KYC-AML & Transaction Monitoring Policy
LightningNodes Private Limited platform; and any of our associated mobile applications (collectively, the "Platform") are owned, operated and managed by LightningNodes Technologies Private Limited (CIN: U62099GJ2023PTC143842), having its registered office at 1302, Gala Empire, Drive-in-Road, Memnagar, Thaltej Road, Ahmedabad City, Ahmedabad-380054,Gujarat

(hereinafter referred to as ‘the ‘Company’ or ‘Us’ or ‘We’ or ‘Our’, which term shall mean and include our affiliates, group entities, related parties and service providers).




1 a). This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy (“KYC-AML Policy”) sets out the terms regarding identity verification of our users and the procedures followed for early identification and reporting of prohibited/illegal activities which may be committed by using our services. When using the Platform, you must at all times comply with this KYC-AML Policy. . You shall regularly and periodically check this KYC-AML Policy including before you make any transaction on We may also amend or update this KYC-AML Policy (in whole or in part). We shall have no liability or responsibility whatsoever due to any such changes, additions, removals or modifications.

The purpose of this KYC-AML Policy is to:

1. have a system in place for preventing any money laundering financial transaction, terrorism financing and/or any other criminal activities through the Platform;

2. make Our staff and management aware of the meaning of anti-money laundering and counter-terrorism financing and their responsibilities towards the same pursuant PMLA (as defined hereafter) and relevant guidelines; and

3. document requirements under the PMLA and relevant guidelines and also to identify, monitor, report any relevant transaction to appropriate authorities.



Unless the context requires otherwise, following terms shall have meanings ascribed to them as below.


2 a) “Applicable Law” shall mean any applicable statute, law, regulation, ordinance, rule, judgement, order, decree, by-law, approval from the concerned authority, government resolution, order, directive, guideline, policy, requirement, or other governmental restriction in force in India, including without limitation the Prevention of Money Laundering Act 2002 (“PMLA”), the Prevention of Money Laundering (Maintenance of Records) Rules 2005 (“PML Rules”), and various applicable guidelines, rules and regulations of the Computer Emergency Response Team, India, and the Reserve Bank of India or its constituents/payment system providers as applicable, replaced and updated from time to time.

2 b) “Account” means the registered account of the User on .


2 c)  “Cryptos” or “Cryptocurrencies” or “Digital Tokens” or “Virtual Digital Assets” means: means any "virtual digital asset” as defined under the Indian Income Tax Act, 1961, as amended or superseded from time to time


2 d) “Customer Due Diligence (CDD)” means identifying the user and verifying their identity by using a reliable, independent source of documents, data, or information.

2 f) “Officially Valid Document/OVD” means the passport, the driving licence, proof of possession of an Aadhaar Number, ‘Aadhaar Number' means an identification number as defined under the Aadhaar (Targeted Delivery of Financial and other Subsidies, Benefits and Services) Act, 2016 or the voter's identity card issued by the Election Commission of India for the purpose of this definition.


2 g) “Person” means an individual who is above eighteen (18) years of age and an Indian citizen-resident.


2 i) “Suspicious Transaction” means a transaction, including an attempted transaction on , whether or not made using fiat currency, which under our opinion:


i)  give rise to a reasonable ground of suspicion that it may involve proceeds of a crime/an offence, regardless of the value involved; or

ii) appears to be made in circumstances of unusual or unjustified complexity or in contravention to any applicable law; or

iii) appears to have no economic rationale or bona fide purpose; or

iv) gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism. Terrorism includes transactions involving funds suspected to be linked or related to or to be used for terrorism, terrorist acts, or by a terrorist, terrorist organisation, or those who finance or are attempting to finance terrorism.


2 j) “Restricted Jurisdiction” means and includes any jurisdiction other than India; and


2 k)  User or Client or you or your means guests on the Platform or persons using the Platform or availing the Services, directly or indirectly;



3 a) KYC means to ‘Know Your Customer' which is an effective way for an institution to confirm and thereby verify the authenticity of a customer. KYC is for identification of any individual opening and operating an Account and is the guiding principle behind the AML measures.

The Company aims to have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent the  Platform or availing the Services from being used, intentionally or unintentionally, for money laundering purposes. KYC of a User enables the Company to know/ understand its Users and their financial dealings better which in turn will help the Company to manage its risks prudently.

The Users identification should entail verification on the basis of documents and information provided by the Users. The objectives of KYC are as under:


  1. to ensure appropriate Users identification and obtaining sufficient information about to the User in order to identify on whose behalf any transaction is conducted;
  2. verify the User identity using reliable independent source document, data or information;
  3. conduct on-going due diligence and scrutiny of the Account/ User to ensure that the transactions conducted are consistent with the Users’ background/ financial status, its activities and risk profile.
  4. monitor the transactions of a suspicious nature,
  5. satisfy that the proposed Users is not an undischarged insolvent,
  6. minimise frauds,
  7. avoid opening Benami accounts with fictitious names and addresses.

The Company collects the documents and information as per Clause 4 (a) of the User Terms and Conditions.


4 a) Account.
If you choose to register with us , an Account will be created for your use on  for which you must register, open and maintain by providing your details, completing necessary KYC verification requirements as per KYC-AML Policy and executing such undertakings, declarations, agreements etc. as required. Your account shall be activated only upon successful completion of KYC verification requirements.

We are required to collect your personal data for registering and opening your Account and any other document as and when required. You shall ensure that all the information, data, details provided by you are reliable, accurate and complete. Please refer to our
Privacy Policy which explains what information (including sensitive personal data) shall we collect/access and how it is used and shared.


