Last updated: 20 May 2026
Enhanced Due Diligence (EDD) Policy
This Policy describes the additional checks Rishi Jagariya Traders Private Limited (operating the CoinConnect brand) and its partners carry out for customers and transactions that present a higher risk of money laundering, terrorist financing, sanctions evasion or fraud, in line with PMLA and FATF guidance.
1. EDD Triggers
- Politically Exposed Persons (PEPs) and their close associates / family.
- Customers from, or with significant activity in, higher-risk jurisdictions.
- Transactions above defined monetary thresholds.
- Unusual transaction patterns inconsistent with the customer's profile.
- Counterparty wallet addresses linked to mixers, darknet markets, sanctioned entities or known fraud.
- Adverse media or sanctions / watchlist matches.
2. Additional Information Collected
- Source of funds and source of wealth declarations with documentary evidence.
- Latest Income Tax Return, bank statements (6–12 months) or salary slips.
- Business / employment details and ownership structure for entities.
- Purpose and intended nature of the business relationship.
- Beneficial-owner identification down to 10% threshold (or lower if required).
3. Senior Management Approval
EDD customers can be onboarded or have transactions cleared only with written approval from the Principal Officer or, for the highest-risk cases, the Designated Director.
4. Enhanced Monitoring
EDD customers are subject to more frequent reviews (at least annually), lower transaction-monitoring thresholds, and ongoing wallet-screening using blockchain analytics tools.
5. Refusal and Exit
Where EDD cannot be satisfactorily completed, or where risk remains unacceptable, we will decline to onboard the prospect or exit the relationship and, if warranted, file an STR with FIU-IND.
6. Records
EDD records are retained for a minimum of five (5) years after the end of the relationship, in line with PMLA.
7. Contact
Questions: support@coinconnect.com