AML & KYC Policy

1. Purpose & regulatory framework

Payzoplus maintains a robust Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know-Your-Customer (KYC) framework aligned with:

• The Prevention of Money Laundering Act, 2002 (PMLA) and the PML (Maintenance of Records) Rules, 2005;
• The RBI Master Direction on Know Your Customer (as amended);
• The Foreign Exchange Management Act, 1999 (FEMA) and related Master Directions;
• FATF recommendations and applicable sanctions regimes (UN, and others as required);
• The Unlawful Activities (Prevention) Act, 1967 (UAPA) sanctions lists.

2. Customer Due Diligence (CDD)

We verify the identity of every customer before establishing a business relationship and at periodic intervals thereafter. CDD includes:

2.1 Individuals

• Officially Valid Documents (OVDs) — Aadhaar (via consented OTP/offline XML), PAN, passport, voter ID, or driving licence;
• Photograph and live/video verification where required;
• Verification of mobile and email.

2.2 Businesses

• Certificate of incorporation, PAN, GSTIN, and IEC (for cross-border trade);
• Board/authorisation documents and details of authorised signatories;
• Identification and verification of Beneficial Owners (25%+ ownership/control threshold as applicable).

3. Risk-based approach

Customers and transactions are risk-rated (low / medium / high) based on profile, geography, product, and transaction behaviour. Enhanced Due Diligence (EDD) is applied to higher-risk customers, including Politically Exposed Persons (PEPs), complex ownership structures, and transactions involving higher-risk jurisdictions.

4. Sanctions & watch-list screening

All customers and counterparties are screened at onboarding and on an ongoing basis against UN sanctions lists, the UAPA lists, and other applicable databases. We do not process transactions involving sanctioned persons, entities, or jurisdictions.

5. Ongoing monitoring & reporting

• Continuous, automated transaction monitoring for unusual or suspicious patterns;
• Filing of Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) with the Financial Intelligence Unit – India (FIU-IND) as required;
• Investigation and, where warranted, suspension or termination of relationships;
• Strict confidentiality — we do not “tip off” customers about regulatory reporting.

6. Record-keeping

KYC and transaction records are retained for a minimum of five (5) years from the date of the transaction or the end of the business relationship, as mandated by the PMLA, and made available to regulators and law-enforcement on lawful request.

7. Prohibited customers & activities

• Anonymous or fictitious-name accounts, and shell entities without verifiable business;
• Persons on sanctions or watch-lists;
• Activities prohibited under FEMA (including the prohibited LRS list) and other applicable laws.

8. Governance & training

A designated Principal Officer and Designated Director oversee AML/CTF compliance. Employees undergo periodic AML/KYC training, and the framework is independently reviewed and updated to reflect regulatory changes.

9. Contact

AML/KYC queries: Principal Officer, compliance@payzoplus.com · Payzoplus Global Private Limited · Deep Tower, 100/2, Keladevi Road, Vikas Nagar, Mishrilal Nagar, Ganga Nagar, Dewas, Madhya Pradesh 455001, India.