KYC & AML Policy

Harshreejee Finance & Leasing Company Private Limited

Preamble

Harshreejee Finance & Leasing Company Private Limited (“the Company”) is committed to preventing its products and services from being used, intentionally or unintentionally, for money laundering or terrorist financing.

This Policy is prepared in accordance with the Reserve Bank of India (RBI) guidelines, the Prevention of Money Laundering Act (PMLA), 2002, and other applicable regulations. It establishes procedures for Know Your Customer (KYC) and Anti-Money Laundering (AML) for individual borrowers availing payday loans.

1. Objectives

• Prevent misuse of services for money laundering or terrorist financing
• Ensure compliance with RBI guidelines and PMLA
• Establish customer identification, verification, and monitoring procedures

2. Definition of Customer

A “Customer” refers to any individual who applies for or maintains a payday loan account with the Company, including the borrower.

3. Customer Acceptance Policy (CAP)

• No accounts in fictitious, anonymous, or benami names
• Customers categorized into low, medium, and high-risk profiles
• Mandatory identity and address verification before approval
• Ensure genuine customers are not denied services

4. Customer Identification Procedures (CIP)

• Verify identity using reliable and independent documents
• Understand purpose and nature of the loan
• Apply enhanced due diligence for high-risk customers
• Maintain records of identity and address proof

5. KYC Document Requirements

Proof of Identity (any two, self-attested)

• Passport
• PAN Card
• Voter ID
• Driving License
• Aadhaar

Proof of Address (any one, self-attested)

• Passport
• Electricity Bill (not older than 3 months)
• Telephone Bill (not older than 3 months)
• Bank Statement (not older than 3 months)
• Aadhaar
• Rent Agreement
• Water Bill
• Wi-Fi Bill

Additional Documents

• Salary slips (last 3 months)
• Bank statements (last 6 months)

6. Monitoring and Reporting

• Transactions monitored based on risk profile
• Unusual or suspicious transactions flagged
• Periodic review of risk categorization
• Suspicious transactions reported to FIU-IND

7. Risk Management

• Board oversight on KYC/AML compliance
• Internal audits and compliance checks
• Employee training on AML procedures

8. Customer Education

Customers are informed about KYC requirements and their purpose through communication and support channels.

9. Technology Risk

The Company evaluates risks related to digital lending and online platforms to prevent misuse.

10. Principal Officer

A Principal Officer is appointed to monitor compliance and report suspicious transactions to the Financial Intelligence Unit – India (FIU-IND).

11. Record Maintenance

• Maintain transaction records as per PMLA rules
• Preserve customer data for at least 10 years
• Ensure records are accessible for regulatory authorities

12. Policy Updates

The Board may update this Policy to align with regulatory or business changes.

13. Reporting to FIU-IND

Director, FIU-IND
Financial Intelligence Unit – India
6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110021
Website: http://fiuindia.gov.in

14. Approval & Adoption

This KYC & AML Policy is approved by the Board of Directors of Harshreejee Finance & Leasing Company Private Limited and is effective from __________.

Board of Directors
Harshreejee Finance & Leasing Company Private Limited