AML & KYC Policy

AML/KYC POLICY

PropaTrade Education Private Limited

CIN: U85500AP2026PTC125374

Last Updated: July 23, 2026

Effective Date: July 23, 2026

ANTI-MONEY LAUNDERING AND KNOW YOUR CUSTOMER POLICY

This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy" or "Policy") is adopted by PropaTrade Education Private Limited, a company incorporated under the Companies Act, 2013, bearing CIN: U85500AP2026PTC125374, having its registered office at Tirupati, India ("PropaTrade," "Company," "we," "us," or "our").

This Policy sets out PropaTrade's voluntary commitment to maintaining robust anti-money laundering (AML), combating the financing of terrorism (CFT), and know your customer (KYC) procedures as a matter of good business practice and corporate governance, notwithstanding PropaTrade's regulatory status as described below.

1. REGULATORY STATUS AND POLICY OBJECTIVES

1.1 Regulatory Clarification

1.1.1 PropaTrade operates a simulated trading education platform and engages individuals as independent contractors for simulated trading research under the Indian Contract Act, 1872.

1.1.2 PropaTrade is NOT a reporting entity under the Prevention of Money Laundering Act, 2002 ("PMLA"). PropaTrade is not a financial institution, banking company, intermediary, or any other entity designated as a "reporting entity" under Section 2(1)(wa) of the PMLA.

1.1.3 PropaTrade does NOT have reporting obligations to the Financial Intelligence Unit – India (FIU-IND). PropaTrade is not required to file Suspicious Transaction Reports (STRs) or Cash Transaction Reports (CTRs) with FIU-IND.

1.1.4 Notwithstanding the above, PropaTrade voluntarily implements AML/KYC procedures as a matter of good corporate governance and to prevent the misuse of its platform and payment systems for illicit purposes.

1.2 Policy Objectives

1.2.1 The objectives of this Policy are to:

(a) Prevent the use of PropaTrade's services and payment infrastructure for money laundering, terrorist financing, tax evasion, or other financial crimes;

(b) Establish and maintain effective KYC procedures to verify the identity of Contractors;

(d) Comply with applicable Indian laws to the extent relevant to PropaTrade's operations;

(e) Maintain appropriate records as a matter of good business practice;

(f) Cooperate with law enforcement authorities when required by law or court order.

2. KYC REQUIREMENTS

2.1 Tiered KYC Approach

2.1.1 PropaTrade implements a tiered KYC approach aligned with the contractor engagement lifecycle:

Evaluation Stage (Basic KYC):

#	Requirement	Purpose	Verification Method
1	Full Legal Name	Identity verification	Self-declaration; cross-verified at Consultant stage
2	Date of Birth	Age verification (18+ mandatory)	Self-declaration
3	Email Address	Communication channel	Email verification
4	Mobile Number	Contact verification	OTP-based verification
5	Country of Residence	Eligibility (UN sanctions screening)	Self-declaration; IP-based verification

PAN verification is NOT required at the Evaluation stage. PAN is required only at the Consultant Account stage.

Consultant Account Stage (Full KYC):

#	Requirement	Purpose	Verification Method
1	PAN Card	Identity and tax identification (Indian tax residents)	Verified through Surepass (PAN verification against NSDL/UTIITSL database)
2	Full Legal Name	Identity verification (must match PAN card)	Cross-verified with PAN database
3	Bank Account Details	Research Stipend disbursement	Bank account verification through Surepass (penny drop verification)
4	Electronic Signature (eSign)	Contractor agreement execution	Aadhaar-based eSign under IT Act Section 3A

2.2 Additional Documentation (Enhanced Due Diligence)

2.2.1 PropaTrade may request additional documentation for enhanced due diligence, including:

(a) Address proof (utility bill, bank statement, or government-issued document);

(b) Photograph;

(d) Declaration of occupation and income;

(e) Any other document as may be required for compliance purposes.

2.3 Global Eligibility

2.3.1 PropaTrade accepts Contractors from any country globally, except residents of nations subject to comprehensive sanctions imposed by the United Nations Security Council. Residents of UN-sanctioned nations are not eligible.

2.3.2 PAN verification is required only for Indian tax residents at the Consultant Account stage for Research Stipend disbursement and TDS compliance purposes.

2.3.3 US citizens and residents are eligible to participate in PropaTrade programs, subject to compliance with all applicable US laws and regulations by the Contractor.

2.4 Aadhaar eSign Clarification

2.4.1 PropaTrade uses Aadhaar-based electronic signature (eSign) under Section 3A of the Information Technology Act, 2000, facilitated through authorised Certifying Authorities.

2.4.2 PropaTrade does NOT perform Aadhaar Authentication or eKYC as defined under the Aadhaar Act, 2016. PropaTrade does NOT access or store Aadhaar numbers.

3. DUE DILIGENCE PROCEDURES

3.1 Standard Due Diligence

3.1.1 Standard due diligence is performed for all Contractors and includes:

(a) Verification of identity using available documentation appropriate to the engagement stage;

(b) Verification of eligibility based on country of residence (UN sanctions screening);

(d) Assessment of the nature and purpose of the contractor engagement.

3.2 Enhanced Due Diligence (EDD)

3.2.1 Enhanced Due Diligence may be performed in the following circumstances:

(a) High-value transactions (cumulative Commitment Fee payments exceeding ₹5,00,000 in a financial year);

(b) Contractors identified as Politically Exposed Persons (PEPs) or their close associates;

(d) Unusual or suspicious transaction patterns;

(e) Cases flagged by internal monitoring systems;

(f) Any other circumstance where PropaTrade determines that enhanced scrutiny is warranted.

