Read our AML & KYC policy carefully.
The Platform is managed and operated by ntsmetrics.com, (hereinafter referred to as “Us”/ “We”/”North Star Metrics”). You accept and understand that this KYC/AML Policy forms a legal and binding agreement between You and North Star Metrics.
You hereby expressly consent to North Star Metrics's continuous monitoring and collecting of information and data of Your activities on our Platform for the purpose of this KYC/AML Policy.
1.1 “Applicable Law” shall mean any applicable statute, law, regulation, ordinance, rule, judgment, order, decree, by-law, approval from the concerned authority, government resolution, order, directive, guideline, policy, requirement, or other governmental restriction in force in India, including without limitation the Prevention of Money Laundering Act 2002 (“PMLA”), the Prevention of Money Laundering (Maintenance of Records) Rules 2005 (“PML Rules”), and various applicable guidelines, rules and regulations of the Computer Emergency Response Team, India, and the Reserve Bank of India or its constituents/payment system providers as applicable, replaced and updated from time to time.
1.2 “Crypto(s)” are virtual digital assets and refer to a cryptographically secured digital representation of value or contractual rights that uses distributed ledger technology and can be transferred, stored or traded electronically using the Platform, including but not limited to bitcoin (BTC) and Ether (ETH).
1.3 “Customer”/“User”/“You” shall mean any Person using/accessing the Platform, for trading in Cryptos.
1.4 “Customer Due Diligence (CDD)” means identifying the customer and verifying their identity by using a reliable, independent source of documents, data, or information.
1.5 “Officially Valid Document/OVD” means the passport, the driving license, proof of possession of an Aadhaar Number, or the voter's identity card issued by the Election Commission of India For the purpose of this definition, ‘Aadhaar Number' means an identification number as defined under the Aadhaar (Targeted Delivery of Financial and other Subsidies, Benefits and Services) Act, 2016.
1.6 “Person” means an individual who is above eighteen (18) years of age and an Indian citizen-resident.
1.7 “Politically Exposed Person” (PEP) is a person who is authorized to perform prominent public functions in a country and includes governors of the state, members of Parliament, military officers, senior government and judicial executives, and heads of local bodies such as municipal corporations, among others. You could also qualify as a PEP if You are a family member or a close relative of such an individual.
1.8 “Suspicious Transaction” means a transaction, including an attempted transaction on the Platform, whether or not made using fiat currency, which under North Star Metrics's sole discretion:
a. give rise to a reasonable ground of suspicion that it may involve proceeds of a crime/an offense, regardless of the value involved; or
b. appears to be made in circumstances of unusual or unjustified complexity or in contravention to any Applicable Law; or
c. appears to have no economic rationale or bona fide purpose; or
d. gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism. Terrorism includes transactions involving funds suspected to be linked or related to or to be used for terrorism, terrorist acts, or by a terrorist, terrorist organization, or those who finance or are attempting to finance terrorism.
1.9 “User Account”/“North Star Metrics Account” shall mean the account created on the Platform through which the User gives instructions for Crypto trading to North Star Metrics.
2. KYC norms
2.1 KYC is the key principle for the identification of any individual opening and operating a User Account. KYC means to ‘Know Your Customer' which is an effective way for an institution to confirm and thereby verify the authenticity of a customer.
2.2 The customer identification should entail verification on the basis of documents and information provided by the customer. The objectives of KYC are as under:
a. To ensure appropriate customer identification,
b. Monitor the transactions of a suspicious nature,
c. Satisfy that the proposed customer is not an undischarged insolvent,
d. Minimize frauds,
e. Avoid opening Benami accounts with fictitious names and addresses, and
f. Weed out undesirable customers.
3. Declarations and Obligations
3.1 Declarations and Disclosure of Information by North Star Metrics
3.1.1 At the time You open a North Star Metrics Account and opt to trade using the Platform, North Star Metrics shall endeavor to identify and verify Your identity. To this effect, North Star Metrics shall collect, and You, as the User shall provide, such documents and data, as requested by North Star Metrics from time to time, to establish and verify the identity of the User / for KYC purposes / to establish and verify the nature of any Suspicious Transaction undertaken on the Platform. All data provided by You for KYC, and customer identification purposes or information on the Suspicious Transaction, shall be true, correct, and up-to-date. North Star Metrics may also use/deploy various software and/or technology or other means, either directly or through its service providers/vendors to establish and verify Your identity and/or the documents/information provided by You. You hereby consent to any such identity verification and KYC checks.
