AML CFT

Last Updated: November 30, 2025

Landbitt (the “Company”) is a technology platform and not a bank, investment advisor, broker-dealer, or financial institution. The purchase of Digital Co-ownership Certificates (“Tokens”) on the Landbitt Platform is speculative and involves a high degree of risk. By using the Platform and making an investment, you acknowledge and accept the following :

Landbitt.com is committed to operating in full compliance with all applicable laws and regulations aimed at combating money laundering and the financing of terrorism. This policy is established pursuant to, and in consideration of, the legal principles set forth in Indian law, including the Prevention of Money Laundering Act (PMLA), 2002, and relevant notifications from the Central Board of Direct Taxes (CBDT).

Of specific relevance is the CBDT notification S.O. 2959(E) dated June 30, 2022, which clarifies the tax treatment of Virtual Digital Assets (VDAs), including Non-Fungible Tokens (NFTs). This notification defines a qualifying NFT and explicitly excludes NFTs whose transfer results in the legally enforceable transfer of ownership of an underlying tangible asset.

This policy is designed to address the risks associated with non-fungible digital assets traded on our platform.

Landbitt has a zero-tolerance policy towards money laundering, terrorist financing, and other illicit financial activities. We are committed to implementing a robust risk-based AML/CFT program to:

• Prevent the use of our platform for illegal purposes.
• Protect our users, employees, and the integrity of our platform.
• Comply with all legal and regulatory obligations.
• Foster a culture of compliance and vigilance.

• Virtual Digital Asset (VDA): As defined u/s 2(47A) of the Income-tax Act, 1961, includes any information, code, number, or token generated through cryptographic means, providing a digital representation of value. This includes cryptocurrencies and NFTs.
• Non-Fungible Token (NFT): A unique digital token that qualifies as a VDA, as specified in CBDT notification S.O. 2959(E).
• Money Laundering (ML): The process of disguising the financial proceeds of crime to make them appear legitimate.
• Terrorist Financing (TF): The financing of terrorist acts, terrorists, and terrorist organizations.
• Customer Due Diligence (CDD): The process of identifying and verifying a customer’s identity.
• Enhanced Due Diligence (EDD): Enhanced measures for higher-risk customers and transactions.
• Suspicious Transaction: A transaction, whether completed or attempted, which is inconsistent with a user’s known, legitimate business or personal activities, or which appears unusual for the user.

• Customer Risk: Risks associated with different customer types (e.g., individuals, corporate entities, Politically Exposed Persons – PEPs).
• Geographic Risk: Risks associated with customers or transactions linked to high-risk jurisdictions.
• Product/Service Risk: Risks associated with our offerings, including the trading of cryptocurrencies and the specific class of NFTs we support.
• Channel/Delivery Risk: Risks associated with online, anonymous, and cross-border transactions.

Policies and procedures will be calibrated to mitigate these identified risks.

We will not accept anonymous users or accounts in fictitious names.

B. Standard Customer Due Diligence (CDD):

For all customers, Landbitt will:

• For Individuals: Full legal name, date of birth, government-issued identification number (e.g., Aadhaar, PAN, Passport), and residential address.
• For Legal Entities: Name, registered address, proof of incorporation, and identities of beneficial owners (individuals owning 10% or more) and senior managing officials.

2. Understand the Nature of the Customer’s Business: Understand the intended purpose and
nature of the business relationship.

EDD will be applied to higher-risk categories, including but not limited to:

• PEPs and their close associates..
• Customers from or transacting in high-risk jurisdictions.
• Customers involved in transactions that are complex, unusually large, or exhibit an unusual pattern.
• Entities offering wallet-mixing or anonymizing services. EDD measures may include:
• Obtaining additional information on the source of funds/wealth.
• Requiring approval from senior management to establish or continue the business relationship.
• Conducting enhanced ongoing monitoring.

A. Ongoing Monitoring:
We will implement a system of ongoing transaction monitoring to identify patterns of activity that appear suspicious. This includes both automated systems and manual reviews.

B. Suspicious Activity Reporting:
Where a transaction gives rise to a suspicion of money laundering or terrorist financing, it will be promptly reviewed. If the suspicion cannot be dispelled, a Suspicious Transaction Report (STR) will be filed with the Financial Intelligence Unit-India (FIU-IND) in accordance with the PMLA, 2002.

C. Record Keeping:
All customer identification data, account files, and business correspondence, including the results of any analysis undertaken (e.g., findings of an investigation), will be maintained for a period of five years from the date of transaction or the termination of the business relationship, as required by law.

Given the CBDT notification, Landbitt will implement specific controls for NFT transactions:

• Clarification of Asset Type: We will clearly communicate to users that the NFTs traded on our platform are representational derivative digital assets and may not necessarily confer legally enforceable ownership rights over any underlying tangible asset (like real estate).
• Prohibited NFTs: We will not support the trading of any NFT that claims to represent direct Land Registry driven ownership of a tangible asset where the transfer of the NFT is intended to legally transfer ownership of that physical asset.
• Risk-Based Monitoring of NFT Sales: Large, rapid, or circular purchases/sales of NFTs between related parties (wash trading) will be monitored as potential red flags for market manipulation or money laundering.

Landbitt will screen all customers against relevant national and international sanctions lists (e.g., FATF Grey List and UNSC Consolidated List) and lists of known terrorists and terrorist organizations. No business will be conducted with individuals or entities on such lists.

All relevant employees will receive ongoing training on this AML/CFT policy, their responsibilities, and the latest typologies and trends in money laundering and terrorist financing, particularly in the VDA and NFT space. Training will be conducted at least annually.

A designated Compliance Officer will be appointed. This officer will be responsible for the day-to-day implementation and oversight of this AML/CFT program, including liaison with regulatory authorities and the filing of STRs.