KYC & AML Policy

The primary objective of this Policy is to prevent the use of our lending platform for money laundering, terrorist financing, identity fraud, or any other unlawful activities. We achieve this through customer verification, risk assessment, transaction monitoring, and continuous compliance with applicable laws.

This Policy is implemented in accordance with the applicable regulatory framework, including:

• Reserve Bank of India (RBI) Master Direction – Know Your Customer (KYC).
• Prevention of Money Laundering Act (PMLA), 2002.
• Applicable AML/CFT guidelines, circulars, and regulatory updates issued by RBI.
• Other laws, notifications, and directions issued by competent authorities from time to time.

Before providing any financial service, MudraSewa follows a structured customer acceptance process to ensure regulatory compliance and responsible onboarding.

• Anonymous, fictitious, or benami identities are not accepted.
• Valid identity and address proof must be provided before loan disbursement.
• Additional verification may be carried out for high-risk customers, including Politically Exposed Persons (PEPs) and Non-Resident Indians (NRIs).
• Applications may be declined where mandatory documentation or verification requirements are not fulfilled.

Every applicant is required to complete identity verification before any lending relationship is established.

• Verification may be performed using Aadhaar, PAN, Passport, Voter ID, or other officially valid documents.
• Biometric or Aadhaar-based authentication may be used wherever permitted by law.
• Video KYC may be conducted in accordance with RBI guidelines.
• Existing customers may be required to complete periodic re-KYC based on their risk profile.

Customers are categorized into different risk levels based on factors such as occupation, transaction behaviour, source of income, and regulatory indicators.

• Low Risk – Salaried individuals and government employees.
• Medium Risk – Self-employed professionals and business owners.
• High Risk – Politically Exposed Persons (PEPs), cash-intensive businesses, and other higher-risk categories.

The frequency of KYC updates and monitoring is determined according to the assigned customer risk category.

We continuously monitor customer transactions to identify unusual or suspicious activities that may require additional review or regulatory reporting.

• Automated systems generate alerts for suspicious transaction patterns.
• High-value and unusual transactions are reviewed through risk-based monitoring.
• Threshold-based reporting mechanisms are maintained in accordance with regulatory requirements.

KYC records and transaction information are securely maintained in accordance with applicable legal and regulatory requirements.

• KYC documents are retained for at least five years after closure of the customer relationship.
• Transaction records are preserved for a minimum of five years from the transaction date.
• Records are securely stored and made available to authorized regulators whenever required.

Where required under applicable law, MudraSewa reports prescribed transactions to the appropriate regulatory authorities within the specified timelines.

• Suspicious Transaction Reports (STRs) are filed with FIU-IND whenever applicable.
• Cash Transaction Reports (CTRs) are submitted for reportable cash transactions.
• Periodic AML/CFT reporting requirements prescribed by RBI and other authorities are duly complied with.

Employees receive regular training on KYC, AML, fraud prevention, customer due diligence, and regulatory compliance to ensure consistent implementation of this Policy.

• Periodic compliance awareness and refresher programs.
• Documented onboarding and verification procedures.
• Defined roles, responsibilities, and escalation mechanisms for compliance matters.

This Policy is periodically reviewed to ensure continued compliance with regulatory requirements and industry best practices.

• Regular internal audits assess the effectiveness of KYC & AML controls.
• Senior management periodically reviews the Policy and compliance framework.
• Corrective measures are implemented promptly wherever gaps or deficiencies are identified.