KYC & AML Policy

KYC & AML Policy for Salary Baba

IDF Financial Services Pvt. Ltd. is an RBI-registered NBFC P2P specializing in short-term personal loans.

1. Objective

To prevent misuse of the NBFC P2P's services for money laundering, terrorist financing, and other unlawful activities by implementing robust Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures.

2. Regulatory Framework

• RBI Master Direction – KYC, 2016 (updated as on August 14, 2025).
• Prevention of Money Laundering Act (PMLA), 2002.
• RBI's AML/CFT guidelines and all subsequent circulars and amendments.

3. Customer Acceptance Policy (CAP)

• No account shall be opened anonymously or under fictitious/benami names.
• Mandatory collection of valid identity and address proof before loan disbursal.
• Enhanced due diligence for high-risk customers such as PEPs or NRIs.
• Accounts shall not be opened if the customer refuses to provide required documentation.

4. Customer Identification Procedure (CIP)

• Verification through valid KYC documents such as Aadhaar, PAN, Passport, or Voter ID.
• Biometric authentication via UIDAI where applicable.
• Video KYC permitted for onboarding, subject to regulatory compliance.
• Periodic re-KYC for existing customers based on their risk categorization.

5. Risk Categorization

• Low Risk: Salaried individuals and government employees.
• Medium Risk: Self-employed and small business owners.
• High Risk: Politically Exposed Persons (PEPs), cash-intensive businesses.
• Risk-based KYC updating frequency will apply accordingly.

6. Monitoring of Transactions

• Automated alert systems will identify suspicious activities such as frequent cash deposits or round-tripping.
• Threshold-based reports will be generated for FIU-IND.
• Real-time flagging of high-value or unusual transactions.

7. Record Keeping

• Maintain KYC records for at least 5 years post account closure.
• Transaction records retained for 5 years from the transaction date.
• All data will be securely stored and made available for regulatory inspection when required.

8. Reporting to Authorities

• Suspicious Transaction Reports (STRs) will be filed with FIU-IND within prescribed timelines.
• Cash Transaction Reports (CTRs) will be filed for cash transactions over ₹10 lakh.
• Compliance with RBI's AML/CFT periodic reporting formats will be ensured.

9. Employee Training & Accountability

• Ongoing employee training on KYC/AML procedures, red flags, and escalation processes.
• Standard operating procedures for onboarding, documentation, and verification.
• Defined accountability and escalation matrix for credit and operations teams.

10. Internal Audit & Review

• Quarterly internal audits focused on KYC/AML compliance effectiveness.
• Annual policy review by senior management and the Board.
• Timely corrective measures for any lapses or identified deficiencies.