Anti-Money Laundering (AML) Policy

Policy Statement

The Company is committed to the highest standards of Anti-Money Laundering (AML) compliance and combating the financing of terrorism (CFT). This policy ensures the Company complies with all applicable AML laws and regulations, including the Prevention of Money Laundering Act (PMLA), 2002, and directives issued by the Reserve Bank of India (RBI) and the Financial Intelligence Unit, India (FIU-IND).

Purpose and Objectives

• Prevent the Company's products and services from being used for money laundering or terrorist financing.
• Establish robust internal controls and reporting mechanisms.
• Ensure all employees are aware of their responsibilities and act in full compliance with applicable regulations.
• Foster a culture of transparency, integrity, and regulatory compliance across all business units.

Regulatory Framework

• Prevention of Money Laundering Act (PMLA), 2002 and Rules thereunder.
• Reserve Bank of India (RBI) Master Direction on KYC, 2016 (as amended).
• Financial Intelligence Unit, India (FIU-IND) reporting requirements.
• Financial Action Task Force (FATF) recommendations.
• UN Security Council (UNSC) Sanctions Lists and related international obligations.

Scope & Applicability

This policy applies to all employees, consultants, contractors, and subsidiaries of the Company It also covers all business lines and services where financial transactions or customer relationships are involved, including third-party providers handling financial or customer data.

Roles and Responsibilities

• Board of Directors: Approve and oversee the AML Policy; ensure compliance culture.
• Principal Officer (PO): Report suspicious transactions to FIU-IND and oversee compliance implementation.
• Compliance Officer: Monitor ongoing transactions, maintain records, and ensure AML training.
• Employees: Identify suspicious activity and promptly escalate concerns.

Customer Due Diligence (CDD)

The Company follows a risk-based approach to identify and verify customers. This includes obtaining and verifying Officially Valid Documents (OVDs) such as PAN, Aadhaar, or Passport, and classifying customers as Low, Medium, or High risk. Enhanced Due Diligence (EDD) is applied for Politically Exposed Persons (PEPs) or foreign clients.

Record Keeping

Customer identification data, account files, and correspondence will be retained for at least 5 years after the business relationship ends. Transaction records will be maintained for 5 years from the date of the transaction and made available for audit or regulatory inspection upon request.

Monitoring of Transactions

The Company shall monitor all transactions to identify suspicious or unusual activities. Automated alerts will be configured for threshold breaches or suspicious transaction patterns, and high-risk accounts will be subject to additional review by the Compliance Department.

Suspicious Transaction Reporting (STR)

Employees must immediately report any suspicious activity to the Principal Officer or Compliance Department. The Principal Officer shall file a Suspicious Transaction Report (STR) or Cash Transaction Report (CTR) with FIU-IND within prescribed timelines. Employees must avoid tipping off customers regarding the filing of such reports.

Training and Awareness

Mandatory AML and CFT training shall be conducted for all employees during onboarding and annually thereafter. Training will cover red-flag indicators, customer identification procedures, and reporting obligations.

Penalties for Non-Compliance

Failure to comply with AML procedures may result in disciplinary action, termination of employment, or regulatory penalties under the PMLA, 2002. The Company reserves the right to report willful violations to the appropriate authorities.

Review and Updates

This policy shall be reviewed annually or whenever there are changes in regulatory or operational requirements. The Compliance Officer will ensure updates are approved by the Board of Directors and communicated to all employees.

Employee Acknowledgment

I acknowledge that I have read and understood the Anti-Money Laundering (AML) Policy of the Company I agree to adhere to the guidelines, participate in AML training, and report any suspicious activity in accordance with this policy.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________