3.3 Ongoing Due Diligence

3.3.1 PropaTrade may conduct ongoing due diligence throughout the contractor relationship, including:

(a) Periodic review and update of KYC information;

(b) Monitoring of transactions for consistency with the Contractor's known profile;

4. POLITICALLY EXPOSED PERSONS (PEPs)

4.1 Definition

4.1.1 A Politically Exposed Person (PEP) is an individual who is or has been entrusted with prominent public functions in India or in a foreign country, including but not limited to heads of state, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials.

4.2 PEP Screening

4.2.1 PropaTrade may screen Contractors against PEP databases during the KYC process.

4.2.2 Where a Contractor is identified as a PEP, a family member of a PEP, or a close associate of a PEP, Enhanced Due Diligence shall be applied, including:

(a) Senior management review of the contractor engagement;

(b) Establishing the source of funds;

5. SANCTIONS SCREENING

5.1 PropaTrade screens Contractors against the following sanctions lists:

(a) United Nations Security Council sanctions lists (primary screening criterion for eligibility);

(b) Government of India sanctions lists and restricted entity lists published by the Ministry of Home Affairs and the Ministry of External Affairs;

5.2 Contractors identified on any applicable sanctions list shall be denied access to the Platform, and their accounts shall be terminated immediately.

6. SUSPICIOUS ACTIVITY MONITORING

6.1 Transaction Monitoring

6.1.1 PropaTrade monitors financial transactions (Commitment Fee payments and Research Stipend disbursements) for suspicious patterns, including but not limited to:

(a) Unusually frequent or high-value Commitment Fee payments;

(b) Multiple payments made using different payment methods or accounts within a short period;

(d) Transactions that are inconsistent with the Contractor's known profile;

(e) Rapid or frequent Research Stipend payout requests inconsistent with trading activity;

(f) Attempts to use the Platform for purposes other than simulated trading research.

6.2 Behavioural Monitoring

6.2.1 PropaTrade monitors Contractor behaviour on the Platform for indicators of potential misuse, including:

(a) Use of multiple accounts by the same individual;

(b) Use of VPNs or proxies to obscure geographical location;

(d) Unusual trading patterns that suggest exploitation rather than genuine research activity.

6.3 Internal Procedures

6.3.1 Where PropaTrade identifies a transaction or activity that it suspects may be related to money laundering, terrorist financing, or other illicit activity, PropaTrade shall:

(a) Escalate the matter internally for review by senior management;

(b) Take appropriate action, which may include freezing, restricting, or terminating the Contractor's account;

(d) Preserve all records related to the suspicious activity.

6.3.2 PropaTrade may be unable to provide reasons for actions taken under this Section due to the nature of compliance investigations or applicable legal requirements.

7. RECORD KEEPING

7.1 PropaTrade maintains the following records for a minimum period of five (5) years from the date of the transaction or the date of termination of the contractor relationship, whichever is later:

(a) KYC documents and records of verification;

(b) Records of all financial transactions (Commitment Fee payments received and Research Stipend disbursements made);

(d) Correspondence relating to suspicious activity monitoring;

(e) Internal reports and analyses related to AML/KYC;

(f) Training records.

7.2 Records shall be maintained in a manner that permits their retrieval and production before relevant authorities within a reasonable timeframe.

8. COOPERATION WITH AUTHORITIES

8.1 PropaTrade shall cooperate with law enforcement authorities, courts, and regulatory bodies when required by:

(a) An order of any court of competent jurisdiction;

(b) A lawful request from law enforcement authorities;

8.2 PropaTrade may designate a compliance contact responsible for liaising with authorities on AML/KYC matters.

9. CONTRACTOR COOPERATION

9.1 Contractors are required to cooperate with PropaTrade's KYC and AML procedures, including:

(a) Providing accurate and complete information during application and KYC;

(b) Promptly updating any changes to personal information, particularly PAN, bank details, and contact information;

(d) Not engaging in any activity designed to evade or circumvent AML/KYC controls.

9.2 Failure to cooperate with KYC requirements may result in:

(a) Restriction of Platform access;

(b) Suspension or termination of the contractor engagement;

(d) Reporting to relevant authorities where required by law.

10. ACCOUNT RESTRICTIONS FOR NON-COMPLIANCE

10.1 PropaTrade reserves the right to take the following actions for non-compliance with this Policy:

(a) Reject a Contractor's application;

(b) Suspend or restrict the account pending completion of KYC or investigation;

(d) Terminate the contractor engagement;

(e) Report to law enforcement or regulatory authorities where required by law;

(f) Take any other action deemed necessary.

11. TRAINING AND AWARENESS

11.1 PropaTrade ensures that relevant personnel receive appropriate training on:

(a) AML/KYC procedures and obligations;

(b) Identification and escalation of suspicious activities;

(d) Record keeping requirements;

(e) Consequences of non-compliance.

12. REVIEW AND UPDATE

12.1 This Policy shall be reviewed and updated periodically to reflect changes in applicable law, regulatory guidance, and PropaTrade's business operations.

12.2 Contractors shall be notified of material changes to this Policy through the Platform or via email.

13. CONTACT INFORMATION

For any queries regarding this AML/KYC Policy, please contact:

Grievance Officer / Compliance Contact: Sai Kalyan GP, Director

Email: [email protected]

Address: PropaTrade Education Private Limited, Tirupati, India

PropaTrade Education Private Limited

CIN: U85500AP2026PTC125374 | GSTIN: 37AAQCP9565N1Z7

Registered Office: Tirupati, India

Trading involves risk. Results shown are from a simulated environment and do not guarantee similar outcomes. Individual results may vary significantly.