1Purpose
This Framework sets out how Plaitr, a self-custodial platform whose regulated services are delivered by licensed partner institutions, identifies, assesses, and mitigates financial- crime and operational risk at the enterprise level and for individual Users at the gating layer. Regulated risk management on the underlying rails is performed by Plaitr's licensed partners.
2Enterprise risk assessment
Plaitr conducts an enterprise-wide risk assessment at least annually and on material change (new product, new jurisdiction, new partner, or significant regulatory development). The assessment covers, at a minimum:
Customer risk: industry mix, complexity, PEP exposure
Product risk: stablecoin flows, fiat rails, cross-border payouts, cards (when launched)
Geographic risk: India corridors, UAE, and high-risk jurisdictions
Channel risk: digital-only onboarding, no face-to-face, partner-mediated flows
The output is a risk heatmap with mitigating controls, presented to senior management.
3User-level risk scoring
Each User is scored at onboarding and on refresh across the following factors:
Industry
Country of counterparties and jurisdictions served
Expected monthly volume
Ownership structure and complexity
Screening outcome (sanctions, PEP, adverse media)
Time in business
Scores are aggregated into Low, Medium, or High. High-risk Users require Enhanced Due Diligence and senior sign-off before activation.
4Transaction risk
Regulated transaction risk scoring on the underlying rails is performed by the licensed partner. Plaitr monitors platform-level activity for consistency with the User's declared business profile and escalates concerns to the relevant partner.
5Escalation and review
Material changes in risk profile trigger a reassessment. User risk ratings drive periodic-review cadence per the KYC & Customer Due Diligence Policy.
6Governance
This Framework is owned by the Plaitr Compliance function, approved by senior management, and reviewed at least annually.
7Contact
Questions: compliance@plaitr.com.