KYC and AML Policy

Credknow Solutions Private Limited

1. Objective

This policy outlines the framework for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance followed by Credknow Solutions Private Limited (“Credknow” or “the Company”) in accordance with applicable laws, including the Prevention of Money Laundering Act, 2002 (PMLA), RBI guidelines, and industry best practices.

  • Prevent misuse of Credknow for unlawful activities like money laundering and terrorism financing.
  • Ensure proper client identification, verification, and monitoring.
  • Promote high ethical and legal business standards.

2. Scope

  • All departments interacting with clients.
  • All customers availing services like loans, credit revival, etc.
  • Third-party vendors involved in onboarding or verification.

3. Regulatory Framework

  • Prevention of Money Laundering Act, 2002 and related rules.
  • RBI Master Directions on KYC.
  • Guidelines from FIU-IND, UIDAI, and other authorities.

4. KYC Policy Elements

a. Customer Acceptance Policy (CAP)

  • No anonymous or fictitious names.
  • Due diligence before onboarding.
  • Risk-based categorization (Low/Medium/High).
  • Extra checks for PEPs and high-risk clients.

b. Customer Identification Procedures (CIP)

  • Use of reliable documents:
    • Individuals: PAN, Aadhaar, Passport, etc.
    • Entities: Certificate of Incorporation, PAN, GST, etc.
  • Verification methods: Aadhaar, Video KYC, PAN validation, etc.

c. Monitoring of Transactions

  • Ongoing monitoring of customer activity.
  • Detection of unusual or suspicious patterns.
  • Automated red-flag alerts where applicable.

d. Risk Management

  • Customer risk classification and periodic reviews.
  • Enhanced due diligence for high-risk cases.

5. AML Compliance

  • Verification of Source of Funds.
  • Monitoring for:
    • Large or unexplained transactions.
    • Transaction structuring to avoid thresholds.
    • Multiple unrelated accounts.
  • STR filing with FIU-IND.

6. Record Maintenance

  • KYC records and transaction logs for at least 5 years.
  • STRs stored for 5 years post-filing.
  • Secure, encrypted storage with limited access.

7. Employee Training

  • Staff trained on KYC/AML practices.
  • Periodic refresher sessions.

8. Audit and Review

  • Regular internal audits.
  • Policy updates based on regulations.

9. Responsibilities

  • KYC Officer: Oversees onboarding compliance.
  • Principal Officer: Manages AML reporting.
  • Compliance Officer: Monitors overall adherence.

10. Review and Amendments

This policy will be reviewed annually or upon regulatory updates. Changes will be approved by senior management and shared with concerned teams.

Conclusion

Credknow is committed to strong customer verification, data integrity, and compliance with financial crime regulations. This policy reinforces our secure and responsible business operations.