AML & KYC Policy

The purpose of this Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy is to:

• Comply with PMLA, SEBI, AMFI, IRDAI, and other applicable regulations.

• Prevent money laundering, terrorist financing, and fraudulent transactions.

• Ensure that Niyyam™ users are accurately identified and verified before engaging in financial transactions.

• Protect the Platform and its users from financial and regulatory risks.

This policy applies to:

• All users of Niyyam™, including investors, policyholders, and borrowers.

• All financial transactions facilitated via the Platform, including mutual funds, insurance policies, and loans.

• All employees, agents, and third-party service providers engaged in user onboarding, KYC, or transaction processing.

3.1 Identity Verification: Collect government-issued ID proofs such as PAN, Aadhaar, passport, voter ID, or driver license. Verify name, date of birth, and photograph for all users.

3.2 Address Verification: Collect official address proof: utility bill, bank statement, Aadhaar, passport, or voter ID.

3.3 Financial & Risk Profiling: Obtain bank account details, income details, and FATCA/CRS declarations. Conduct risk assessment based on investment experience, source of funds, and financial profile.

3.4 Enhanced Due Diligence (EDD): Applied to high-risk users such as politically exposed persons (PEPs), foreign nationals, or users with complex financial profiles.

4.1 Transaction Monitoring: Monitor transactions for unusual, suspicious, or high-value activity. Flag and review transactions that deviate from the user financial profile.

4.2 Reporting Suspicious Activity: Report suspicious transactions to the Financial Intelligence Unit — India (FIU-IND) as required under PMLA. Maintain records of reports, investigations, and actions taken.

4.3 Prohibited Users & Activities: Users involved in fraud, money laundering, terrorism financing, or illegal activities will be blocked and reported to authorities.

All KYC and AML-related documents, logs, and reports will be retained for at least 5 years or as mandated by law. Records include:

• Identity and address proofs

• Financial and risk profiles

• Transaction monitoring reports

• Suspicious transaction reports and regulatory filings

Data will be securely stored, encrypted, and accessible only to authorized personnel.

Users are required to:

• Provide accurate and complete KYC documents.

• Update any changes in personal information (address, contact details, bank accounts).

• Cooperate with verification requests or inquiries from the Platform.

Failure to comply may result in denied access, blocked transactions, or account suspension.