AML & KYC Policy 

1. Introduction

Zenguard Headquarters Private Limited is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy applies to all financial products and services operated under the Zenguard ecosystem, including Zenguard Markets, Zenguard Funding, and Zenguard Wallets.

This policy is formulated in compliance with the Prevention of Money Laundering Act, 2002 (PMLA), the rules and regulations of the Reserve Bank of India (RBI), guidelines issued by the Securities and Exchange Board of India (SEBI), and the Financial Intelligence Unit — India (FIU-IND) requirements.

2. KYC Requirements

All users of Zenguard financial products must complete KYC verification before accessing trading, funding, or wallet services. The KYC process requires: Government-issued photo identification (Aadhaar, PAN Card, Passport, Voter ID, or Driving License). Proof of address (utility bill, bank statement, or Aadhaar). PAN Card (mandatory for financial transactions in India). Bank account verification. Selfie/live photo for facial verification.

For corporate/institutional accounts, additional documentation is required: Certificate of Incorporation. Memorandum and Articles of Association. Board Resolution. KYC of authorized signatories and beneficial owners (25%+ shareholding).

3. Customer Due Diligence (CDD)

We perform risk-based Customer Due Diligence for all users. This includes: Identity verification at onboarding. Risk profiling based on transaction patterns, geography, and product usage. Ongoing monitoring of account activity. Enhanced Due Diligence (EDD) for high-risk customers, including Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, and accounts with unusual transaction patterns.

4. Transaction Monitoring

We employ automated and manual transaction monitoring systems to detect suspicious activities, including: Transactions inconsistent with the customer's known profile. Unusually large or frequent transactions. Structuring of transactions to avoid reporting thresholds. Rapid movement of funds across multiple accounts. Transactions involving high-risk jurisdictions.

5. Suspicious Activity Reporting

If we identify suspicious transactions or activities, we are obligated to file Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit — India (FIU-IND). We also file Cash Transaction Reports (CTRs) for cash transactions exceeding INR 10 lakhs and report cross-border wire transfers exceeding INR 5 lakhs.

We may freeze or close accounts pending investigation without prior notice to the account holder, as required by law.

6. Record Keeping

In compliance with the PMLA, we maintain all KYC records, transaction records, and correspondence for a minimum of 5 years after the business relationship has ended. Records of suspicious transactions and reports filed with FIU-IND are retained for 8 years.

7. Crypto-Specific Provisions

For Zenguard Wallets and any cryptocurrency-related services: We implement Travel Rule compliance for virtual asset transfers. Wallet addresses are screened against known blacklists and sanctions lists. We do not support anonymous or privacy-focused cryptocurrencies. All crypto-to-fiat and fiat-to-crypto conversions require completed KYC. We monitor for suspicious blockchain activity, including mixer/tumbler usage and darknet marketplace interactions.

8. Sanctions Compliance

We screen all users and transactions against applicable sanctions lists, including: United Nations Security Council Sanctions List. OFAC Specially Designated Nationals List. European Union Sanctions List. India's Ministry of Home Affairs banned entities list. We do not provide services to individuals or entities subject to sanctions.

9. Employee Training

All employees handling financial products undergo mandatory AML/KYC training at onboarding and annually thereafter. Training covers identification of suspicious activities, reporting obligations, regulatory updates, and sanctions compliance.

10. Compliance Officer

Our designated AML Compliance Officer oversees the implementation of this policy and can be contacted at: Email: compliance@zenguardhq.com. All concerns regarding potential money laundering or financial crime should be reported to this address.