Counter-Terrorist Financing (CTF) Policy

Policy Statement

The Company is committed to preventing its products, services, and operations from being used for financing terrorism. This Counter-Terrorist Financing (CTF) Policy outlines the framework and controls implemented to detect, deter, and report any activities or transactions that may be linked to terrorist organizations or financing activities.

Objectives

• Ensure compliance with applicable anti-terrorism and anti-money laundering (AML/CTF) laws and regulations.
• Establish internal controls and monitoring systems to detect and report suspicious transactions.
• Promote employee awareness and accountability in identifying and mitigating CTF risks.
• Cooperate with law enforcement and regulatory bodies in combating terrorism financing.

Regulatory Framework

• The Prevention of Money Laundering Act (PMLA), 2002 and its amendments.
• The Unlawful Activities (Prevention) Act (UAPA), 1967.
• Reserve Bank of India (RBI) Master Directions on KYC and AML/CTF.
• Financial Intelligence Unit, India (FIU-IND) guidelines.
• United Nations Security Council (UNSC) Sanctions and Counter-Terrorism resolutions.

Scope and Applicability

This policy applies to all employees, business units, and third parties engaged by the Company It covers customer onboarding, transaction monitoring, and reporting obligations under Indian and international CTF regulations.

Key Principles

• Know Your Customer (KYC): Verify customer identity and assess risk profiles to prevent anonymity in financial dealings.
• Risk-Based Approach: Identify high-risk customers, countries, and transactions associated with terrorist activities.
• Ongoing Monitoring: Regularly review transactions and customer behavior for unusual or suspicious activity.
• Reporting Obligations: Promptly report suspicious transactions to FIU-IND through the Principal Officer.

Detection and Reporting of Suspicious Activity

All employees must remain vigilant for signs of potential terrorist financing, such as:

• Transactions inconsistent with a customer's known business activities.
• Use of multiple accounts or intermediaries without clear purpose.
• Frequent transfers to or from high-risk jurisdictions.
• Transactions involving persons or entities listed under the UAPA or UNSC sanctions.

Any suspicious transaction must be immediately escalated to the Compliance Officer or Principal Officer for review and potential reporting to FIU-IND.

Roles and Responsibilities

• Board of Directors: Provide oversight and ensure the CTF framework aligns with regulatory expectations.
• Principal Officer: Serve as the point of contact with FIU-IND and ensure timely filing of reports.
• Compliance Officer: Monitor transaction activity, update CTF controls, and conduct training programs.
• Employees: Adhere to this policy, perform due diligence, and report suspicious activity promptly.

Training and Awareness

Periodic CTF training will be conducted for all employees to strengthen awareness of terrorism financing risks, red-flag indicators, and reporting protocols. Participation in training programs is mandatory for employees in compliance-sensitive roles.

Record Keeping

Records of customer identification, transactions, and CTF-related reports shall be maintained securely for a minimum of five (5) years. All records must be easily retrievable for internal audits and regulatory inspections.

Policy Review

This policy shall be reviewed annually or upon significant changes in regulatory requirements or business operations. All revisions must be approved by the Board of Directors and communicated to relevant personnel.

Employee Acknowledgment

I acknowledge that I have read and understood the Counter-Terrorist Financing (CTF) Policy of the Company I agree to comply with the procedures outlined and actively contribute to the prevention of terrorism financing.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________