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AML / CFT / CPF POLICY

Overview

BitGo Technologies India Private Limited ("BitGo") is committed to maintaining the highest standards of Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) compliance. BitGo operates as a Reporting Entity under Section 2(1)(sa) of the Prevention of Money Laundering Act, 2002 (PMLA) and complies with all obligations prescribed by the Financial Intelligence Unit - India (FIU-IND) for Virtual Digital Asset Service Providers (VDASPs).

This summary outlines the key principles and controls adopted by BitGo to prevent misuse of its platform for money laundering, terrorist financing, proliferation financing, or other unlawful activities.

Regulatory Framework

BitGo's AML/CFT/CPF framework is designed in accordance with:

  • The Prevention of Money Laundering Act, 2002 (PMLA);

  • The Prevention of Money-laundering (Maintenance of Records) Rules, 2005

  • The AML/CFT/CPF Guidelines for Reporting Entities Providing Services Related to Virtual Digital Assets , 2026

  • Applicable sanctions, UN Security Council Resolutions (UNSCRs), UAPA, WMDA, OFAC and Indian Government directives

Risk-Based Approach

BitGo follows a risk-based approach to AML/CFT/CPF compliance. Customer due diligence, transaction monitoring, and ongoing controls are applied proportionately based on customer risk profile, transaction behaviour, geographic exposure, product usage, and Virtual Digital Asset (VDA)-related risks.

Customers are categorised intomedium and high risk, and enhanced controls are applied where higher risk is identified. Re-KYC is performed based on the customer's risk rating: annually for medium-risk customers and every six months for high-risk customers. Additionally, a system of periodic review of the risk classification of customers is undertaken once every six months to ensure correct risk categorisation.

Customer Due Diligence (CDD)

BitGo undertakes comprehensive Know Your Customer (KYC) and Know Your Business (KYB) procedures before establishing any business relationship. These include:

  • Identity verification using officially valid documents

  • Verification of beneficial ownership for business entities

  • Sanctions, Politically Exposed Person (PEP), and adverse media screening

  • Collection of source of funds / source of wealth information, where applicable

Accounts are activated only after successful completion of required due diligence.

Enhanced Due Diligence

Enhanced Due Diligence (EDD) is applied for higher-risk customers and transactions, including:

  • Politically Exposed Persons (PEPs) and their close associates;

  • Unusual, complex, or high-value transactions;

  • Exposure to high-risk jurisdictions or unhosted wallets;

  • Clients who are Non-profit organisations; and

  • Clients originating from specific countries designated as tax heavens and those on the FATF grey and black lists

Transaction Monitoring

BitGo maintains a robust risk-based transaction monitoring framework covering all VDA custody and transfer activities. Monitoring includes automated and manual reviews to detect:

  • Unusual or suspicious transaction patterns

  • Transactions inconsistent with a customer's risk profile

  • Structuring or layering activity

  • Sanctions or restricted jurisdiction exposure

  • Proliferation financing indicators

Transactions involving anonymity-enhancing technologies (such as mixers, tumblers, or privacy-focused tokens) are closely monitored, and any attempted, direct or indirect exposure is flagged, investigated, reported and handled in line with the FIU-IND guidelines.

Travel Rule Compliance

BitGo complies with FIU-IND Travel Rule requirements for Virtual Digital Asset transfers. Required originator and beneficiary information is collected, verified, transmitted, and retained in accordance with applicable laws. Transfers lacking required information may be delayed, rejected, suspended, or reported.

Reporting & Cooperation

BitGo reports suspicious or attempted suspicious transactions to FIU-IND within prescribed timelines and strictly adheres to the prohibition on tipping-off. BitGo cooperates fully with FIU-IND, law enforcement agencies, and other competent authorities.

Record Maintenance

Records relating to customer identification, transactions, and Travel Rule information are securely maintained for the period prescribed under law and are made available to authorities upon lawful request.

Governance & Oversight

BitGo has appointed a Designated Director and Principal Officer, as required under PMLA, who are responsible for overseeing AML/CFT/CPF compliance. The policy is approved by the Board of Directors and reviewed periodically.

Commitment

BitGo remains committed to operating in full compliance with Indian AML/CFT/CPF laws and to safeguarding the integrity of the Virtual Digital Asset ecosystem.