KYC and AML Policy

Status of this document

Published in draft. This KYC and AML Policy sets out the standards we hold ourselves to and follow in practice today. It has not yet been formally adopted by the Board of Directors, and this page will say so until it has. We publish it in draft rather than not at all, because a borrower is better served by knowing our position than by an empty page.

Adopted under the Reserve Bank of India’s Master Direction on Know Your Customer and the Prevention of Money Laundering Act, 2002.

Not yet confirmed. The date on which the Board approved this policy is published here once that approval is recorded. Until then we do not print one.

1. Why we ask

Every regulated lender in India is required to establish who its customer is before opening an account. This is not paperwork for its own sake, it is how the financial system keeps proceeds of crime out of legitimate credit, and it protects honest borrowers from having their identity used by someone else.

2. Customer acceptance

• No account is opened in an anonymous or fictitious name.
• No account is opened where we are unable to verify identity and address, or where the customer does not co-operate with the verification process.
• We screen against the lists of individuals and entities notified by the United Nations Security Council and circulated by the Reserve Bank of India.
• Customers are categorised as low, medium or high risk, and the extent of due diligence is calibrated accordingly.
• We do not decline a facility solely because a customer belongs to a particular section of society, and we do not use KYC as a pretext for doing so.

3. Documents we accept

Any one of the following Officially Valid Documents establishes both identity and address:

• Passport
• Driving licence
• Voter’s identity card issued by the Election Commission of India
• Aadhaar, proof of possession, with the number redacted where required
• Job card issued by NREGA, signed by a State Government officer
• Letter issued by the National Population Register containing name and address

PAN is required in addition, in accordance with income tax law.

For a company

• Certificate of incorporation and Memorandum and Articles of Association
• Board resolution authorising the borrowing and naming the authorised signatories
• PAN of the company
• KYC of the beneficial owners, directors and authorised signatories

For a partnership or LLP

• Registration certificate and partnership or LLP deed
• PAN of the firm
• KYC of partners and authorised signatories

4. Beneficial ownership

For any customer other than an individual, we identify the beneficial owner, the natural person who ultimately owns or controls the customer, and verify their identity, applying the thresholds prescribed under the Prevention of Money Laundering Rules.

5. Ongoing due diligence and periodic updation

KYC records are updated periodically: every ten years for low-risk customers, every eight years for medium risk and every two years for high risk, or earlier if there is a material change. We monitor transactions for consistency with the customer’s known profile and source of funds.

6. Record keeping and reporting

• Records of identity and of transactions are maintained for the period prescribed by law, generally not less than five years from the date of the transaction or the closure of the account, as applicable.
• Cash Transaction Reports, Suspicious Transaction Reports and other prescribed reports are filed with the Financial Intelligence Unit-India within the required timelines.
• Where a Suspicious Transaction Report is filed, we are prohibited by law from informing the customer. This is not discourtesy; it is a statutory requirement.

7. Principal Officer and Designated Director

Not yet confirmed. This section is blank in the source document. The names and contact details of our Principal Officer and Designated Director are published here once the Board has appointed them and the appointments have been confirmed. Until then we do not print a name.

8. Confidentiality

Information collected for KYC purposes is treated as confidential and is used only for the purposes for which it was collected. It is not shared for cross-selling or with any third party except as permitted by law. See our Privacy Policy.

9. Training and review

Staff dealing with customers are trained on this policy and on the identification of suspicious transactions. The policy is reviewed by the Board at least annually.