KYC AND AML POLICY

KYC AND AML POLICY

HAR SHREEJEE FINANCE & LEASING COMPANY LIMITED

PREAMBLE

Harshreejee Finance & Leasing Company Limited (hereinafter “the Company”) is committed to preventing its products and services from being used, intentionally or unintentionally, for money laundering or terrorist financing. This policy has been prepared in compliance with the Reserve Bank of India (RBI) guidelines, the Prevention of Money Laundering Act (PMLA), 2002, and other applicable regulations. It focuses on robust procedures for Know Your Customer (KYC), Anti-Money Laundering (AML) for individual borrowers availing payday loans.

OBJECTIVES

  1. Ensure the Company is not used for money laundering or terrorist financing activities.
  2. Comply with all regulatory requirements under RBI guidelines and PMLA.
  3. Establish procedures for identification, verification, and monitoring of individual customers.

DEFINITION OF CUSTOMER

For this Policy, a “Customer” refers to any individual who applies for or maintains a payday loan account with Harshreejee Finance & Leasing Company Limited. This includes:

  • The borrower themselves.

CUSTOMER ACCEPTANCE POLICY (CAP)

  1. No account or loan shall be provided in fictitious, anonymous, or benami names.
  2. Customers shall be categorised into risk levels (low, medium, high) based on their profile, transaction patterns, and background.
  3. Loans shall only be approved after proper verification of identity and address.
  4. Procedures will ensure that genuine customers are not denied services.
  5. Risk information shall be collected at the time of the loan application.

CUSTOMER IDENTIFICATION PROCEDURES (CIP)

The Company shall:

  1. Verify the identity of each customer using reliable, independent documents.
  2. Obtain information regarding the purpose and expected nature of the loan.
  3. Apply enhanced due diligence for higher-risk customers.
  4. Maintain photographs, identity, and address proof for all customers.

KYC DOCUMENT REQUIREMENTS FOR INDIVIDUALS

Proof of Identity (at least two, self-attested):

  • Passport
  • PAN Card (with photograph)
  • Voter’s ID
  • Driving License
  • Aadhaar letter issued by UIDAI

Proof of Address (any one, self-attested):

  • Passport
  • Electricity bill (not older than 3 months)
  • Telephone bill (not older than 3 months)
  • Bank statement (not older than 3 months)
  • Aadhaar letter issued by UIDAI
  • Rent Agreement
  • Water Bill
  • Wifi Bill

Additional Documents for Payday Loan Application:

  • Salary slips of the last three 3 months.
  • Bank Statements of the salary account of the last 6 months, if required, then bank statements of the saving account(s) of the last 6 months.

MONITORING AND REPORTING OF TRANSACTIONS

  1. All transactions will be monitored in line with the customer’s risk profile.
  2. Special attention will be given to unusually large or irregular payments inconsistent with the customer’s profile.
  3. Risk factors such as customer background, source of income, and repayment pattern shall determine monitoring intensity.
  4. Risk categorization and enhanced due diligence shall be reviewed at least every six months.
  5. Suspicious transactions will be reported to the Financial Intelligence Unit – India (FIU-IND) by the Principal Officer.

RISK MANAGEMENT

  • The Board ensures effective KYC and AML procedures, including oversight, internal controls, and segregation of duties.
  • Internal audit and compliance departments evaluate adherence to policies.
  • All employees undergo regular training in KYC/AML procedures.

CUSTOMER EDUCATION

  • Customers will be informed about the purpose of KYC documentation through pamphlets or direct communication.
  • Frontline staff will be trained to handle queries or concerns regarding KYC requests.

INTRODUCTION OF NEW TECHNOLOGIES

  • The Company shall review and address potential money laundering risks from digital channels or online loan applications.

APPOINTMENT OF PRINCIPAL OFFICER

  • A Principal Officer shall be appointed at the head office to monitor KYC/AML compliance and report suspicious transactions to FIU-IND.
  • The Principal Officer will maintain liaison with enforcement agencies and ensure the timely submission of CTRs and STRs.

MAINTENANCE OF RECORDS

  1. Records of all cash and suspicious transactions shall be maintained as per the PMLA Rules.
  2. Customer identification and transaction records will be preserved for at least ten years after the end of the business relationship.
  3. Records will be easily retrievable for regulatory authorities and prosecution purposes.

UPDATING OF KYC POLICY

  • The Board is authorized to update or amend this policy to comply with RBI or statutory amendments.

REPORTING TO FIU-IND

All qualifying cash and suspicious transactions will be reported to:

Director, FIU-IND
Financial Intelligence Unit – India
6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110021
Website: http://fiuindia.gov.in

APPROVAL & ADOPTION

This KYC & AML Policy is approved by the Board of Directors of Harshreejee Finance & Leasing Company Limited and is effective from the date of adoption that is _______.

Board of Directors
Harshreejee Finance & Leasing Company Limited