3.1.3 North Star Metrics shall endeavor to verify, either itself or through third-party vendors/service providers, the identity and address of the Users along with the other details and documents submitted by You as may be legally/operationally tenable, including but not limited to using the following methods:
a. PAN/e-PAN verification through government sources; or
b. Masked/Offline Aadhar/Proof of Possession of Aadhar under the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016; or
c. Passport issued under the Passports Act, 1967; or
d. Verification of Voter ID card issued by the Election Commission of India; or
e. Any other document may be required by North Star Metrics from time to time.
You as the User, hereby agree to provide the required documents and information for KYC checks in a timely manner, to create and to continue using the User Account through which the You may give instructions on the Platform.
3.1.4 Your failure as a User, to provide the requisite KYC documents or any identification documents or information as requested by North Star Metrics, may hinder or completely restrict Your use of the Platform and the related services to the User.
3.1.5 You acknowledge and agree that the foregoing list of documentation, verification, and information may be amended by North Star Metrics by way of a notification/intimation, in its sole discretion from time to time, without prior notice.
3.1.6 North Star Metrics reserves the right to examine or request additional information and documents to establish Your identity, and financial position, including sources of Your funds and/or details of the Crypto wallet to which You transferred / from where You received any Crypto, and You shall provide all assistance and cooperation in this regard. If You fail/refuse to comply with the requirements herein, North Star Metrics shall not allow You to create or operate the User Account or carry out Crypto transactions through the Platform.
3.1.7 You agree to provide such additional documents as may be required by North Star Metrics, to ensure compliance with any Applicable Laws or North Star Metrics's policies or a request from any law enforcement authorities immediately, upon receipt of a written request from North Star Metrics.
3.1.8 You further represent, warrant, and agree to provide true, correct, and complete KYC documents, information, and data to North Star Metrics / its delegates/agents/representatives.
3.1.9 Where any transaction or series of transactions undertaken by You are considered as Suspicious Transaction(s) at the sole discretion of North Star Metrics or North Star Metrics reasonably perceives that it is likely to involve proceeds of crime or be used towards any illegal activity, or in an event, if North Star Metrics receives requests/requisitions from any banking partner/ payment system provider or participant/ statutory/ regulatory/ supervisory/ law enforcement authority/enforcement authority (“Authorities”), North Star Metrics shall report all such Suspicious Transaction(s) to the Authorities, as well as use, retain and share Your personal data, documents, and information available with North Star Metrics with the Authorities, and block and freeze Your access to the Platform and Your North Star Metrics Account, and may also increase the future monitoring of such User Account. You as the User, hereby undertake and warrant to provide all assistance, support, and cooperation in this regard including additional documents to verify the identity or the details of the transaction.
3.1.10 North Star Metrics does not allow the opening of or keeping any anonymous User Accounts or creating any accounts under fictitious names or on behalf of other persons whose identity has not been disclosed, or cannot be verified, or more than one (1) account for a person.
3.2 Your Obligations
3.2.1 You agree to use the Platform only for lawful and legal purposes as per this KYC/AML Policy, as amended from time to time, and the Applicable Laws.
3.2.2 You shall not use the Platform for any illegal or unlawful or criminal or anti-national purposes or for financing any such activity under any circumstance whatsoever.
3.2.3 You shall not impersonate another person or misrepresent Yourself on the Platform Under any circumstance whatsoever.
3.2.4 You undertake and warrant not to indulge in any Benami transactions or any transactions that are in violation of any Applicable Laws, this Policy or any other policy or instruction as issued by North Star Metrics from time to time.
4. Customer Acceptance Policy (CAP)
4.1 Account Opening Procedures
4.1.1 Any Indian national resident can open a North Star Metrics Account with North Star Metrics and such North Star Metrics Account can only be accessed within the geographical territory and jurisdiction of India.
4.1.2 The User has to provide the following before his/ her North Star Metrics Account can be made operational:
a. Permanent Account Number (PAN) given by Income Tax Authorities,
b. Documents for identification and proof of residence (Aadhaar/Voter ID/Passport),
c. Live selfie from the camera.
