STABLEX

Alpha Street Technologies Private Limited, operating the Stablex platform (stablex.in), is committed to maintaining the highest standards of compliance with applicable Indian law governing anti-money laundering (AML), combating the financing of terrorism (CFT), and anti-fraud measures. This Policy sets out our obligations, detection mechanisms, and enforcement actions in these areas.

This Policy applies to all users, accounts, and transactions on the Stablex platform and is binding on all staff, officers, and agents of Alpha Street Technologies Private Limited.

Legal Framework: Prevention of Money Laundering Act, 2002 (PMLA) · PMLA Rules, 2005 · FIU-IND Directions · Unlawful Activities (Prevention) Act, 1967 (UAPA) · Information Technology Act, 2000 · FEMA, 1999

1. Policy Commitment & Scope

Stablex operates as a reporting entity under the Prevention of Money Laundering Act, 2002. We are committed to:

• Preventing the platform from being used for money laundering, terrorism financing, or any financial crime
• Maintaining a robust Know Your Customer (KYC) framework as the first line of defence
• Actively monitoring transactions for suspicious patterns and red flags
• Reporting suspicious activity to FIU-IND as required
• Maintaining records as mandated under PMLA and applicable regulations
• Cooperating fully with law enforcement and competent authorities

2. Know Your Customer (KYC) Framework

KYC is the foundation of our AML/CFT programme. No user may deposit, trade, or withdraw without completing full KYC verification.

Customer Identification Programme (CIP)

• Full legal name, date of birth, and photograph
• PAN card (mandatory for all Indian residents)
• Aadhaar-based verification or equivalent government-issued photo ID
• Proof of current residential address
• Verified bank account in the user’s own name
• Liveness check or video KYC where required

Enhanced Due Diligence (EDD)

• Politically Exposed Persons (PEPs)
• High-volume users (₹50,000+ per day or equivalent)
• High-risk users based on geography or behaviour
• Accounts flagged during transaction monitoring

3. Anti-Money Laundering (AML) Measures

Stablex maintains active controls to detect and prevent placement, layering, and integration of illicit funds.

Transaction Monitoring

4. Anti-Terrorism Financing (CFT) Policy

ZERO TOLERANCE: Stablex has an absolute zero-tolerance policy for terrorism financing or support of proscribed organisations.

Sanctions Screening

• UNSC Sanctions Lists
• OFAC SDN List
• MHA list under UAPA
• EU and UK Consolidated Sanctions Lists
• Other international and domestic watchlists

5. Anti-Fraud Policy

Prohibited Fraudulent Activities

• Fake or stolen identity documents
• Use of another person’s PAN or bank account
• Multiple accounts to bypass limits
• Chargeback fraud on INR deposits
• Trade manipulation or collusion
• Exploitation of bugs or vulnerabilities
• Phishing or impersonation of Stablex staff
• Bot usage for unfair trading advantage

6. Roles & Responsibilities

Compliance Officer

• Overseeing implementation of this Policy
• Filing STRs, CTRs, and mandatory reports
• Liaising with law enforcement and regulators
• Maintaining and updating the Policy
• Training staff on AML/CFT obligations

7. Consequences of Policy Violations