KYC Policy

1. Purpose & Scope

This KYC Policy establishes the customer identification, verification, and ongoing due diligence procedures followed by Vinance Coin ("VNC"), operated by Vinance Technologies Pvt Ltd. The policy ensures compliance with the Prevention of Money Laundering Act (PMLA), 2002, RBI Master Directions on KYC, and FATF recommendations for Virtual Asset Service Providers (VASPs).

Scope

• All individual and corporate customers registering on the VNC Platform
• All products: spot trading, P2P trading, futures, copy trading, staking, airdrops, wallet services, fiat on/off ramps
• Both domestic (India) and international customers
• Ongoing monitoring and periodic re-verification

2. Regulatory Requirements

• PMLA (Maintenance of Records) Rules, 2005 — CDD and record-keeping requirements for reporting entities
• RBI Master Directions on KYC (2016, updated 2023) — Customer identification, risk categorization, periodic KYC update
• FIU-IND Guidelines — Reporting entity obligations for VDA service providers
• FATF Recommendation 10 — Customer Due Diligence
• Income Tax Act, Section 206AB/206CCA — PAN verification for TDS compliance
• Digital Personal Data Protection Act (DPDPA), 2023 — Consent and data minimization for KYC data

3. KYC Verification Tiers

VNC implements a tiered KYC system that progressively unlocks platform features and higher transaction limits based on the level of verification completed.

4. Accepted Identity Documents

4.1 Indian Nationals

4.2 Non-Resident / Foreign Nationals

• Passport: Valid passport with at least 6 months validity
• Visa / OCI / PIO Card: Proof of legal stay in India (if applicable)
• Global ID: Government-issued national ID from country of citizenship
• Address Proof: Utility bill, bank statement, or government correspondence (within 3 months)

4.3 Corporate / Institutional

• Certificate of Incorporation / Registration
• Memorandum and Articles of Association (MOA/AOA)
• Board Resolution authorizing account opening and trading
• PAN of the entity
• KYC of authorized signatories and Ultimate Beneficial Owners (UBOs with ≥25% ownership)
• Audited financial statements (latest 2 years)
• GST registration certificate (if applicable)

5. Identity Verification Methods

• Document OCR: Automated extraction and validation of PAN/Aadhaar numbers from uploaded images
• Biometric Matching: Selfie compared against document photographs using facial recognition
• Liveness Detection: Anti-spoofing check to confirm real person (not photo or video of a photo)
• Video KYC: Live video call with compliance officer for Level 2+ verification (as per RBI norms)
• e-KYC via Aadhaar: Consent-based authentication through UIDAI for instant verification
• Database Verification: PAN validated against NSDL/UTIITSL, Aadhaar via DigiLocker

Verification Providers (Configurable)

• Manual review (default)
• SumSub — automated KYC with global coverage
• Jumio — ID verification and liveness
• Onfido — document verification + biometrics
• Shufti Pro — AI-powered identity verification

6. PEP & Sanctions Screening

All customers are screened against global PEP databases and sanctions lists during onboarding and on an ongoing basis:

• Screening against OFAC SDN, UN, EU, UK HMT, FATF sanctions lists
• PEP database screening for domestic and foreign politically exposed persons
• Adverse media screening for links to financial crime, fraud, or terrorism
• Fuzzy name matching with configurable threshold (minimum 85% match score)
• Automatic account blocking on confirmed sanctions match
• Enhanced due diligence for all identified PEPs — source of wealth, senior management approval

7. Enhanced Due Diligence (EDD)

EDD is mandatory in the following scenarios:

• Customer identified as a Politically Exposed Person (PEP) or family/close associate of PEP
• Customer from a FATF grey/blacklist jurisdiction or high-risk country
• Customer with adverse media or criminal record flags
• Transaction volume exceeding ₹50,00,000 per month without clear business justification
• Complex corporate structures with multi-layered ownership, nominee shareholders, or shell entities
• Non-face-to-face onboarding where identity verification is remote-only

EDD Measures

• Source of wealth and source of funds documentation (bank statements, salary slips, ITR)
• Purpose and intended nature of the business relationship
• Senior management approval for account opening/continuation
• Enhanced monitoring — lower transaction thresholds, more frequent reviews
• Identification and verification of Ultimate Beneficial Owners (UBOs)
• Periodic re-assessment (every 6 months instead of annual)

8. Ongoing Due Diligence & Re-verification

• Periodic KYC Update: Every 365 days (configurable per risk level — more frequent for high-risk customers)
• Event-Triggered Re-KYC: Upon change in customer information, unusual transaction patterns, or sanctions list updates
• Transaction Monitoring: Continuous comparison of transaction patterns against customer profile and declared activity
• Dormant Account Reactivation: Full re-KYC required for accounts inactive for more than 90 days
• Document Expiry: Users notified 30 days before document expiry; account restricted if not renewed

9. Non-Acceptance & Rejection

VNC reserves the right to reject or close accounts in the following cases:

• Customer fails to provide adequate identity documentation within the prescribed timeframe
• Documents are found to be forged, altered, or fraudulent
• Customer is a confirmed match on any sanctions list
• Customer refuses to provide source of funds documentation when requested
• Customer is a minor (below 18 years of age)
• Reasonable suspicion of the account being used for money laundering or terrorist financing
• Customer is from a fully blocked jurisdiction (as per our Geo-Blocking policy)

Rejection reasons are documented internally but are not disclosed to the customer where doing so could compromise an investigation or tip off a suspected criminal.

10. Record Keeping

• KYC Documents: Retained for 5 years after account closure (PMLA requirement)
• Verification Logs: All verification attempts, approvals, rejections logged with timestamps and reviewer IDs
• Communication Records: All KYC-related communications with customers retained for 5 years
• Storage: AES-256 encrypted at rest, TLS in transit, access restricted with role-based permissions
• Audit Trail: Immutable log of all KYC actions — who reviewed, what was approved/rejected, when

11. Data Protection & Privacy

KYC data is handled in accordance with our Privacy Policy and applicable data protection laws:

• Consent: Explicit consent obtained before collecting Aadhaar data (UIDAI requirement)
• Purpose Limitation: KYC data used solely for identity verification, compliance, and fraud prevention
• Data Minimization: Only minimum necessary documents are collected per verification tier
• Right to Access: Customers can request copies of their KYC records
• Right to Correction: Customers can update incorrect information via profile settings
• Encryption: PAN and Aadhaar numbers are partially masked in API responses (e.g., ABC****4F, ****1234)
• Access Control: Only authorized compliance staff can access full KYC documents

12. Customer Obligations

• Provide accurate, up-to-date information during registration and KYC verification
• Notify VNC promptly of any changes to personal details (name, address, contact information)
• Cooperate with re-verification requests and provide additional documents when requested
• Not use another person's identity or documents for account registration
• Not maintain multiple accounts (one account per individual/entity)
• Comply with all applicable laws regarding the use of the Platform

13. Contact Information

For KYC-related queries, document submission support, or verification status inquiries:

• 📧 KYC Support: kyc@vncexchange.com
• 📧 Compliance Team: compliance@vncexchange.com
• 📧 General Support: support@vncexchange.com
• 🌐 Dashboard: Check your KYC status anytime at vncexchange.com/dashboard

This policy is reviewed annually and updated to reflect changes in regulatory requirements. Last review: February 2026.