KYC Policy

Policy On

‘Know Your Customer’ Guidelines And

‘Anti-Money  Laundering’ Standards

RAHIR ACS MONEY  PRIVATE LIMITED

Introduction

The Reserve Bank of India (“RBI”) has issued Master Direction on Issuance and Operation of Prepaid Payment Instruments (“Direction”) which governs the functioning of the companies issuing prepaid payment instruments (“PPI”). Among other things contained in the Direction, RBI requires adoption of ‘Know Your Customer’ (“KYC”) guidelines - Anti Money Laundering (AML), as defined in the PML Act (defined hereinafter), thereby setting standards for prevention of money laundering activities and corporate practices while dealing with their  customers from time to time, by the entities issuing PPI and their Retailer / Distributor. These guidelines incorporate the recommendations made by the Financial Action Task Force on anti-money laundering standards and combating financing of terrorism as these are being used as the International Benchmark for framing the stated policies, by the regulatory authorities.

In view of the same, Rahir Acs Money Private Limited (“Company” or “RAMPL”) has adopted a robust policy frame work on KYC and AML measures in line with the prescribed RBI guidelines (“KYC-AML Policy” or this “Policy”). The Company shall adopt all the best practices prescribed by RBI from time to time and shall make appropriate modifications to the Policy, if necessary, to conform to the standards so prescribed. The contents of the Policy shall always be read in tandem/auto- corrected with the changes/modifications which shall be advised by RBI from time to time.

Objective:

The objective of the Policy is to prevent the Company from being used, intentionally or unintentionally, by criminal elements for money laundering activities or terrorist financing activities. KYC procedures shall also enable the Company to know and understand its Customers  (defined hereinafter)  and  its  financial  dealings  better  which  in  turn  will  help  it  to            manage its risks prudently.

This Policy includes 4 (Four) key elements:

1. Customer Acceptance Policy (“CAP”);
2. Customer Identification Procedures (“CIP”);
3. Monitoring of Transactions;
4. Risk Management.

Applicability:

It may be noted that this Policy as stated in this document shall prevail over anything else contained in any other document, process, circular and / or instruction that has been issued by RFPL in this regard and shall be applicable to all verticals and products  of  the Company,  whether existing or rolled out in future.

Definitions:

In this Policy, unless there is anything in the subject or context inconsistent therewith, the expressions listed below shall, when capitalized, have the following meanings:

“Retailer” shall mean the any person appointed by the Company or by the Distributor representing the Company, for furthering the business objects of the Company.

“AML” stands for anti-money laundering.

“Beneficial Owner” shall  mean the ultimate natural person who inter alia fulfills  the criteria provided in Sub Clause 8 of Part II (Customer Identification Procedures) of this Policy.

“CDD” or Customer Due Diligence shall mean the process of the identifying and verifying the Customers and the Beneficial Owners.

“Central KYC Records Registry” shall mean an entity defined under Rule 2(1)(aa) of the PML Rules, to receive, store, safeguard and retrieve the KYC records in digital form of a Customer.

“CFT” stands for combating financing of terrorism.

“Customer” shall mean any Person that (a) has a business relationship with the Company and/or its Retailer / Distributor ;(b) has a financial transaction or activity with the Company and / or its Retailer / Distributor; (c) is connected with a financial transaction which can pose significant reputation or other risks to Company.The definition of “Customer” shall include any Person who is in process of or is proposing to become a customer of the Company.

“KYC” stands for know your customer.

“Master Directions” shall have the meaning given to such term in the Introduction to this Policy.

“Person” includes an individual, statutory corporation, company, body corporate, partnership, joint venture, association of persons, Hindu Undivided Family (HUF), societies (including co-operative societies), trust, unincorporated organization and other bodies / agencies as may be considered as “Person” by RFPL.

“PEP” shall mean a politically exposed person.

“PMLA Act” shall mean the Prevention of Money Laundering Act, 2002, including all the rules / regulations made pursuant thereto, as amended from time to time

“PML Rules” shall mean Prevention of Money-laundering (Maintenance of Records) Rules, 2005, as amended from time to time.

“Senior Management” for the purpose of this Policy shall mean the Directors of the  Company, as applicable.

“Suspicious Transactions” shall have the meaning given to such term in the Master  Directions and any other regulations, guidelines, and /or circulars as may be issued by RBI.