4 b) One account per User or Entity. 
You may only open one account with us unless we have agreed in writing the opening of additional accounts. We may refuse the creation of duplicate accounts for the same user. Where duplicate accounts are detected/identified, we may choose to close or merge duplicate accounts at our sole discretion.


4 c) Who can open an Account? 
You must meet all eligibility criteria and residency requirements to open, maintain and operate your Account as mentioned in Clause 4 of the
User Terms and Conditions.

If we change the eligibility criteria to be registered with  and you no longer comply with the new eligibility criteria, as determined by us in our sole discretion, you accept that we may close your account without any liability for us.

You are solely responsible for ensuring that you are in compliance with all laws, rules and regulations applicable to you. If your right to access  is revoked or use of  is in any way prohibited, in such circumstances, you agree not to use or access  or use  in any way whatsoever.


4 d) Account Opening Procedures. 

User has to provide the following documents for opening the Account. before his/her account can be made operational:


i) Permanent Account Number (PAN) given by Income Tax Authorities,

ii) Documents for identification and proof of residence (Aadhaar/Voter ID/Passport)

iii) in-person verification via live selfie over internet

iv) Account Name, Account Number and IFSC code

v) Six month bank statement (if corporate entity) Please refer  in Clause 4 of the User Terms and Conditions

 The act of providing your Aadhaar ID is voluntary in nature unless mandated under applicable law. User may choose to provide us with an alternative identity proof.

4 e) Please note that post the account opening process, the User would be required to add and verify their bank account for making INR deposits/withdrawals through penny-drop or similar mechanism. The above documents/data would help to establish the identity of the person opening the account but would not be sufficient to prepare a profile of expected activities in the account. Towards this, the following additional details may need to be collected while opening the Account: Politically Exposed Person (PEP)and Trading experience.

5 - CUSTOMER IDENTIFICATION PROCEDURE                                                                                                                                                                                        

5 a) One of the objectives of the KYC and data/information collection norms carried out by us is to ensure appropriate customer identification. Customer Identification means undertaking the process of CDD. We may need to obtain sufficient information necessary to establish, to its satisfaction, the identity of each user, whether regular or occasional and the purpose of the intended nature of the transaction being executed on/ through the

Customer Identification Procedure is carried out at different stages while the accessed by the User and is not limited to instances when:

i) registering an Account,

ii) periodic review of an Account,

iii) any transaction is being executed by the User on the , and/or

iv) periodic checks to investigate authenticity/veracity or the adequacy of the earlier obtained user identification data.



6 a) All transactions executed and/or attempted to be executed on  are regularly monitored through use of software-based algorithms, in order to identify and highlight certain kinds of transaction including without limitation, high value transactions and suspicious/prohibited/illegal transactions as per applicable laws.


6 b) We may, from time to time, undertake necessary investigation in order to identify and examine transactions inconsistent with any User’s risk profile (determined in accordance with verification of the KYC documentation, sophistication, and expected usage pattern.


6 c) We reserve the right to terminate the user account, restrict and/or prevent access to , or report to the appropriate enforcement authorities the activities of any user in respect of suspicious transactions.



7 a) The Company will maintain and preserve the following information and/or data:


7 b) Records of all transactions executed on , for a period of at least 10 (Ten) years from the date of each transaction or for such duration as may be required by the relevant law enforcement agencies and authorities and as per the applicable laws.

7 c) Identification records of users (including but not limited to the identification documents submitted pursuant to this policy, during the subsistence of and for a period of at least 10 (Ten) years from the date of termination of such user account or for such duration as may be required by the relevant law enforcement agencies and authorities and as per the applicable laws.



8 a) You undertake that you will not use  for any illegal/prohibited or unlawful or criminal or anti-national purposes or for financing any such activity under any circumstance whatsoever. You must not let anyone access/use your account or watch you accessing it. You undertake that you shall not impersonate another person or misrepresent itself/himself/herself on  under any circumstance whatsoever.


8 b) All activities under Account shall be deemed as activities carried out by the registered user. You shall only use the account with us to transact on your own account and not on behalf of any other person or entity.

We disclaim any liability arising from any transactions which are not conducted by you or for any obligations of other users to you, any acts or omissions of a third party or user of with whom you choose to deal with.

If you know or suspect that anyone other than you know or has unauthorised access to your account Information or any part of it, you must promptly notify us by sending us an email at [email protected] .

We are not liable for any losses/damages/costs or other consequences of unauthorised/illegal/unwarranted use of your account. You undertake that you will not indulge in any benami transactions that are in violation of applicable laws, this policy or any other policy or instruction issued by  from time to time.

The Regulatory / Statutory Requirements

The Company ensures the availability of a Compliance Officer at all times. The Compliance Officer is responsible for managing the day-to-day operations of this KYC-AML Policy. This includes, but is not limited to:

  1. ensuring compliance of the provisions of the Applicable Laws and relevant guidelines;
  2. act as a central reference point and play and active role in identification & assessment of potential suspicious transactions;
  3. ensure that The Company discharges its legal obligation to report suspicious transactions to concerned authorities; and
  4. ensuring the maintenance of a continually high level of staff AML awareness even between training sessions.

Employee Training

  1. The Company is fully committed to establish appropriate policies and procedures for ensuring effectiveness and compliance with respect to all relevant legal requirements.
  2. We implement ongoing employee training programmes so that the Company’s staff is completely aware of the provisions of the PMLA and guidelines and amendments thereof. These training programmes focus on frontline staff, back office staff, compliance staff, risk management staff and staff dealing with customers. It is very crucial that all those concerned fully understand the rationale behind these guidelines, obligations and requirements, implement them consistently and are sensitive to the risks of their systems being potentially misused by unscrupulous elements, if there is any lapse on their part.

Last updated on: 2 February, 2024