AML and KYC Policy

Introduction

We are committed to conducting business in accordance with the highest ethical standards and in full compliance with applicable laws and regulations relating to the prevention of money laundering, terrorist financing, fraud, and other financial crimes. This Policy must be read with the Terms & Conditions, Privacy Policy, and Grievance Redressal Policy. Disputes relating to KYC/AML processes are resolved per the dispute resolution clause of the Terms & Conditions (arbitration seated at New Delhi; courts at New Delhi for interim relief and enforcement).

This AML & KYC Policy (“Policy”) outlines our framework to comply with the Prevention of Money Laundering Act, 2002 (PMLA), Rules thereunder, RBI Master Direction – Know Your Customer (KYC), directives from FIU-IND, and global standards such as FATF Recommendations.

1. Objectives of the Policy

1. Prevent use of the Platform for money laundering, terrorist financing, or fraudulent purposes.
2. Ensure compliance with KYC/AML regulations prescribed by RBI, SEBI, UIDAI, FIU-IND, and other authorities.
3. Establish robust procedures for customer due diligence (CDD), record-keeping, monitoring, and reporting.
4. Protect EaseMyDeal, partners, and Users from reputational, operational, legal, and regulatory risks.

2. Scope & Applicability

1. This Policy applies to all Users availing services through EaseMyDeal including mobile/DTH recharge & BBPS bill payments; credit card payment services; gold purchase, storage, redemption, and Gold FD+; gift cards & Gift PPI; loans & credit facilitation; travel bookings; and affiliate/referral products.
2. It covers individual customers, corporate/merchant partners, and agents, intermediaries, and distributors.

3. Regulatory Framework

• PMLA 2002 & Rules thereunder
• RBI Master Direction – KYC (2016, updated periodically)
• FIU-IND guidelines
• UIDAI/Aadhaar eKYC regulations
• DPDP Act 2023
• FATF Recommendations

4. Know Your Customer (KYC) Process

1. Customer Due Diligence (CDD): Full KYC is mandatory for high-value transactions and regulated products (Gift PPI, Gold, Credit facilitation). Minimum KYC may be accepted for low-value services like mobile/DTH recharge, subject to RBI guidelines. Enhanced Due Diligence (EDD) applies to high-risk customers (PEPs, cross-border transactions, high-value gold/gift PPI, unusual patterns), requiring additional verification, source-of-funds documentation, and ongoing monitoring.
2. Acceptable KYC Documents: For individuals: Aadhaar and PAN. For non-individuals (corporates/partnerships): Certificate of Incorporation, PAN, GST Registration, authorized signatory proof, and governing documents (e.g., Partnership Deed, Board Resolution authorizing signatories).
3. Aadhaar-based eKYC / Offline Verification: Where permitted, Aadhaar-based OTP/eSign or offline XML/Paperless KYC may be used. Biometric data will not be stored, in compliance with UIDAI.
4. Periodic KYC Updates: High-risk: every 2 years; Medium-risk: every 8 years; Low-risk: every 10 years.

5. Risk-Based Approach (RBA)

Customers are categorized into Low / Medium / High risk based on:

• Nature of service (e.g., recharge vs. loan/gold/credit card payments)
• Geography (FATF high-risk jurisdictions)
• Transaction behavior (large, unusual, structured patterns)
• Occupation/business profile

EDD applies for high-risk customers (e.g., Politically Exposed Persons, cross-border remittances, unusually large payments, transactions flagged by automated AML monitoring systems, adverse media/sanctions/law-enforcement alerts).

6. Monitoring of Transactions

1. Transactions are monitored through automated systems and manual reviews.
2. Parameters include unusual size/frequency, multiple accounts controlled by the same user, suspicious patterns (structuring/smurfing), transactions inconsistent with profile, mismatched IP/device locations, and multiple login attempts.
3. Red-flag alerts are reviewed by the Chief Compliance & Risk Officer; STRs are filed with FIU-IND as required.

7. Record-Keeping

1. KYC documents, account files, correspondence, and transaction logs are retained for at least 10 years after account closure or longer if required by law.
2. Data is stored securely within India in compliance with the DPDP Act and RBI data localization norms.

8. Roles & Responsibilities

• Board of Directors — overall accountability for AML/KYC compliance.
• Chief Compliance & Risk Officer (CCRO) — responsible for STR/CTR filings with FIU-IND.
• Designated Director — ensures compliance with obligations under PMLA.
• Grievance/Compliance Officer — execution of KYC verification and transaction monitoring.
• Operations Teams — first point of contact for User KYC/AML queries.

9. Training & Awareness

1. All employees and authorized partners undergo periodic AML/KYC training.
2. Training covers identifying suspicious transactions, handling User data securely, and reporting obligations.

10. Sanctions & Blacklists

1. We do not onboard or may restrict services to individuals/entities appearing on UN Sanctions List, RBI Defaulter List, SEBI Debarred List, or FIU-IND flagged entities.
2. Transactions involving FATF high-risk jurisdictions are subject to EDD or may be declined.

11. Data Privacy & Security in AML/KYC

1. KYC/AML data is handled in accordance with our Privacy Policy.
2. Sensitive data (Aadhaar, PAN, biometrics) is encrypted and stored securely; access is strictly controlled.
3. No KYC data is sold or misused.

12. User Obligations

1. Provide accurate, valid, and up-to-date KYC information; do not impersonate or use forged/stolen identity documents.
2. We may deny/refuse services if KYC is incomplete or suspicious; report suspicious/fraudulent documents to FIU-IND or law enforcement; request additional documents (source of funds, purpose of transaction, beneficial ownership); freeze accounts where required by orders or sanctions matches; and place temporary holds pending verification.

13. Non-Compliance Consequences

• Temporary suspension of services
• Permanent account closure
• Reporting to regulatory/law enforcement authorities
• Freezing of accounts where required by law

14. Review & Updates

1. This Policy will be reviewed annually, or earlier if directed by regulators.
2. Amendments will be published on the Platform with a “Last Updated” date.

15. Limitation of Liability

1. EaseMyDeal’s liability in connection with AML/KYC processes is limited strictly to compliance with applicable laws.
2. Users are responsible for providing valid KYC details and ensuring lawful use of services.
3. If nevertheless held liable by a competent authority, our liability is capped at the convenience fee actually retained for the relevant transaction, or INR 100, whichever is lower.