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KYC & AML Policy

Document Name: KYC & AML Policy
Review Period: Annual
Owner / Contact: Compliance Department
Approver: Board of Directors

1. Introduction

This KYC & AML Policy is framed to prevent the company from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities. The Company ensures compliance with the Prevention of Money Laundering Act (PMLA), 2002 and the rules framed thereunder, as amended from time to time, and the directions issued by Reserve Bank of India (RBI).

2. Objectives

• To prevent criminal elements from using ICPL for money laundering activities.
• To put in place appropriate KYC policies and procedures.
• To ensure customer identification and verification standards.
• To ensure effective implementation of AML standards.
• To comply with all applicable legal and regulatory requirements.

3. Definitions

Customer: A person or entity that maintains a business relationship with the Company or for whom the Company opens an account.
Money Laundering: A process of making illegally-gained proceeds appear legal.
Principal Officer: A person designated by the Company responsible for monitoring and reporting of all transactions and sharing of information as required under the law.

4. Key Elements of the Policy

The KYC Policy includes the following four key elements:

• Customer Acceptance Policy (CAP)
• Customer Identification Procedures (CIP)
• Monitoring of Transactions
• Risk Management

5. Customer Acceptance Policy

• No account is opened in anonymous or fictitious names.
• Due diligence is exercised before entering into any business relationship.
• Customers are categorized based on risk perception into low, medium and high risk.
• Documentation requirements and other information are collected depending on the risk category of the customer.
• It is ensured 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.

6. Customer Identification Procedure

ICPL follows customer identification procedures in the following cases:

• Commencement of an account-based relationship with the customer.
• When there is doubt about the authenticity or adequacy of previously obtained customer identification data.

The identification of the customer is done by collecting reliable documents, data, or information and verifying the same using independent sources like Aadhaar, PAN, etc.

7. Monitoring of Transactions

ICPL monitors transactions of a suspicious nature and records the same. The nature and level of monitoring depends on the risk sensitivity of the account. Transactions are reviewed to ensure that they are consistent with the customer’s risk profile and business.

8. Risk Management

ICPL has a risk-based approach to implement its KYC & AML policy. Customers are categorized based on risk perception and appropriate due diligence is conducted accordingly. High-risk customers are subject to enhanced due diligence. Periodic internal audits are conducted to ensure compliance.

9. Maintenance of Records

ICPL maintains all necessary records of transactions for at least five years after the business relationship has ended. This includes information related to identification, account files, business correspondence and records of transactions.

10. Reporting to FIU-IND

ICPL reports all suspicious transactions to the Financial Intelligence Unit – India (FIU-IND). The Principal Officer is responsible for timely submission of Suspicious Transaction Reports (STR) and other reporting obligations.

11. Designated Director and Principal Officer

The Company has designated a Director as the “Designated Director” and appointed a “Principal Officer” to ensure overall compliance with the obligations under PMLA, rules and regulations issued by RBI.

12. Employee Training

ICPL conducts ongoing training programs to educate employees about AML and KYC policies, procedures, and standards. Employees are trained to detect and report suspicious transactions.

13. Review of the Policy

This KYC & AML policy shall be reviewed annually or as and when required by regulatory updates. Any changes made shall be approved by the Board of Directors and updated on the Company’s website.