Please note that post the account opening process, the User would be required to add and verify their bank account/UPI ID for making INR deposits/withdrawals.
4.1.3 The above documents/data would help to establish the identity of the person opening the account but would not be sufficient to prepare a profile of expected activities in the North Star Metrics Account. Towards this, the following additional details may need to be collected while opening the North Star Metrics Account:
a. Annual income, b. Occupation, c. If Politically Exposed Person (PEP), d. Trading experience, and e. Marital status.
4.1.4 The User's North Star Metrics Account will only be made operational for the User to avail of our services when such documents, information as mentioned above, or any other additional information as requested by North Star Metrics has been verified as per the satisfaction of North Star Metrics.
4.2 North Star Metrics shall maintain an audit trail of any upload/modification/download
4.3 Safeguard measures taken by North Star Metrics
4.3.1 Before registering a North Star Metrics Account, We on a reasonable efforts basis ensure that:
a. Such North Star Metrics Account is not under an anonymous or fictitious/benami name.
b. No North Star Metrics Account is made operational and the User is not allowed to avail our services in an event if we are unable to apply appropriate CDD measures, i.e. verify the User identity and/or obtain documents required or non-reliability of the documents/information furnished to North Star Metrics, either due to non-cooperation of the User or non-reliability of the documents/information furnished by the customer.
c. No account is opened or trades are executed without following CDD procedure.
d. The User's identity does not match with any person with a known criminal background or having any association/ relationship with banned entities/ persons such as individual terrorists or terrorist organizations etc.
4.3.2 Users are not permitted to act on behalf of another User and can only transact on North Star Metrics's platform on their own account, with their own funds, and for their own benefit. Users are not permitted to open any of the following:
a. an anonymous account;
b. an account under a fictitious name; or
c. an account on behalf of other persons whose identity is undisclosed or unverifiable.
4.3.3 North Star Metrics at its sole discretion may review the User's North Star Metrics Account and transactions for any Suspicious Transactions or in an event if North Star Metrics receives a request for the same from Authorities and based on North Star Metrics's judgment or instruction from Authorities such North Star Metrics Account may be suspended, frozen, blocked, disabled, or terminated.
4.3.4 North Star Metrics may, in its sole discretion, refuse to open any new accounts, suspend or terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Platform if it is unable to ensure compliance with any of the aforementioned conditions, either due to non-cooperation by the User or due to the details provided by the User being found enlisted on any Sanctions Lists or unreliable or unverifiable to North Star Metrics's satisfaction.
4.3.5 Requirements/obligations under international agreements & Communication from international agencies: North Star Metrics shall reasonably ensure that it does not have any account in the name of individuals appearing in the lists of individuals and entities, suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC), other watchlists and sanctions lists.
5. Customer Identification Procedure (CIP)
One of the objectives of the “KYC” and data/information collection norms being carried out by North Star Metrics is to ensure appropriate Customer Identification. Customer Identification means undertaking the process of CDD. North Star Metrics may need to obtain sufficient information necessary to establish, to its satisfaction, the identity of each User, whether regular or occasional and the purpose of the intended nature of the transaction being executed on/ through the Platform.
Customer Identification Procedure is carried out at different stages while the Platform is accessed by the User and is not limited to instances when:
a. Registering a North Star Metrics Account,
b. Periodic review of a North Star Metrics Account,
c. Any transaction is being executed by the User on the Platform, and/or
d. North Star Metrics has a doubt about the authenticity/veracity or the adequacy of the earlier obtained User Identification data.
5.1 User identification
Identification of a User is an important prerequisite for registering and opening a North Star Metrics Account. No North Star Metrics Account is allowed on the Platform unless verification and due diligence of said User is successfully completed by North Star Metrics.
5.1.1 What is Identity?
Identity generally means a set of attributes that together uniquely identify a ‘natural’ or a ‘legal’ person. The attributes which help in the unique identity of a ‘natural’ or ‘legal’ person are called identifiers. Identifiers are of two types:
a.) Primary and b.) Secondary.
a. Primary Identifiers: Means and includes the name (in full), Date of Birth, PAN number, and Passport number/Voter Identity Card/Driving License as they help in uniquely establishing the identity of the person.
b. Secondary Identifiers: Includes address, location, Nationality, and other such identification, as they help further refine the identity. User identification does not start and end at the point of application but it is always an ongoing exercise.