I)Customer Acceptance Policy (“CAP”):

1. Customer Acceptance Policy lays down the criteria for acceptance of the Customers. The guidelines in respect of the Customer relationship in the Company broadly includes the following:

1. No account is to be opened in anonymous or  fictitious  /  benami name(s) /  entity (ies);

1. No account is opened where the Company is unable to apply appropriate CDD measures, either due to non-cooperation of the customer or non-reliability of the documents/information furnished.

1. No transaction or account-based relationship is undertaken without: (a) following the Customer Identification Procedure and Risk Management.

1. CDD procedure shall be applied at the Unique Customer Identification Code (UCIC) level.

1. CDD Procedure shall be applicable for all the joint account holders, while opening  a joint account.

1. Any mandatory information to be sought for KYC purpose while opening an  account and during the periodic updation, shall be clearly specified.

1. Any optional / additional information should be sought separately with consent, clearly indicating that providing of such information is optional.

1. Necessary checks should be carried out before opening a new account to ensure that the identity of the Customer does not match with any Person with known criminal background or with banned entities such as individual terrorists or  terrorist organizations, etc or with Persons whose name appears in the sanctions lists circulated by the RBI.

1. Documentation requirements and other information to be collected in respect of different categories of the Customers and keeping in mind the requirements of PMLA Act and the guidelines issued by RBI and other statutory and regulatory bodies from time to time.

2. While implementation of Customer Acceptance Policy is necessary, such procedures should not become too restrictive and result in denial of the Company services to general public, especially those, who are financially or socially disadvantaged.

3. However, Retailer / Distributor, through whom the business is conducted and who may be the customer as well, work on the pre-paid model with the Company have been classified as Low Risk customers.

4. The customer profile will be treated as a confidential and details contained  therein will not be divulged to outsiders for cross selling or any other purposes.

5. The responsibility of ensuring compliance in relation to customer acceptance policy shall be with the Sales / Business Development Team of the Company.

II)Customer Identification Procedures (“CIP”):

1. Customer identification means  identifying the Customer and verifying  their  identity  by using reliable, independent source documents, data or information. The Company shall obtain sufficient information necessary to verify the identity of each new Customer.  Besides  risk  perception,  the  nature  of  information/documents  required would also depend on the type of the Customer (individual, corporate, etc.). For the Customers that are natural persons, the Company shall obtain sufficient identification data to verify the identity of the Customer, their address/location, and  live photograph.

2. The KYC checklist / documents and information to be obtained from Customers shall be in line with Annexure II of this Policy; provided however, in cases where Customer desiring to open an account does not  have the  information mentioned  in Annexure  II, the Company may open accounts subject to the conditions specified under Regulation 24 of the Master Directions. All such documents shall be: (a) original seen

and verified (OSV) by the officer of the Company or an authorized Retailer / Distributor of the Company. KYC process followed by the Company has been enumerated below:

2.1.KYC Process

1. Minimum KYC for Customers

As per the PPI Direction, the minimum details include mobile number verified with One Time Pin (OTP) and self-declaration of name and unique identification number of any of the ‘officially valid document’ defined under Rule 2(d) of the PML Rules 2005, as amended from time to time. As per RBI Master Direction on KYC guidelines, Officially Valid Document (OVD) means

• Passport,
• Driving License,
• Voter's Identity Card issued by the Election Commission of India,
• Job Card issued by NREGA duly signed by an officer of the State Government,
• letter issued by the National Population Register containing details of name and address.

Wallet Limits for Minimum KYC Customers:

Acs Money wallet customers with Minimum KYC as specified above will be entitled to hold wallet balance/value of Rs. 10,000 only at any point of time and avail of a permissible total value of re- loads during any given month of Rs. 10,000 only which would be in an electronic form only.

These Customers shall be converted into Full KYC compliant within a period of 24 months from the date of issue of PPI, failing which no further credit shall be allowed in such PPIs. However, the Customer shall be allowed to use the balance available in the account.

