2.⁠ Scope

Applies to all Clients and their end-customers, as well as Company personnel and third-party partners.

3.⁠ Client Verification

• Collect and verify: Certificate of Incorporation, Company PAN, Authorized-Signatory proof, recent bank statement.
• Identify beneficial owners holding ≥25 % equity.

4.⁠ ⁠End-Customer Verification

• For redemptions ≥₹50,000, Clients must collect government-issued ID and address proof.
• Enhanced due diligence for PEPs and sanctioned individuals.

5.⁠ Risk Assessment

• Classify Clients as Low, Medium, or High risk.
• Medium/High risk receive quarterly reviews and annual KYC re-validation.

6.⁠ ⁠Transaction Monitoring

• Automated alerts for:
• ≥200 % month-over-month funding/redemption spikes.
• Frequent redemptions just below thresholds.
• Compliance Officer reviews alerts within 24 hours.

7.⁠ Suspicious Activity Reporting

• Report to FIU-IND within 7 business days.
• Retain SAR records for 8 years.

8.⁠ Record-Keeping

• Maintain KYC files, transaction logs, and monitoring reports for 8 years.
• Secure storage with audit trails.

9.⁠ Training & Governance

• Annual AML/KYC training.
• Quarterly internal audits of compliance processes.