Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy

1. To prevent criminal elements from using companies for Money Laundering and Terrorist funding activities
2. To put in place an effective system and procedure for Customer identification and verifying its/his/her identity, residential address, and other details
3. To enable Company to know and understand its Customers and their financial dealings better which, in turn, would help the Company to manage risks prudently
4. To put in place appropriate controls for detection and reporting of suspicious activities as envisaged under the Anti Money Laundering Act, 2002 and rules thereunder and in accordance with laid down procedures
5. To comply with applicable laws and regulatory guidelines

a) Aadhaar Number

Shall have the meaning assigned to it in clause (a) of section 2 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 (18 of 2016)

b) Act and Rules

Means the Prevention of Money-Laundering Act, 2002 and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, respectively and amendments thereto.

c) Authentication

In the context of Aadhaar authentication, means the process as defined under sub-section (c) of section 2 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016.

d) Board

Means Board of Directors of the Company.

e) Central KYC Records Registry (CKYCR)

Means an entity defined under Rule 2(1)(aa) of the Prevention of Money Laundering Rules, to receive, store, safeguard and retrieve the KYC records in digital form of a customer.

f) Customer

Means a person who is engaged in a financial transaction or activity with a company and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting.

g) Customer Due Diligence (CDD)

Means identifying and verifying the customer and the beneficial owner.

h) Designated Director

Means Managing Director or a whole-time Director, or any director duly authorised by the Board of Directors of the Company to ensure overall compliance with the obligations imposed under chapter IV of the Prevention of Money Laundering Act and the Rules.

i) Digital KYC

Means the capturing live photo of the customer and officially valid document or the proof of possession of Aadhaar, where offline verification cannot be carried out, along with the latitude and longitude of the location where such live photo is being taken by an authorised officer of the RE as per the provisions contained in the Act.

j) Officially Valid Document (OVD)

Means Passport, Driving license, Proof of possession of Aadhaar Number, Voter's Identity Card issued by the Election Commission of India, Job card issued by NREGA duly signed by an officer of the State Government and letter issued by the National Population Register containing details of name and address.

k) Politically Exposed Persons (PEP)

Politically Exposed Persons are Persons who are or have been entrusted with prominent public functions in India or foreign country, e.g., Heads of States or of Governments, senior politicians (eg. MPs, MLAs, MLC, Municipal Counsellors, Panchayat President, Members), senior government/judicial/military officers, senior executives of state-owned corporations, all political party officials, Political Parties, etc.

l) Suspicious Transaction

Means a "transaction", including an attempted transaction, whether or not made in cash, which, to a person acting in good faith: gives rise to a reasonable ground of suspicion that it may involve proceeds of an offense specified in the Schedule to the Act, regardless of the value involved; or appears to be made in circumstances of unusual or unjustified complexity.

m) Video-based Customer Identification Process (V-CIP)

Means a method of customer identification by an official of the company by undertaking seamless, secure, real-time, consent based audio-visual interaction with the customer to obtain identification information including the documents required for CDD purpose.

Key Aspects of CAP:

• No account is opened in anonymous or fictitious/benami names
• Parameters of risk perception are clearly defined in terms of customer profile, social and financial status, nature of business activity, location etc.
• Documentation requirements and other information to be collected in respect of different categories of customers depending on perceived risk
• Circumstances in which a customer is permitted to act on behalf of another person/entity, the arrangements to be made in this regard

CIP Requirements:

• Obtain identification data and verify the identity of the customer
• Verify that the customer is not a person whose name appears in any list of known or suspected terrorists or terrorist organizations
• Record customer identification information and verification procedures followed
• Obtain and verify Beneficial Ownership information
• Perform ongoing Due Diligence

Monitoring includes:

• Scrutiny of transactions having regard to customer's profile
• Periodical review of existing records and keeping them up-to-date
• Identification and reporting of complex, unusually large transactions and all unusual patterns which have no apparent economic or lawful purpose

Records to be maintained include:

• All KYC documents
• Account opening forms
• Transaction records
• Correspondence with customers
• Risk assessment documents
• Suspicious transaction reports

• The Company's KYC/AML policy
• Requirements of relevant laws and regulations
• Methods for identifying suspicious transactions
• Enhanced due diligence procedures for high-risk customers
• Record keeping requirements
• Reporting procedures