2.1.2.Full KYC for Retailer / Distributor and Customers

As per the PPI Direction, the Full KYC shall be done in line with the RBI Master Direction on KYC guidelines. A brief process flow for Full KYC is given below:

1. Identification and on boarding process for Retailer / Distributor

Case 1: For a ProspectiveRetailer / Distributor

• For registering a prospective Retailer / Distributor and onboarding onto the Acs Money Network, company’s employee visits the Retailer / Distributor and interacts, verifies and collects the requisite information and documentation from the Retailer / Distributor and inputs this data onto the Acs Money Portal – acsmoney.co.in

• In case a request from a prospective Retailer / Distributor is received either via email or website, along with the requisite information and documentation, a Acs Money employee visits that Retailer / Distributor and interacts, verifies and collects the seen and verified copies of the information and documentation and uploads it onto the Acs Money Portal - acsmoney.co.in

• A maker-checker concept is implemented to verify the uploaded information and furnished documentation to authenticate, authorize and activate the Retailer / Distributor onto Acs Money system.

Case 2: For a Prospective Retailer / Distributor under an Existing Retailer /

Distributor

Prospective Retailer / Distributor is created by an already existing Retailer / Distributor in the Company’s system in a hierarchical manner i.e. prospective Retailer / Distributor (who is being added) gets registered under the existing Retailer / Distributor (who is adding). In order to get and verify the information of the prospective Retailer / Distributor being added to the system, it is necessary to perform KYC which is ensured by the following process:

Request for KYC:

• Existing Retailer / Distributor will put request for adding the prospective Retailer / Distributor under him/her  by  filling the basic  details  of the Retailer / Distributor (E.g. name,  phone number which acts as the credentials for Retailer / Distributor login).

• Subsequently, on the KYC page, the process of uploading required documents will be done.
• Documents uploaded by the Existing Retailer / Distributor will include documents for Address Proof (Aadhaar, Driving License, Passport, Voter ID etc.), PAN Card for ID proof, and Live photo of the New Retailer / Distributor holding the IDs as displayed on the Company’s portal acsmoney.co.in

• After uploading all the  documents, the  Existing Retailer / Distributor will give the consent   for the KYC verification of the prospective Retailer / Distributor being registered and declare that he/she has verified the uploaded documents with the originals; request for addition / registration of prospective Retailer / Distributor gets registered  successfully and his/her approval for KYC will be submitted successfully.

Approval of KYC:

• Approval of KYC shall be performed by Acs Money CRM User and is done through Acs Money CRM portal. This process will include verification of the furnished information and uploaded documents. Once an authorized Acs Money CRM user views, verifies and approves the KYC request, the Retailer / Distributor can login to the portal by using his/her Registered Mobile Number and secure password.

-Parallel trial of advanced technology for Automated KYC Approval using AI/ML based technologies:

Acs Money is investing in more advanced risk technologies for KYC matching, review and approval. Such technology components will be deployed in KYC approval process initially on a trial basis to monitor effectiveness and improve accuracy. This process will include uptake of uploaded documents and auto- segmentation of documents and images for details and facial data extraction and then matching with person photographs. The system will auto-capture and fill these details and matching logic will provide score which will be filtered below a threshold for manual authorized Acs Money CRM user to validate. During trial period all cases will parallelly be validated by manual user to verify this trial. Over time, the system will learn and threshold updated for more efficient automation.

Note:

• When KYC request is being processed through mobile app then there is a provision to scan QR code from Aadhaar Card so that the user details can automatically get filled on KYC request page.

• While onboarding the Retailer / Distributor, they would undertake, when registering via the app, web or email, that they will: a) not charge beyond what is prescribed by the Company; and b) post a signage indicating their status as service providers for the Company and the fees for all services available at the outlet.

2. Identification and onboarding process for Customer Request for KYC:

• Company’s Retailer / Distributor makes request for adding a new Customer. Any Retailer / Distributor of the company, whether appointed directly or otherwise as per this Policy, can make this request by filling the basic details of the Customer for registration via Acs Money portal - acsmoney.co.in

• Subsequently, with the help of KYC page, the process of uploading the required documents is done. The Customer documents uploaded by the Retailer / Distributor includes documents for Address Proof (Aadhaar Card, PAN Card, Driving License, Passport etc.) and a Live photo of the Customer holding the ID card as displayed on the portal.

• In case of non-availability of PAN Card of the Customer, Retailer / Distributor can select Form 60 option. Once the documents are uploaded, an OTP is sent to the Customer’s mobile. Customer provides the OTP and request for KYC is submitted successfully.

Approval of KYC:

• Approval of KYC request is done by Acs Money CRM user on the Acs Money CRM portal. This process includes verification of the basic customer information and uploaded documents. After verification, the Acs Money CRM user approves the KYC of the customer.

