reviews are conducted to ensure the effectiveness of controls.
11. Cooperation with Authorities
CoinXpe fully cooperates with:
Information is shared strictly in accordance with applicable laws.
12. Policy Review & Updates
This Policy is reviewed periodically and updated to reflect:
- Changes in laws or regulations
- FIU-IND advisories
- Risk assessment outcomes
Updates are effective upon publication on the CoinXpe website.
13. Compliance & AML Officer
CoinxPe has appointed a dedicated Compliance & AML Officer to oversee the implementation and enforcement of this policy.
Compliance / Principal Officer
Name: Mr Asif Khan
Designation: Compliance & AML Officer
SUPERMINT INFOTECH PRIVATE LIMITED
Email: compliance@supermintinfotech.com