While using Teravent and its associated services, you must read and understand Teravent's applicable policies, including this Know Your Customer (KYC) Policy and the Teravent Privacy Policy.
Effective on April 15, 2025.
This Know Your Customer ("KYC") Policy outlines the procedures Teravent Limited will follow when onboarding and monitoring all clients, partners, and account holders interacting with Teravent platforms, including the Teravent Registry and any associated digital services.
The purpose of this Policy is to reduce the risk of money laundering, terrorist financing, fraud, and other financial crimes, and to ensure Teravent follows high standards of integrity, transparency, and ethical business conduct.
Although Teravent may not, at present, fall squarely under regulated AML/CTF regimes in either India or the United Kingdom, we voluntarily adopt these standards to uphold global best practices. This Policy draws on the UK's Money Laundering Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 (POCA), India's Prevention of Money Laundering Act (PMLA) 2002, and international best practices including FATF Recommendations.
This Policy will be reviewed at least annually by the CEO or designated Head of Policy to ensure continued alignment with applicable law and best practice. Additional interim reviews may occur based on: identified gaps in KYC implementation or monitoring; changes to AML/CTF regulation in India, the UK, or any jurisdiction in which Teravent operates; updates to FATF guidance or global sanctions frameworks; or significant shifts in industry best practice.
Teravent requires all Account Holders to provide and verify specific information during the onboarding process to ensure compliance with AML, CTF, and sanctions regulations. For corporate entities, information collected includes:
- Full legal name, registered office address, and company registration number (Companies House number for UK entities or Corporate Identification Number (CIN) for Indian entities).
- Tax identification details - Unique Taxpayer Reference (UTR) in the UK and Permanent Account Number (PAN) in India where applicable.
- Industry sector and nature of business activities, alongside details of directors and senior management.
- Ultimate Beneficial Ownership (UBO) information in line with UK MLR 2017 and Indian beneficial ownership disclosure regulations. UBOs are defined as individuals with more than 25% ownership or control.
Account Holders are screened against high-risk jurisdictions identified by FATF, and sanctions lists maintained by UK HM Treasury, OFSI, the United Nations, and relevant Indian authorities. Politically Exposed Persons (PEPs) registers are also consulted.
Once onboarded, Teravent maintains secure and accurate KYC records for a minimum of five years from the date of the last transaction, consistent with PMLA (India) and MLR 2017 (UK) requirements.
Teravent conducts continuous monitoring of all transactions and participant activity on its platforms to detect unusual or potentially suspicious behaviour. Where monitoring reveals elevated risk or irregularities, Teravent may temporarily suspend or permanently cease trading with the counterparty, initiate Enhanced Due Diligence (EDD), request further information, or conduct on-site verification where necessary.
- Single transactions that are unusually large relative to the entity's normal activity or industry norms.
- High volume of small-value transactions, or transactions structured just below regulatory thresholds.
- Behaviour inconsistent with the stated business purpose, or requests to route transactions through opaque intermediaries.
- Entities with unnecessarily complex ownership structures designed to obscure control.
Preventing financial crime is a responsibility shared by all employees. It is mandatory for all new employees to review the KYC and AML guidelines as part of their onboarding process, and all employees are required to review updated versions of the Policy annually. Role-specific training is provided to staff whose responsibilities directly involve the Teravent Registry, client onboarding, or transaction monitoring.
All employees must remain vigilant and promptly escalate any high-risk or suspicious activities to their Line Manager and the Compliance Officer. All reports are escalated and documented following Teravent's internal protocols, aligned with UK and Indian regulatory guidance and global best practices.
Teravent maintains comprehensive and secure records to support compliance and audit readiness. All KYC documentation, transaction data, ongoing monitoring logs, and communications regarding risk assessment and escalation are retained for a minimum of five years from the date of the most recent activity - consistent with both UK MLR 2017 and Indian PMLA guidelines.