-Parallel trial of advanced technology for Automated KYC Approval using AI/ML based technologies:

Acs Money is investing in more advanced risk technologies for KYC matching, review and approval. Such technology components will be deployed in KYC approval process initially on a trial basis to monitor effectiveness and improve accuracy. This process will include uptake of uploaded documents and auto- segmentation of documents and images for details and facial data extraction and then matching with person photographs. The system will auto-capture and fill these details and matching logic will provide score which will be filtered below a threshold for manual authorized Acs Money CRM user to validate. During trial period all cases will parallelly be validated by manual user to verify this trial. Over time, the system will learn and threshold updated for more efficient automation.

Note:

• The KYC verification and  updation process remains the same as above even  in case its initiated via the app.

ethod of taking a Live Photo

2.2.KYC Updation:

1. For KYC updation, a request will be sent by the user via email to the Acs Money

Support Team at contact.acsmoney@gmail.com along with complete, clear and valid documents to update against his/her record stored with Acs Money. After due scrutiny of the documents, the information will be updated.

1. Retailer / Distributor are classified under lowrisk category and their KYC shall be updated once in every ten years.
2. Updation from Minimum-KYC Wallet to Full KYC Wallet: Users can also contact Acs Money Authorized Retailer / Distributor along with the documents. The Acs Money Retailer / Distributor sends the information along with the supporting documents via email to Acs Money at contact.acsmoney@gmail.com.com for account upgradation. Upon successful verification, the account is upgraded, and the user is intimated of the same accordingly via SMS and/ or via personal enquiry at the Retailer / Distributor location.

2.3.KYC Rejection:

Request for KYC updation will be rejected on the following conditions:

1. Information  furnished  by  the  user  does  not  match  with  the  document/s furnished/ uploaded.
2. Furnished documentation is not complete, has invalid/expired documentation or copies furnished are illegible.
3. Photograph captured does not  match with the correct formats  as  displayed  in the below pictorial presentation.

3. For the Customers that are natural persons, the Company shall obtain sufficient identification data to verify the identity of the Customer, their address/location, and recent photograph.

4. For the Customers that are legal Persons, the Company shall:
   1. verify the legal status of such Person through proper and relevant documents;
   2. verify that any person purporting to act on behalf of the legal Person is so authorized and identify and verify the identity of that Person; and
   3. understand the ownership and control structure of such legal Person and determine who are the natural persons who ultimately control such legal Person.

5. The Company has formulated and implemented Customer Identification Procedures to determine the real identity of its Customers keeping the above in view.

6. In addition, if applicable, Enhanced Customer Identification Requirements keeping in view the provisions PML Act as indicated in Annexure I hereto, shall also be adhered to while undertaking Customer Identification Procedure.

7. The responsibility of ensuring compliance in relation to customer  identification  policy shall be with the Sales / Business Development Team of the Company.

8.Identification of Beneficial Owner:

For opening an account of a legal Person who is not a natural Person, the ultimate Beneficial Owner shall be identified and all reasonable steps in terms of Rule 9(3) of the PML Rules, to verify his/her identity shall be undertaken.

Where no natural person is identified under points 1, 3 and 4 above, the Beneficial Owner

is the relevant natural person who holds the position of senior managing official.

Where the Customer or the owner of the controlling interest is a company listed on a

stock exchange, or is a subsidiary of such a company, it is not necessary to identify and

verify the identity of any shareholder or ultimate natural Beneficial Owner of such

companies.

In cases of trust/nominee or fiduciary accounts whether the Customer is acting on behalf

of another Person as trustee/nominee or any other intermediary shall be determined. In

such cases, satisfactory evidence of the identity of the intermediaries and of the Persons

on whose behalf they are acting, as also details of the nature of the trust or other

arrangements in place shall be obtained.

9.Allotment of Unique Customer Identification Code (UCIC):

The Company shall allot a Unique Customer Identification Code (“UCIC”) to all its new Customers while entering into a relationship. Further for the existing Customers such UCIC would be created, as required in terms of the applicable laws and / or RBI regulations. The UCIC will be used to identify Customers, avoid multiple identities and monitor financial transactions in a holistic manner.

III)Monitoring of Transactions:

1. Ongoing monitoring / ongoing due diligence is an essential element of effective implementation of this Policy. The Company shall make an endeavor to understand the normal and reasonable activity of the Retailer / Distributor and Customer so that transactions which fall outside the regular/pattern of activity can be identified. Monitoring of transactions shall be conducted by the Operations Team of the Company.

