Policy On ‘ Know Your Customer ’ Guidelines And ‘Anti-Money Laundering’ Standards Introduction:

The Reserve Bank of India (“RBI”) has issued Master Direction on Issuance and Operation of Prepaid Payment Instruments (“Direction”) which governs the functioning of the companies issuing prepaid payment instruments (“PPI”). Among other things contained in the Direction, RBI requires adoption of ‘Know Your Customer’ (“KYC”) guidelines - Anti Money Laundering (AML), as defined in the PML Act (defined hereinafter), thereby setting standards for prevention of money laundering activities and corporate practices while dealing with their customers from time to time, by the entities issuing PPI and their agents. These guidelines incorporate the recommendations made by the Financial Action Task Force on anti-money laundering standards and combating financing of terrorism as these are being used as the International Benchmark for framing the stated policies, by the regulatory authorities.

In view of the same, Pentabit has adopted a robust policy frame work on KYC and AML measures in line with the prescribed RBI guidelines(“KYC-AML Policy” or this “Policy”). The Company shall adopt all the best practices prescribed by RBI from time to time and shall make appropriate modifications to the Policy, if necessary, to conform to the standards so prescribed. The contents of the Policy shall always be read in tandem/auto- corrected with the changes/modifications which shall be advised by RBI from time to time.

Objective :

The objective of the Policy is to prevent the Company from being used, intentionally or unintentionally, by criminal elements for money laundering activities or terrorist financing activities. KYC procedures shall also enable the Company to know and understand its Customers (defined hereinafter) and its financial dealings better which in turn will help it to manage its risks prudently. Senior Management includes Directors of the Company. Responsibility will be explicitly allocated within the Company for ensuring that the policies and procedures as applicable to Company are implemented effectively.

This Policy includes 7 (seven) key elements:

1. Customer Acceptance Policy (“CAP”);
2. Customer Identification Procedures (“CIP”);
3. Monitoring of Transactions;
4. Risk Management.
5. Customer Grievance/Dispute Management
6. PPI Interoperability Policies
7. Reporting to Financial Intelligence Unit – India

Applicability

It may be noted that this Policy as stated in this document shall prevail over anything else contained in any other document, process, circular and / or instruction that has been issued by RFPL in this regard and shall be applicable to all verticals and products of the Company, whether existing or rolled out in future.