Anti-Money Laundering (AML) & Know-Your-Customer (KYC) Policy

1. Introduction

At 11Exch, we uphold the highest standards of integrity, transparency, and compliance.
This AML & KYC Policy outlines our legal responsibilities and preventive measures against money laundering, fraud, and misuse of digital identities.

We comply with:

The Prevention of Money Laundering Act (PMLA), 2002
The Financial Action Task Force (FATF) Recommendations
The Reserve Bank of India (RBI) Master Directions on KYC
The Digital Personal Data Protection Act, 2023 (DPDP)
Information Technology Act, 2000 (IT Act)

Together, these ensure that all financial and identity-related operations within the 11Exch ecosystem remain lawful, ethical, and auditable.

2. Objective

The primary objectives of this policy are to:

Prevent money laundering and terrorist financing.
Verify user and affiliate identities through KYC.
Detect and report suspicious financial or promotional activity.
Maintain transparent financial records.
Comply with global AML and data privacy frameworks.

This policy works hand-in-hand with our Compliance & Licensing, Legal Policy, and Data Protection Policy.

3. Scope

This policy applies to:

All users registering for IDs or affiliate accounts.
All affiliates, advertisers, and partners working with 11Exch.
All employees handling payments, data, or verification.

It extends to any transaction or campaign that directly or indirectly involves monetary exchange through 11Exch.

4. Legal Foundation

11Exch operates as a digital intermediary, not a gaming operator.
Our AML and KYC framework aligns with Indian financial laws to ensure:

Proper user identification and verification,
Record retention for five years post-transaction,
Reporting of suspicious transactions to authorities when required.

All compliance records are documented in the Transparency Report.

5. KYC Verification Procedure

To ensure genuine participation and prevent misuse, every user or affiliate must complete Know-Your-Customer (KYC) verification before activation.

We collect:

Full name and date of birth
Government-issued ID proof (Aadhaar, PAN, Passport, or Voter ID)
Proof of address (Utility Bill, Driving License, or Bank Statement)
Selfie or live verification for identity match

Verification data is encrypted and processed under the Data Protection Policy and Security Policy.

6. AML Control Mechanisms

Our AML framework consists of the following preventive layers:

Control Layer	Description	Policy Reference
User Due Diligence (UDD)	Screening of every user or affiliate before approval.	Compliance & Licensing
Enhanced Due Diligence (EDD)	Extra verification for high-value or international users.	Compliance & Security
Transaction Monitoring	Real-time analysis of financial patterns to detect anomalies.	Transparency Report
Suspicious Activity Reporting (SAR)	Filing reports for fraudulent or high-risk activity.	Grievance Redressal
Record Retention	All KYC and AML records stored securely for audit.	Security Policy

7. Red-Flag Indicators

11Exch actively monitors for red-flag behaviors such as:

Frequent failed payment attempts or reversals.
Unusual commission withdrawals or bulk ID purchases.
Accounts using proxy IPs or mismatched KYC details.
Affiliates with unverifiable traffic sources.
Rapid deposits followed by inactivity or sudden withdrawal requests.

When such activities are detected, the Compliance Department investigates and may suspend or terminate the account immediately.

8. Affiliate & Partner Due Diligence

Before any affiliate or advertiser partnership is activated:

Full KYC documentation and licensing proof are required.
Business registration and domain validation are verified.
Financial source and transaction intent are reviewed.

Affiliates failing to meet standards under the Affiliate Disclosure or Advertising & Sponsorship policies are rejected or delisted.

9. Record-Keeping & Audit

We maintain AML and KYC records securely for at least five (5) years after account termination.
Records include:

Identity documents and verification logs.
Affiliate contracts and payment receipts.
Suspicious Activity Reports (SARs) and resolution summaries.

All documentation is encrypted and available for regulatory inspection under the Transparency Report.

10. Reporting Suspicious Activity

If illegal or suspicious activity is identified, 11Exch may:

Freeze affected accounts.
File an internal SAR (Suspicious Activity Report).
Notify authorities under applicable AML laws.
Cooperate fully with law enforcement agencies.

All reports are handled confidentially under the User Trust & Conduct and Grievance Redressal policies.

11. Roles & Responsibilities

Compliance Officer

Monitors AML & KYC adherence.
Approves or rejects high-risk accounts.
Files reports and maintains audit logs.

Employees

Follow KYC procedures during onboarding.
Report anomalies immediately.

Users & Affiliates

Provide accurate and authentic documentation.
Avoid third-party transactions or misleading representations.

12. International Compliance

For global affiliates and users outside India, 11Exch ensures cross-border compliance with:

FATF and OECD anti-money laundering standards.
EU AMLD6 for European entities.
GDPR data privacy provisions during verification.

All data transfers are secured and documented under the Data Protection Policy.

13. Confidentiality & Data Protection

All verification and AML data are encrypted using AES-256 and stored in secure data centers.
Only authorized compliance officers have access.
Data is never shared externally without legal justification or user consent, as mandated by the Privacy Policy.

14. Penalties for Non-Compliance

11Exch may impose one or more of the following actions against users or affiliates who violate AML or KYC rules:

Immediate account suspension or termination.
Forfeiture of affiliate commissions.
Blacklisting of partner domains.
Reporting to law enforcement or financial intelligence units.

Repeat offenders are permanently barred from future collaborations under the Compliance & Licensing framework.

15. Training & Awareness

All employees and affiliates undergo periodic AML training that includes:

Risk identification and red-flag detection.
Documentation of verification procedures.
Reporting obligations and escalation paths.
Ethical standards and anti-fraud conduct.

Refresher programs occur every six months under the Compliance & Security policy.

16. Review & Updates

This AML & KYC Policy is reviewed annually or whenever regulatory updates occur.
All revisions are recorded under the Corrections & Updates section with the Last Updated date clearly marked.

17. Contact & Reporting

For AML or KYC queries, document submission, or suspicious activity reporting, contact:
📧 compliance@11exch.com
📩 grievance@11exch.com
🌐 Contact Us page

All reports are acknowledged within 48 hours and resolved within 15 working days.

18. Disclaimer

This policy is for compliance and educational purposes only.
11Exch is an affiliate and digital intermediary, not a financial institution or gaming operator.
Users are responsible for ensuring that their participation complies with local laws, as outlined in the Disclaimer and Terms & Conditions.