2. Special attention shall be paid to certain categories of transactions such as those which are complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose. The transactions that involve large amounts of cash inconsistent with the normal and expected activity of the Retailer / Distributor and /  or  Customer should particularly attract the attention of the Company.

3. The Sales / Business Development Team of the Company shall carry out the periodic review   of   performance   of   Retailer / Distributor,   risk   categorization   of   transactions/Customer’s accounts and the need for applying enhanced due diligence measures at a periodicity of not less than annual basis.

4. The responsibility of ensuring compliance in relation to monitoring of transactions/ ongoing due diligence shall be with the Sales / Business Development Team of the Company.

IV)Risk Management:

1. Senior Management includes Directors of the Company. Responsibility will be explicitly allocated within the Company for ensuring that the policies and procedures as applicable to Company are implemented effectively. Sales personnel shall be responsible for  creating risk profiles of its existing and new Retailer / Distributor and apply various AML measures keeping in view the risks involved in a transaction, account or business relationship in relation to each Retailer / Distributor and / or Customer.

2. There shall be a cooling period of 5 minutes for funds transfer upon opening the wallet so as to mitigate the fraudulent use of the wallet.

V)Record Keeping

1. Maintenance of records of transactions: The Company shall maintain proper record  of the transactions as required under Section 12 of the PML Act read with Rule 3 of the PML Rules.

The records required to be maintained in relation to the transactions mentioned above shall contain the following information:

1. the nature of the transactions;
2. the amount of the transaction and the currency in which it was denominated;
3. the date on which the transaction was conducted;
4. the parties to the transaction.

2. Preservation of records:

1. The electronic information provided for KYC is  stored in an encrypted format   on the Company’s server which is archived to the local repository on a weekly basis (7 days of the documents are uploaded). All the data which has been archived is moved from the server and stored on the encrypted local repository. Any KYC request pending for more than 7 days, the data gets archived and stored in an encrypted format on the local repository, and the Company will reject the request and the user will be prompted to do the KYC again.

1. Company shall maintain a log of all the transactions undertaken for at least ten years. This data shall be made available for scrutiny to RBI or any other agency

/ agencies as may be advised by RBI. Company shall also file Suspicious Transaction Reports (STRs) to Financial Intelligence Unit- India (FIU-IND).

1. Company shall take appropriate steps to evolve a system for proper maintenance and preservation of information (in hard and/or soft copies) in a manner that allows such data to be retrieved easily and quickly whenever required or as and when requested by competent authorities.

1. The Compliance Team of the Company shall be responsible of compliance of the above provisions in relation to Record Keeping and preservation of record.

VI)Compliance of this Policy

1. The Company shall have an ongoing employee training program so that the members of the staff and its Retailer / Distributor are adequately trained in KYC procedures. Training requirements shall have different focuses for frontline staff, compliance staff and staff dealing with new Retailer / Distributor. It is crucial that all those concerned fully understand the rationale behind the KYC policies and implement them consistently.

2. The Senior Management of the Company under the supervision of the Board of Directors and any committee of  the  Company shall ensure effective implementation of this Policy by putting in place appropriate procedures to ensuring their effective implementation, covering proper management oversight, systems and controls, segregation of duties, training and other related matters.

3. The Company shall utilize risk-based approach to address management  and  mitigation of various AML risks and ensure concurrent/internal audit and independent evaluation to verify the compliance with this Policy and procedures,  including legal  and regulatory compliances under the PML Act, PML Rules, the guidelines issued by RBI and other statutory and regulatory bodies from time to time.

4. The Company shall put in place a concurrent / internal audit system to verify compliances with KYC / AML policies and procedures and shall also ensure independent evaluation of the Company’s policies and procedures,  including  legal and regulatory requirements.

5. Further, the Company shall have an adequate screening mechanism in place as an integral  part  of  its  recruitment/  hiring  process  to  ensure  that  persons  of  criminal nature or background do not get an access, to misuse the financial channel. The Head of Human Resources of the Company shall be responsible for compliance of this provision.

6. The Compliance Team of the Company shall submit on a quarterly basis, audit notes and compliance to the Board of Directors of the Company.

VII)Designated Director

The Company shall appoint a person who is the Managing Director or a whole time Director, (but other than the Principal Officer), as the “Designated Director”, to ensure compliance with the obligations under the PML Act and PML Rules. The name, designation and address of such ‘designated director’, may be communicated to the FIU-IND.