5.1.2 What is Identification?
Identification is the act of establishing who a person is:
c. In the context of KYC, identification means establishing who a person purports to be.
d. This is done by recording the information provided by the User covering the elements of his identity (i.e. name, and the address at which they can be located).
e. For undertaking CDD, the following shall be obtained from an individual while establishing a relationship. The features to be verified and the documents to be obtained for establishing the identity of a person are as under:
i. Permanent Account Number (PAN) or the equivalent e-PAN, and
ii. Certified copy of an Officially Valid Document (OVD) or the equivalent e-document thereof containing the details of identity and address. “Officially Valid Document” (OVD) means i) the Passport, ii) Aadhaar card, iii) the Voter's Identity Card, iv) or any other document as required by North Star Metrics from time to time and in its sole discretion.
5.1.3 What is Verification?Verification of identity is the process of proving whether a person actually is who they claim to be. In the context of KYC, verification is the process of seeking satisfactory evidence of the identity of those with whom North Star Metrics does business. This is done by carrying out checks on the correctness of the information provided by the customer.
5.1.4 Process of video-KYCIn scenarios where the document provided by a User has some issues and cannot be validated using the automated solutions North Star Metrics has in place, a video-KYC might be required from the User to validate the identity and authenticity of the document/ information submitted by them. We would also use the video-KYC process while performing enhanced due diligence wherever required.
5.1.5 Periodic updation of KYCPeriodic updation of KYC of Users is performed at such intervals of time and using such processes/documents as decided by North Star Metrics at its sole discretion. A risk-based approach for periodic updation of KYC is to be adopted: f. No change in KYC information: In case of no change in the KYC information, a self-declaration from the User in this regard shall be obtained through User's email id and mobile number registered with North Star Metrics. g. Change in address: In case of a change only in the address details of the User, a self-declaration of the new address may be obtained from the User through the User's email id and mobile number registered with North Star Metrics along with valid proof to be submitted by the User for the change in such address. h. Change in contact information like a phone number or email address: In case of a change in the contact details of the User, the User can reach out to North Star Metrics to get the details updated, along with valid proof of change and demonstrating ownership of the North Star Metrics Account for which the details are to be updated.
5.2 Types of CDD
There are 2 types of Customer Due Diligence (CDD) that can be used in accordance with the risk category of the customer.
5.2.1 Basic Due Diligence means the collection and verification of identity proof, address proof, and a photograph to establish the identity of the User. This is done on the basis of the documents and information submitted by the User.
5.2.1 Enhanced Due Diligence (EDD) means additional diligence measures undertaken over and above the Basic Due Diligence. Steps under EDD shall include but will not be limited to checking if a User falls under the category of Politically Exposed Persons (PEPs), or is associated with any terrorist activities/groups, monitoring the account activity of such users, etc.
North Star Metrics shall conduct Basic Due Diligence, EDD, or any other due diligence activity or measures which under its sole discretion and/ or under Applicable Laws is required for a User registering or using the Platform.
6. Anti-Money Laundering Standards
North Star Metrics is vigilant in the fight against money laundering and under its best judgment implements processes not allowing any person to use the Platform for money laundering and terrorist financing activities.
6.1 Steps taken to prevent Money-Laundering activities and Terrorist Financing
North Star Metrics has implemented steps as described below with an objective to prevent any money laundering activity and/or terrorist financing on the Platform. Such processes being implemented are exhaustive in nature and are subject to change as required under any Applicable Law and/or as per North Star Metrics's sole discretion.
North Star Metrics may perform ongoing monitoring for the below sample scenarios:
a. Deposits from multiple bank accounts or UPI IDs
b. Withdrawals to multiple bank accounts
c. Very frequent deposits or withdrawals
d. Deposits and withdrawals without performing any trades
7. Monitoring of Transactions - On-going Due Diligence
7.1 Monitoring and supervision of the North Star Metrics Account in the event of any suspicious activity is detected is essential.
