Obtaining sufficient information about to the client in order to identify who is the actual beneficial owner of the securities or on whose behalf transaction is conducted.
Verifying the customer’s identity using reliable, independent source document, data or information.
Conducting on-going due diligence and scrutiny of the account/client to ensure that the transaction conducted are consistent with the client’s background/financial status, its activities and risk profile.
The Due Diligence Policy involves the following three specific parameters :
- Customer Acceptance Policy
- Customer Identification Policy
- Highlighting Suspicious Transactions.
|Customer Acceptance Policy|
|CoinGeto shall only accept clients who are able to provide complete and true documents in line with the Customer Identification Policy set out below. Customers who do not supply the essential information required while filling in the form provided for registration shall not be accepted.|
|CoinGeto shall use known publicly and freely available portals to check the authenticity of the identification documents provided by the customers and any persons whose documents appear to be unclear, insufficient, fraudulent or misleading shall not be allowed to register, and if registered, their registration shall be terminated.|
|Any customers whose registration information does not match the documents provided or appears to be fictitious may not be registered, and if registered, their registration shall be terminated.|
|No customers shall be allowed to register in fictitious names or if the customer appears to be an anti social element or is found to have a record of fraud, cheating or forgery.|
|CoinGeto shall not accept any customers who are below 18 years of age or who do not have the mental capacity to enter into legally binding contracts. However it shall not be the responsibility of CoinGeto to determine the legal capacity of the customers and a warranty regarding their legal capacity shall be considered as satisfactory fulfillment of this condition.|
|CoinGeto may ask for additional information at any point of time and if the customer refuses or is unable to provide such additional information then such customer shall not be registered, and if registered, their registration shall be terminated.|
Customer Identification Policy
The objective of the Customer Identification Policy is to have a mechanism in place to establish identity of the client along with firm proof of address to prevent opening of any account which is fictitious / benami / anonymous in nature.
Proof of Identity : All customers shall have to provide scanned copies of atleast one of the documents below as proof of identity. CoinGeto shall accept the following documents as proof of identity :
For Individuals :
- Drivers Licence
- Passport (Front and Last page)
- Voters ID Card (Front and Back)
- Aadhar Card (UID)
- Bank Statement
- PAN Card or a PAN intimation letter which is not more than one year old.
For Corporates :
- Certificate of incorporation and Memorandum & Articles of Association
- Resolution of the Board of Directors to open an account and identification of those who have authority to operate the account.
- Power of Attorney granted to its managers, officers or employees to transact business on its behalf
- PAN number
- Copy of the telephone bill
For Partnership :
- Registration certificate, if registered
- Partnership deed
- Power of Attorney granted to a partner or an employee of the firm to transact business on its behalf
- Any officially valid document identifying the partners and the persons holding the Power of Attorney and their addresses
- Telephone bill in the name of firm/partners
For Trusts and Foundations :
- Certificate of registration, if registered
- Power of Attorney granted to transact business on its behalf
- Any officially valid document to identify the trustees, settlors, beneficiaries and those holding Power of Attorney, founders/managers/ directors and their addresses
- Resolution of the managing body of the foundation/association
- Telephone bill
For Proprietorship Concerns :
- Registration certificate (in the case of a registered concern)
- Certificate/licence issued by the Municipal authorities under Shop & Establishment Act,
- Sales and income tax returns
- CST/VAT certificate
- Certificate/registration document issued by Sales Tax/Service Tax/Professional Tax authorities
- Licence issued by the Registering authority like Certificate of Practice issued by Institute of Chartered Accountants of India, Institute of Cost Accountants of India, Institute of Company Secretaries of India, Indian Medical Council, Food and Drug Control Authorities, registration/licensing document issued in the name of the proprietary concern by the Central Government or State Government Authority/ Department, IEC (Importer Exporter Code) issued to the proprietary concern by the office of DGFT, etc
Proof Of address :
- Driver’s License
- Adhaar Card
- Voter’s Identity Card
- E-Aadhar card
- Utility Bills (Landline, Electricity, Gas) not older than 3 months.
Highlighting Suspicious Transactions
Prohibited Activities :
CoinGeto has a very strict policy of not allowing its services to be knowingly used for any “Prohibited Activities”. No customer shall use the services of CoinGeto for any Prohibited Activities. CoinGeto may conduct manual checks to ensure that not customer is indulging in Prohibited Activities; these checks may in future become automated. The Prohibited Activities for the purposes of this policy shall include :
- Fraud: any act or omission, including a misrepresentation that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.
- Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the action of another party.
- Collusion: arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
- Terrorist financing: provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA of 13 June 2002 on combating terrorism.
- Criminal conduct: conduct, which constitutes an offence in any part of the world or would constitute an offence in any part of the world if it occurred there.
- Money laundering: Money laundering is essentially the process of engaging in such financial transactions that are designed to conceal the true origin of criminally derived proceeds for the purpose of ensuring that such proceeds appear to have been received through legitimate sources/origins. It has been defined under the Prevention of Money Laundering Act, 2002 in the following words:
Whosoever directly or indirectly attempts to indulge or knowingly assists or knowingly is a party or is actually involved in any process or activity connected with the proceeds of crime including its concealment, possession, acquisition or use and projecting or claiming it as untainted property shall be guilty of offence of money-laundering.
In case it comes to the knowledge of CoinGeto or CoinGeto becomes suspicious that any customer is engaging in any Prohibited Activities CoinGeto reserves the right to terminate the account of the customer and prevent such customer from undertaking any further actions on any of CoinGeto’s services, existing or in future. CoinGeto shall further be fully entitled, if it so chooses, to report such suspicious activities to the appropriate authorities.