VIII)Appointment of Principal Officer

The Company shall designate a senior employee as  the ‘Principal  Officer’ (“Principal  Officer”) who shall be located at the Head / Corporate office and shall be responsible for monitoring and reporting of all transactions and sharing of information as required under the law. The Principal Officer shall maintain close liaison with enforcement agencies, NBFCs and any other institutions which are involved in the fight against money laundering and combating financing of terrorism.  The employees of the Company shall endeavor to provide any information in relation to  suspicious transactions, on receipt of any notices / other information in relation thereto to the Principal Officer.

IX)Reporting to Financial Intelligence Unit – India

The Principal Officer shall report information relating to Suspicious Transactions, if detected, to the Director, Financial Intelligence Unit - India (FIU-IND) as advised in terms of the PML Rules, in the prescribed formats as designed and circulated by RBI

The employees  of  the  Company  shall  maintain strict  confidentiality  of  the  fact  of  furnishing/ reporting details of suspicious transactions and it shall be ensured that there is no tipping off / information leak to the Customer at any level. A copy of information furnished shall be retained by the Principal Officer for the purposes of official record.

X)MISCELLANEOUS

1. Introduction of new technologies

The Company shall pay special attention to any money laundering threats that may arise from new or developing technologies including online transactions that may favor anonymity, and take measures, if needed, to prevent their use in money laundering. The Company shall ensure that any remittance of funds by any other mode, for any amount, is affected by debit to the Customer’s account and not against cash payment.

2.KYC for the Existing Accounts

While this Policy will apply to all new Retailer / Distributor and Customers, the same would also be applied to the existing Retailer / Distributor and Customers based on materiality and risk. However, transactions with existing Retailer / Distributor and Customers would be continuously monitored for any unusual pattern in the operation of the accounts.

3.Conflict / Modification

The contents of this Policy shall always be read in conjunction with the Master Directions and / or other laws, rules, regulations and guidelines issued in this regard, from time to time and in the event of any change in the Master Directions and / or other laws, rules, regulations and guidelines, this Policy shall ipso facto stand amended to the extent required.

ANNEXURE I

CUSTOMER IDENTIFICATION REQUIREMENTS (INDICATIVE  GUIDELINES)

Accounts  of  Politically  Exposed Persons  (PEPs) resident outside India:

PEPs, or politically exposed persons are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g., Heads of States / Governments, senior politicians,   senior   government/judicial/military   officers,   senior   executives   of   state-owned corporations, important political party officials, etc. The Company shall gather sufficient information on any Person of this category intending to establish a relationship and check all the information available on the Person in the public domain. The Company shall verify the identity    of the Person and seek sufficient information including information about the sources of funds, accounts of the family  members and/or close relatives of the PEPs, before accepting the  PEP   as a Customer. The decision to provide financial services to an account for the PEP shall be taken  by  the  Board/Management  Committee,  in  accordance  with the  Customer  Acceptance Policy and shall be subjected to enhanced monitoring on an ongoing basis. In the event of an existing Customer or the Beneficial Owner of an existing account subsequently becoming a PEP, approval of the Board/Management Committee shall be obtained to continue the business relationship. The above norms shall also be applied to the accounts where the PEP is a Beneficial Owner.

Trust/Nominee or Fiduciary Accounts:

Branch offices shall determine whether the Customer is acting on behalf of another person as trustee/nominee or any other intermediary. If so, they shall insist on receipt of satisfactory evidence of the identity of the intermediaries and of the Persons on whose behalf they are reacting, as also obtain details of the nature of the trust or other arrangements in place. The Company shall take reasonable precautions to verify the identity of the trustees and the settlers of trust (including any Person settling assets into the trust), grantors, protectors, beneficiaries and signatories. Beneficiaries shall be identified when they are defined.

Accounts of companies and firms:

Branch offices need to be vigilant against business entities being used by individuals as a front for maintaining accounts with the Company and / or other NBFCs. Branch offices may examine the control structure of the entity, determine the source of funds and identify the natural persons who have a controlling interest and who comprise the management. When the Company identifies a Customer (which is a company / firm) for opening an account, it should identify the Beneficial Owners of such Customer and take all reasonable steps in terms of Rule 9(3) of the PML Rules to verify the identity.

ANNEXURE II

Customer Identification Procedure Features to be verified and documents that shall be obtained