1. Purpose and Scope

Panchtatvam Global Solutions Private Limited ("Company") is committed to preventing the use of its business for money laundering, terrorist financing, or any other financial crime. This Anti-Money Laundering (AML) Policy sets out the Company's framework for identifying, assessing, and mitigating such risks.

This policy applies to:

• All directors, officers, employees, and contractors of the Company
• All customers, suppliers, and business partners
• All transactions facilitated through the Company's platform and services

2. Legal and Regulatory Framework

Our AML framework is based on the following laws and regulations:

• Prevention of Money Laundering Act, 2002 (PMLA) and PMLA Rules, 2005
• Foreign Exchange Management Act, 1999 (FEMA)
• Reserve Bank of India (RBI) Master Directions on KYC
• Financial Action Task Force (FATF) Recommendations
• Customs Act, 1962 (for trade-based money laundering)
• Income Tax Act, 1961
• Applicable UN Security Council Resolutions on sanctions

3. Definition of Money Laundering

Money laundering is the process of making illegally obtained funds appear legitimate. It typically involves three stages:

• Placement: Introducing illicit funds into the financial system
• Layering: Concealing the trail through complex transactions
• Integration: Reintroducing funds into the legitimate economy

Trade-based money laundering (TBML) — the use of international trade transactions to disguise illicit funds — is a particular risk in our industry, and we maintain heightened vigilance for TBML indicators.

4. Customer Due Diligence (CDD)

We apply Customer Due Diligence measures to all customers and counterparties. CDD includes:

4.1 Standard CDD

• Verification of identity using government-issued documents
• Verification of business registration and ownership structure
• Understanding the nature and purpose of the business relationship
• Screening against sanctions lists and politically exposed persons (PEP) databases

4.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied in higher-risk situations, including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions as identified by FATF
• Transactions involving high-value goods (bullion, precious metals, luxury goods)
• Complex or unusual transaction structures
• Customers who are reluctant to provide required documentation

4.3 Simplified Due Diligence

Simplified due diligence may be applied to low-risk customers and transactions as permitted by applicable regulations.

5. Know Your Customer (KYC)

All customers are required to complete our KYC process before engaging in transactions. Please refer to our KYC Policy for detailed requirements.

6. Suspicious Transaction Monitoring

We monitor transactions for suspicious activity indicators, including but not limited to:

• Transactions inconsistent with the customer's stated business profile
• Unusual payment patterns or methods
• Requests to use third-party payment arrangements without clear justification
• Over- or under-invoicing of goods
• Multiple invoices for the same shipment
• Transactions involving sanctioned countries, entities, or individuals
• Customers who are reluctant to provide information or documentation
• Transactions with no apparent commercial purpose

7. Reporting Obligations

Where we identify suspicious transactions, we are obligated to:

• File a Suspicious Transaction Report (STR) with the Financial Intelligence Unit – India (FIU-IND)
• Maintain records of all STRs filed
• Not tip off the customer that a report has been filed ("tipping off" is a criminal offence)

8. Record Keeping

We maintain records of all customer identification documents, transaction records, and due diligence documentation for a minimum of 5 years from the date of the transaction or the end of the business relationship, whichever is later, as required under PMLA.

9. Sanctions Compliance

We screen all customers, counterparties, and transactions against:

• UN Security Council Consolidated Sanctions List
• OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Sanctions List
• India's designated terrorist lists under UAPA

We will not engage in any transaction that would violate applicable sanctions laws.

10. Employee Training

All employees involved in customer-facing activities and transaction processing receive regular training on AML obligations, red flag indicators, and reporting procedures.

11. Non-Cooperation and Refusal

We reserve the right to refuse to enter into or continue a business relationship, and to decline or reverse a transaction, where:

• A customer fails to complete KYC requirements
• We have reasonable grounds to suspect money laundering or terrorist financing
• The transaction would violate applicable sanctions
• We are required to do so by law or regulatory direction

12. Compliance Officer

13. Policy Review

This policy is reviewed annually and updated as necessary to reflect changes in applicable law, regulatory guidance, and our business activities.