Anti-Money Laundering (AML) Policy
Effective Date: 01 July 2025
We are fully committed to preventing the misuse of our platform for money laundering, terrorist financing, and other illicit financial activities. This Anti-Money Laundering (AML) Policy has been developed in accordance with the Prevention of Money Laundering Act, 2002 (PMLA) and other applicable Indian laws and guidelines issued by the Reserve Bank of India (RBI) and the Financial Intelligence Unit – India (FIU-IND).
This policy provides a clear framework for identifying, assessing, monitoring, and reporting suspicious activities, while also safeguarding our operations and stakeholders from financial crime risks.
1. Objective of the Policy
This AML Policy is designed to:
Ensure compliance with Indian and international AML laws and regulations
Prevent the use of our services for laundering proceeds of crime
Provide guidelines for Customer Due Diligence (CDD), monitoring, and reporting
Promote a culture of integrity and legal responsibility across all employees, clients, and systems
Align with best practices for FinTech AML compliance in India
2. Scope and Applicability
This policy applies to:
All clients, merchants, partners, and API users operating through our digital platforms
All employees, contractors, and third-party service providers engaged in business operations
All services provided within India, including but not limited to pay-in (collections) and payout (payments)
3. Key AML Measures
a. Customer Due Diligence (CDD)
Know Your Customer (KYC):
Mandatory KYC verification prior to client onboarding
Acceptable documents include PAN, Aadhaar, business registration, bank verification
Verification performed via secure digital KYC APIs or physical documentation when necessary
Enhanced Due Diligence (EDD):
Applied for high-value clients, politically exposed persons (PEPs), or high-risk jurisdictions
Additional documentation and periodic re-verification required
b. Ongoing Transaction Monitoring
Real-time and batch monitoring of financial transactions to detect anomalies
Examples of suspicious activity:
Sudden high-value transactions without economic justification
Structuring transactions to avoid reporting thresholds (e.g., ₹9.99 lakh repeatedly)
Frequent transactions from high-risk regions or sanctioned countries
Both automated red-flag detection systems and manual reviews are used
c. Record Maintenance
All transactional logs, KYC data, audit trails, and suspicious activity reports are retained for a minimum of 5 years
Data is encrypted and stored securely in compliance with the Information Technology Act, 2000
4. Reporting Obligations
a. Suspicious Transaction Reports (STRs)
Any suspected transactions are promptly reported to FIU-IND in accordance with regulatory timelines
Confidentiality is maintained throughout the reporting process
b. Threshold-Based Reporting
Cash transactions or payments above regulatory thresholds (e.g., ₹10 lakh) are reported as per RBI directives
Reports include transaction details, client identification, and purpose
c. Employee Escalation Responsibility
All employees must report suspicious transactions to the designated AML Compliance Officer without delay
Internal escalation ensures timely and accurate external reporting
5. AML Compliance Officer
A senior officer is designated as the AML Compliance Officer, responsible for:
Overseeing the implementation and effectiveness of AML policies
Reviewing and approving STRs before submission
Coordinating with regulatory authorities and undergoing compliance audits
Ensuring internal awareness and employee adherence to AML procedures
6. AML Training and Awareness
Annual AML training programs for all employees and contractors
Specialized sessions for operations, customer service, and risk teams
Training includes:
How to identify suspicious behavior
Reporting obligations under the law
Internal escalation processes and penalties for non-compliance
7. Consequences of Non-Compliance
a. Client Non-Compliance
Clients who:
Fail to complete or falsify KYC documentation
Are found engaging in suspicious or illegal activities
Will face:
Immediate service suspension or account termination
Reporting to regulatory or law enforcement agencies
b. Internal Staff Violations
Employees who breach AML protocols may face:
Disciplinary action including termination
Legal consequences depending on the severity of the violation
8. Policy Review and Updates
This policy is reviewed annually or earlier if:
There are changes in PMLA, RBI AML Guidelines, or international standards
Material changes are made to our products, services, or operational structure
Significant AML-related incidents or compliance issues arise
All updates are published on our official website and communicated to relevant stakeholders.
9. Contact Us
For queries, clarifications, or reporting under this AML Policy, please reach out to:
Level 5, ITPL Main Rd, Devasandra Industrial, Bengaluru, Karnataka 560048
Email: cbdo@dotpe.co
Phone: +447563009191