The objective of this AML & Compliance Policy is to ensure A2Z Suvidhaa complies with Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) requirements, fraud prevention standards, and suspicious transaction escalation processes as a Business Correspondent (BC), in line with applicable regulatory guidelines.
2. Scope
This policy applies to all BC agents, merchants, employees, and operations involving customer transactions conducted through A2Z Suvidhaa systems.
3. Policy Guidelines
3.1 Know Your Customer (KYC) Compliance
All customers must undergo KYC verification for transactions above ₹10,000 or as required by regulatory guidelines.
Acceptable KYC documents include Aadhaar, PAN, Voter ID, or other government-issued IDs.
Agents must verify customer identity in-person or via digital means (e.g., Aadhaar OTP) before processing transactions.
Retain KYC records securely for 5 years, as per the Information Security Policy.
3.2 Anti-Money Laundering (AML) Process
Risk-Based Approach:Categorize customers into low, medium, and high-risk based on transaction patterns, location, and profile (e.g., high-risk for frequent large transactions, politically exposed persons).
Customer Due Diligence (CDD):Conduct basic CDD for all customers (e.g., KYC verification). Perform Enhanced Due Diligence (EDD) for high-risk customers, including source of funds verification and additional ID checks.
Transaction Monitoring:Use A2Z Suvidhaa systems to monitor transactions for AML red flags (e.g., multiple high-value transactions, rapid fund movements, transactions inconsistent with customer profile).
3.3 Fraud Prevention
Agents must report any suspicious customer behavior (e.g., fake currency, forged documents) to the central team (support@a2zsuvidhaa.com) within 2 hours.
Use dual verification for transactions above ₹50,000 via A2Z Suvidhaa systems.
Blacklist customers or merchants involved in fraud, reporting them to relevant partners and authorities as needed.
3.4 Suspicious Transaction Escalation
Identification: Agents must flag suspicious transactions (e.g., transactions >₹50,000 without clear purpose, frequent small transactions to avoid KYC, unusual cross-border activity).
Reporting:Escalate suspicious transactions to the Compliance Team (compliance@a2zsuvidhaa.com) within 4 hours. The Compliance Team will investigate and report to relevant partners and regulators within 7 days, as per regulatory guidelines.
Record Keeping: Maintain a log of all suspicious transactions and escalations for 5 years, accessible for audits.
3.5 Due Diligence for BC Agents
Conduct KYC verification for all BC agents during onboarding (e.g., Aadhaar, PAN, address proof), as per the BC Merchant Onboarding and Usage Policy.
Perform background checks for agents (e.g., criminal record check, reference verification).
Monitor agent performance monthly for signs of fraud or non-compliance (e.g., delayed deposits, mismatched records).
4. Training and Communication
Train all agents on AML, KYC, fraud prevention, and escalation procedures during onboarding and annually.
Communicate this policy to agents via email, WhatsApp, the A2Z Suvidhaa agent portal (https://partners.a2zsuvidhaa.com), and the public website (https://www.a2zsuvidhaa.com/compliance).
Agents must sign an acknowledgment form confirming understanding of this policy.
5. Compliance Monitoring and Audits
Conduct random audits of 10 agents monthly to verify KYC compliance, transaction records, and escalation processes.
The Compliance Team will review transaction data weekly for AML red flags, escalating as needed.
Non-compliance by agents (e.g., failing to report suspicious transactions, bypassing KYC) will result in suspension, retraining, or termination.
6. Contact Information
For questions about this policy or to report concerns: