Fincrypt LLP (Operating under brand name: Stable Pay)

1. Purpose & Objective

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (“Policy”) establishes the internal framework adopted by Fincrypt LLP (“Stable Pay”) to:

• Prevent money laundering, terrorist financing, proliferation financing, and related financial crimes
• Ensure compliance with the Prevention of Money Laundering Act, 2002 (PMLA) and its allied rules
• Adhere to guidelines issued by FIU-IND, RBI advisories, and other applicable Indian laws
• Maintain transparency, traceability, and accountability in Virtual Digital Asset (VDA) and fiat transactions

Stable Pay follows a risk-based, technology-driven, and compliance-first approach to AML/CFT obligations.

2. Regulatory Framework & Applicability

This Policy is framed in accordance with:

• Prevention of Money Laundering Act, 2002
• PMLA (Maintenance of Records) Rules, 2005
• FIU-IND guidelines for Reporting Entities (VDA Service Providers)
• RBI advisories applicable to payment and financial intermediaries
• FATF Recommendations (to the extent applicable)

Applicability

This Policy applies to:

• All customers (individuals, merchants, corporates, and institutions)