Know Your Customer (KYC) & Anti-Money Laundering (AML) Policy

1. Preamble

Satsai Finlease Private Limited ("SFPL" / "the Company"), being a Base Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI) under Registration No. B-14.01646, engaged in the business of Payday Loans, EMI-based Loans, Loan Against Property (LAP) and other business loans, recognizes its responsibility to prevent misuse of its financial services for money laundering, terrorist financing and other unlawful activities.

Accordingly, this Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy is formulated in compliance with:

• •RBI Master Direction – Know Your Customer (KYC) Directions, 2016 (as amended from time to time)
• •Prevention of Money Laundering Act, 2002 (PMLA)
• •PML (Maintenance of Records) Rules, 2005
• •RBI Guidelines for NBFCs (Base Layer)
• •FATF Recommendations

This Policy lays down principles, systems, procedures and internal controls to ensure strong customer identification, risk mitigation, due diligence and monitoring.

2. Objectives

The objectives of this Policy are:

• •To prevent the Company from being used knowingly or unknowingly for money laundering or terrorist financing activities.
• •To ensure the Company understands its customers, their financial behavior and associated risks.
• •To promote ethical conduct and transparency in business relationships.
• •To comply with legal and regulatory requirements under RBI and PMLA framework.
• •To define procedures for detection and reporting of suspicious activities.

3. Applicability

This KYC–AML Policy shall prevail over any other internal document, process, circular or instruction. This policy applies to all products and verticals of the Company, whether existing or introduced in the future.

4. Definitions

• •"Aadhaar number" shall have the meaning assigned under the Aadhaar Act, 2016.
• •"Authentication" means Aadhaar authentication as defined under the Aadhaar Act, 2016.
• •"Customer" means a person engaged in a financial transaction or activity with the Company.
• •"Act and Rules" means the Prevention of Money Laundering Act, 2002 and related Rules.
• •"Customer Due Diligence (CDD)" means identifying and verifying the customer and beneficial owner.
• •"Central KYC Records Registry (CKYCR)" means an entity maintaining digital KYC records.
• •"Quikkred" means the digital lending platform operated by Fluxusforge Private Limited.
• •"Designated Director" means the director responsible for AML compliance.
• •"Digital KYC" means electronic customer verification as per RBI guidelines.
• •"Officially Valid Document (OVD)" means passport, driving license, Aadhaar, Voter ID, etc.
• •"Principal Officer" means the officer responsible for AML reporting.
• •"Video based Customer Identification Process (V-CIP)" means video-based customer identification as per RBI norms.

5. Appointment of Principal Officer

The Company shall designate a Principal Officer responsible for AML reporting and coordination with FIU-IND and RBI.

6. Compliance Structure

7. Key Elements of KYC Policy

The KYC Policy consists of:

• •Customer Acceptance Policy (CAP)
• •Customer Identification Procedure (CIP)
• •Customer Due Diligence (CDD)
• •Ongoing Due Diligence
• •Monitoring of Transactions
• •Record Maintenance
• •Reporting Mechanism

8. Customer Acceptance Policy

The Customer Acceptance Policy ensures that:

• •No anonymous or fictitious accounts are opened.
• •Customers are accepted only after identity verification.
• •CDD is mandatory before any transaction.
• •Sanction lists are screened.

Safeguards shall not inconvenience genuine customers.

9. Customer Identification Procedure (CIP)

Customer identity shall be verified using reliable documents and information.

KYC may be conducted through:

• •Physical Verification
• •Video KYC (V-CIP)
• •Digital KYC

OVD and PAN verification is mandatory.

10. Customer Due Diligence (CDD)

CDD includes:

• •Identity verification
• •Address proof
• •Source of funds
• •Purpose of relationship

11. Ongoing Due Diligence

Includes:

• •Periodic KYC updates
• •Transaction review
• •Monitoring unusual activity

12. Transaction Monitoring

Continuous monitoring of customer transactions is required.

Large or unusual transactions are closely reviewed.

Suspicious transactions may include:

• •Unusual repayment behavior
• •Structuring of transactions
• •Sudden closures using cash

13. Reporting to Financial Intelligence Unit-India

The Company shall report cash and suspicious transactions to FIU-IND as per law.

Reports shall be submitted by the 15th of the succeeding month.

14. Record Management

Records shall be retained for at least 5 years after termination of relationship.

15. Reporting Obligations

The Company shall report:

• •STR
• •CTR
• •NTR

All reports shall be filed through the Principal Officer.

16. Data Confidentiality

Customer information shall be kept confidential and used only for lawful purposes.

17. Risk Assessment

• •Annual ML/TF risk assessment shall be conducted.
• •Risk shall be documented and reviewed by the Board.
• •Risk Based Approach (RBA) shall be followed.

18. Review & Amendment

This policy shall be reviewed annually or upon regulatory changes.