Anti-Money Laundering and Counter-Terrorism Financing compliance program for Gletra financial operations, wallet, and marketplace transactions.
Gletra Technologies Pvt. Ltd. is committed to preventing money laundering, terrorist financing, and financial crime across our marketplace, Gletra Wallet, seller settlements, and home service payment systems. This Anti-Money Laundering (AML) Policy establishes our compliance framework aligned with applicable Indian regulations including PMLA guidelines and RBI prepaid payment instrument requirements.
Gletra implements Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), transaction monitoring, suspicious activity reporting, and employee training as core components of our AML program. All users engaging in financial transactions on Gletra are subject to these controls.
This policy applies to buyers, sellers, service providers, and any entity using Gletra payment, wallet, or settlement services. Gletra cooperates fully with the Financial Intelligence Unit — India (FIU-IND) and law enforcement agencies as required by law.
Violations of AML requirements may result in account termination, transaction blocking, asset freezing, and mandatory reporting to authorities without prior user notification where legally prohibited.
Gletra's AML program addresses requirements under:
| User Category | CDD Requirement | Trigger |
|---|---|---|
| All sellers | Full KYC + business verification | Registration |
| Service providers | Individual KYC + background check | Registration |
| Wallet users (withdrawal) | Individual KYC + bank verification | First withdrawal |
| High-value buyers | Enhanced verification | Single transaction > ₹2,00,000 |
| All users | Ongoing monitoring | Continuous automated screening |
EDD applies to: politically exposed persons (PEPs), users from high-risk jurisdictions, accounts with unusual transaction patterns, sellers in high-risk categories (precious metals, electronics), and any account flagged by automated risk scoring.
EDD measures include senior management approval, source of funds documentation, increased monitoring frequency, and transaction limits.
Gletra employs automated systems monitoring for:
Flagged transactions are reviewed by the Compliance Team within 24 hours.
When Gletra identifies suspicious activity that may indicate money laundering or terrorist financing, we file Suspicious Transaction Reports (STRs) with FIU-IND as required by law. Users are not notified of SAR filings where notification is prohibited.
Indicators include: inability to explain source of funds, reluctance to provide KYC documents, transactions with no apparent economic purpose, and use of multiple accounts to obscure identity.
Gletra maintains transaction records, KYC documents, and compliance reports for a minimum of 7 years from account closure or last transaction, whichever is later. Records are stored securely and made available to regulators upon lawful request.
Gletra's Compliance Officer oversees the AML program. All employees handling financial transactions, KYC review, or seller onboarding receive annual AML training. The program is audited internally every 12 months and by external auditors biennially.
All users are screened against UN Security Council sanctions lists, OFAC SDN list, and Indian Ministry of Home Affairs proscribed entity lists at onboarding and continuously thereafter. Matches result in account blocking and regulatory reporting.
Users must provide accurate information and respond to compliance inquiries within 7 days. Non-cooperation results in account restriction. AML inquiries: compliance@gletra.com. Compliance Officer: aml-officer@gletra.com.
This document forms part of the Gletra Terms of Service. Gletra Technologies Pvt. Ltd. reserves the right to update this policy at any time with reasonable notice. Material changes will be communicated via email, in-app notification, or a prominent notice on our platform. Continued use of Gletra after changes constitutes acceptance of the revised policy. For questions, contact legal@gletra.com.