7.2 As part of the ongoing due diligence process, North Star Metrics may monitor North Star Metrics Account activities undertaken by a User through the Platform to reasonably ensure that they are consistent with their knowledge of the User, its risk profile, and where necessary, the source of funds.
7.3 When there are suspicions of money laundering or financing of activities relating to terrorism or where there are doubts about the adequacy or veracity of previously obtained User identification data, North Star Metrics may review the due diligence measures including reverifying Your identity, and may request additional information. You, the User hereby confirm that You shall provide all such information, as and when requested by North Star Metrics.
7.4 Monitoring customer activity and transactions throughout the relationship helps us to know their customers, assess risk, and provide assurance that North Star Metrics is not being used for the purposes of financial crime. However, the extent of monitoring shall be aligned with the risk category of the customer. High-risk accounts have to be subjected to more intensified monitoring.
7.5 Without prejudice to the generality of factors that call for close monitoring following types of transactions shall necessarily be monitored, whereas on basis of monitoring activities conducted by North Star Metrics as described under this Policy, any North Star Metrics Account may be frozen or suspended / User access might be blocked or terminated as decided by North Star Metrics under its sole discretion:
a. Very high account turnover inconsistent with the size of the balance maintained.
b. Special attention should be paid to the complex, unusually large transactions and all unusual patterns, inconsistent with the normal and expected activity of the User, which have no apparent economic rationale or lawful purpose.
7.6 North Star Metrics may enable alerts when the transactions are inconsistent with risk categorization and the updated profile of the customers shall be put into use as a part of effective identification and reporting of suspicious transactions.
8. Contact & Compliance Officer
8.1 North Star Metrics has appointed a ‘Principal / Compliance Officer’ to ensure overall compliance with the obligations imposed herein and under any Applicable Laws. At present, our Compliance Officer is Mr. Sujit Das who can be reached at email@example.com.
8.2 In case of any complaint or queries with respect to this Policy or to report any suspicious or illegal activity of a User within Your knowledge, You may write to us at firstname.lastname@example.org.
9. Risk Management by Periodic Review
9.1 Identification of a customer is an important prerequisite for opening an account. Non-adherence to this may lead to risks e.g. frauds, money laundering, inadvertent overdrafts, and Benami/fictitious accounts.
9.2 Non-compliance of monitoring of the transactions exceeding the threshold limit and non-recording of the transactions may result in intentional splitting/structuring of transactions to evade taxes, money laundering, and financing of terrorist activities.
9.3 North Star Metrics may carry out ‘Money Laundering (ML) and Terrorist Financing (‘TF') Risk Assessment' periodically to identify, assess and take effective measures to mitigate money laundering and terrorist financing risk for Users, countries or geographic areas, and products, services, transactions, or delivery channels that is consistent with any national risk assessment conducted by a body or authority duly notified by the Central Government.
9.4 North Star Metrics, as a best industry practice and under its sole discretion categorizes the Users under low, medium, and high-risk categories, based on the assessment and risk perception. North Star Metrics should prepare the profile of the customer which should contain information relating to the customer's identity, social/financial status, nature of the business activity, and risk categorization shall be undertaken based on these parameters.
9.5 All User Accounts should be periodically updated based on their risk category. Unless otherwise required under this Policy or under Applicable Law or for complying with any request of Authorities, at present, the periodicity of such updation should not be less than once in five (5) years in the case of low-risk category customers, and not less than once in two (2) years in case of high and medium risk categories. North Star Metrics reserves the right to change the above periodicity at any time and from time to time in its sole discretion.
9.7 North Star Metrics may take a view on risk categorization of each customer into low, medium, and high-risk categories depending on their experience, expertise in profiling of the customer based on their understanding, judgment, assessment, and risk perception of the customer and not merely based on any group or class they belong to.
9.8 The risk assessment carried out by North Star Metrics shall:
a. be reasonably documented;
b. consider all the relevant risk factors before determining the level of overall risk and the appropriate level and type of mitigation to be applied;
c. be kept up to date; and
d. be available to competent authorities and self-regulating bodies/Authorities, if and as required under Applicable Laws.
10. Internal Controls
10.1 Preservation of Record / Record Management
10.1.1 North Star Metrics shall reasonably ensure that all information received for the purpose of identification or due diligence is used by it in accordance with North Star Metrics's terms and conditions applicable. North Star Metrics shall also take necessary reasonable steps for maintenance, preservation, and reporting of User information per the internal policies and standard operating procedures of North Star Metrics.
