Anti-Money-Laundering & KYC Policy

01Purpose & our role

SQARME PRIVATE LIMITED ("SQARME", "we", "us") operates SQARME CMD, a managed software service that automates the merchant's own Binance peer-to-peer (P2P) trading account using the merchant's own Binance API keys.

We want to be precise about what we are and are not:

• SQARME is software only. We do not custody, hold, transmit, exchange or convert any funds, fiat or crypto-assets.
• All trades execute on your own Binance account. Money and assets move between you and your counterparties through Binance, your bank, UPI and other rails — never through us.
• SQARME is not an exchange, broker, wallet, payment system, money-services business or virtual-asset service provider (VASP), and is not a "reporting entity" acting on your behalf. We give no financial, investment or tax advice.

Because of this role, this policy explains the limited checks we perform as part of providing the Service, and — more importantly — sets out the AML/KYC obligations that remain entirely yours. This policy forms part of, and should be read with, our Terms of Service, Privacy Policy and Risk Disclaimer.

02Merchant onboarding checks we perform

Before we provision and activate an engine for a merchant, we carry out a limited review intended to deter abuse of the Service. This is not full regulated KYC and does not replace the KYC you have already completed (and must maintain) on Binance.

Our onboarding checks include:

• Binance-validated identity. You connect the Service using your own Binance API key and secret. We validate the keys live against Binance and rely on the identity and merchant profile that Binance returns for your account — including the KYC name, nickname and KYC status held by Binance. We do not independently re-verify your government identity documents.
• Manual review and approval. Every application is reviewed and approved manually by the SQARME team (over Telegram) before any engine is provisioned or activated.
• Right to request, refuse or suspend. We may, at our discretion, request additional information, decline an application, or suspend or terminate an account where we have concerns about misuse, legality, or non-compliance — without being obliged to give detailed reasons.

For exactly which data we store and how we protect it, see the Privacy Policy.

03Your obligations as the merchant

You are the regulated party operating your own Binance account and your own business. By using the Service you represent, warrant and undertake that, at all times, you:

• are and remain fully KYC-verified on Binance, with valid merchant/P2P access, and that the account and API keys you connect are genuinely your own;
• comply with the Prevention of Money-Laundering Act, 2002 (PMLA) and any obligations applicable to you, including any reporting or registration obligations with the Financial Intelligence Unit – India (FIU-IND);
• comply with all applicable RBI directions, FEMA rules and any other foreign-exchange or banking requirements that apply to your activity;
• comply with all applicable Income-Tax and GST obligations, including reporting and tax on your trading income and gains;
• are solely responsible for your own transactions, your counterparties, and the legality and source of all funds and assets you deal with.

SQARME does not assume, share or discharge any of these obligations on your behalf. Your detailed contractual responsibilities are set out in our Terms of Service.

04Prohibited activity

You must not use the Service, directly or indirectly, in connection with any of the following. This list is illustrative, not exhaustive:

• money laundering, layering, or handling the proceeds of crime in any form;
• terrorist financing or financing of proliferation;
• fraud, deception, phishing, or the use of fake or doctored payment receipts;
• operating or facilitating mule accounts, benami accounts, or accounts held in another person's name to disguise the true owner;
• dealing with persons, entities or jurisdictions that are subject to sanctions or that you are otherwise prohibited from transacting with;
• evading, circumventing or defeating Binance's controls, this policy, or any applicable legal, tax or regulatory control;
• any other activity that is unlawful under the laws of India or any jurisdiction that applies to you.

We may suspend or terminate access immediately, without refund, where we reasonably believe the Service is being used for any prohibited activity.

05Counterparty due diligence

P2P trading exposes you to counterparties you do not control. Counterparties may attempt to defraud you — for example by sending fake or edited payment screenshots, claiming a transfer that never settled, or later reversing or disputing a payment.

• You are responsible for verifying that payment has genuinely and irrevocably settled in your own account before you release any crypto-asset.
• Features such as receipt OCR and engine automation are decision-support tools. They do not guarantee that a payment is genuine, final or non-reversible, and they do not transfer the risk of a bad counterparty to SQARME.
• Receipt OCR and automated forwarding are decision-support only. Where the Service reads a payment receipt and where it automatically forwards that receipt to a counterparty, those steps do not confirm that a payment is genuine, final or non-reversible, and they do not confirm that it came from the correct person. You must still independently confirm that settlement has actually occurred in your own account before you release any crypto-asset.
• Any automated “trust score”, risk flag or block-list the software provides about your counterparties is heuristic decision-support generated from your own trading history to help you spot risk. It is not KYC/AML verification, it certifies no one, and it does not transfer any of your AML/KYC obligations to SQARME.
• You should apply your own judgement and your own counterparty checks, consistent with your obligations on Binance and under law.

For a fuller explanation of these risks, see the Risk Disclaimer.

06Monitoring, suspension & reporting

To protect the integrity of the Service and our other customers, we may:

• monitor use of the Service for signs of abuse, fraud or misuse — within the limits of what our software-only role can technically observe;
• suspend, restrict or terminate an account where we identify, or reasonably suspect, prohibited activity, non-payment, security risk, or a breach of our terms;
• cooperate with lawful requests, summons, notices and orders from competent authorities and courts, and take any action we are legally required to take.

07Sanctions & geography

The Service is offered for lawful use in permitted jurisdictions only. You must not access or use the Service from, or on behalf of any person in, a jurisdiction where such use is prohibited, or where you or your activity are subject to applicable sanctions or restrictions.

It is your responsibility to ensure that your use of the Service, and your underlying P2P activity, is lawful in every jurisdiction that applies to you. We may decline or withdraw the Service where we believe this requirement is not met.

08Record-keeping

We retain account, onboarding and billing records for as long as is necessary to provide the Service and to meet our own legal, tax (including GST) and accounting obligations under applicable Indian law. This includes, for example, your registration and contact details, plan and payment history, and approval records.

We do not retain payment receipt images; only the extracted fields (such as amount, date/time, UTR and status) are kept. How we store, protect, encrypt and dispose of data — including counterparty data your engine processes — is described in detail in the Privacy Policy.

You remain responsible for keeping your own records of your transactions to the extent required by law.

09Cooperation with law enforcement

SQARME will cooperate with valid, lawful requests from law-enforcement agencies, regulators and courts of competent jurisdiction. Where we are legally compelled to do so, we may disclose information in our possession, preserve records, or restrict an account, in accordance with applicable law (including the Information Technology Act, 2000) and our Privacy Policy.

Where the law permits, we will act proportionately and limit any disclosure to what is required by the request.

10Updates & contact

We may update this policy from time to time to reflect changes in our service, our practices, or applicable law. The current version, with its effective date, is always available at this page. Material changes will be reflected by an updated effective date above.

For questions about this policy, or to raise a compliance concern, contact the Grievance Officer, SQARME PRIVATE LIMITED:

Email

grievance@sqarme.com

Phone / WhatsApp

+91 99903 22528 (Mon–Fri, 10 AM – 6 PM IST)

Registered office

SQARME PRIVATE LIMITED, 44 Backary Portion, 2nd Floor, Regal Building, Connaught Place, New Delhi – 110001, India.

CIN

U62013DL2025PTC460672

GSTIN

07ABSCS2589N1Z9

This policy is governed by the laws of India, and the courts of New Delhi have exclusive jurisdiction over any dispute relating to it.