10.1.2 In addition, the confidentiality, security, and protection against access, use, and disclosure (including publication or display) of all information of a User, collected or created by North Star Metrics shall be kept in accordance with Applicable Law.
10.1.3 North Star Metrics shall collect and maintain records, in the form of books or stored in a computer, of Your identity proof along with all documents and information provided by You and of all the transactions undertaken by You on the Platform, as required under the Applicable Laws/good industry practices.
10.1.4 North Star Metrics shall maintain and report to Authorities the records of:
a. the KYC details, documents, and data of all Users who open a User Account on the Platform;
b. the KYC details, documents, and data of all Users who undertake a transaction on the Platform; or
c. Your transactions on the Platform.
10.2 North Star Metrics shall make available the identification records and transaction data to the authorities upon request.
10.3 If North Star Metrics:
a. suspects transactions of being involved in ML or TF, or
b. doubts the adequacy or veracity of previously obtained identification data,
necessary steps will be taken to review the due diligence measures undertaken by North Star Metrics or the information obtained (on the purpose and intended nature of the business relationship) from the User.
10.4 Hiring of Employees
Adequate screening mechanisms as an integral part of their personnel recruitment/hiring process shall be put in place to ensure high standards and equal and fair opportunity when hiring employees.
10.5 Employee training
10.5.1 Employee training programs are put in place so that the members of concerned staff are adequately trained in KYC/AML/CFT policy. The focus of the training could be different for frontline staff, compliance staff, risk management staff, Audit staff, and staff dealing with new customers. The front desk staff is trained to handle issues arising from a lack of customer education. Proper staffing of the audit function with persons adequately trained and well-versed in KYC/AML/CFT policies, regulations, and related issues also ensure its proper implementation. e-Learning modules have been introduced for increased awareness.
10.5.2 North Star Metrics may put in place policies and FAQs to answer any queries or questions of the Users and satisfy them while seeking information in furtherance of the Policy.
10.5.3 We have taken every effort to ensure that this Policy adheres to the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by North Star Metrics through the Platform.
Annex 1 – KYC-AML Standards – Dos and Don'ts
1. Before opening any new account, it is ensured that the prospective account opener‘s identity does not match with any person with a known criminal background, and their name does not appear in the list of terrorist individuals/ organizations banned by the UN Security Council Sanction Committee as circulated by RBI.
2. All the copies of supporting documents given by the customer must be photos/images of the original documents.
3. PAN shall be verified from the verification facility of the issuing authority. 4. All transactions of suspicious nature should be monitored.
5. High-risk accounts are subject to intensive monitoring and special attention is paid to all complex, usually large transactions which have no economical/lawful purpose.
6. Based on the risk perception, every new customer should be categorized into low, medium or high risk for monitoring purposes. Risk profiles of customers should be reviewed periodically.
7. Periodical updation of KYC information of every customer (including photographs) should be done.
1. Do not open any account in anonymous or fictitious / benami name(s).
2. Do not open an account where North Star Metrics is unable to apply appropriate Customer Due Diligence (CDD) measures either due to non-cooperation of the customer or non-reliability of the documents/information furnished by the customer.
3. Do not open any account without PAN and an ID document (Passport/Aadhaar/Voter ID card).
4. Services should not be denied to the general public, especially to those who are financially or socially disadvantaged.
5. In the accounts where suspicious activity has been observed, no restrictions are put on the operations and it is ensured that there is no tipping off to the customers.
Annex 2 - Sample suspicious activities
1. False Identity: Identification documents were found to be forged during the customer verification process.
2. Account of persons under investigation: The customer was reported in the media for being under investigation.
3. Account of wanted criminal: The name of the account holder and additional criteria (Date of birth/Father‘s name/Nationality) was the same as a person on the watch list of UN, Interpol, etc.
4. The account used for cybercrime: Complaints of cybercrime were received against a customer.
5. The account used for referral fraud: The customer was found to be creating fake accounts to obtain referral awards for them.
6. Unexplained activity in account inconsistent with the expected activity: Transactions in account inconsistent with what would be expected from expected activity.