Anti-Money Laundering (AML) Policy
Effective Date: 01 Dec 2024
STAAR PAYOUT PRIVATE LIMITED (“Company,” “we,” “our,” or “us”) is committed to complying with India’s laws and regulations to prevent money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our practices to detect, deter, and report suspicious activities in line with applicable Indian regulations.
1. Purpose
The purpose of this policy is to:
- Ensure compliance with India’s anti-money laundering laws, including the Prevention of Money Laundering Act, 2002 (PMLA).
- Establish a framework for identifying, monitoring, and reporting suspicious transactions.
- Protect the integrity of our services from misuse by criminal activities.
2. Scope
This policy applies to:
- All services provided by the Company within India.
- All employees, contractors, and clients using our services, including API integrations for pay-in (collections) and payout (payments).
3. Key AML Measures
a. Customer Due Diligence (CDD)
- Know Your Customer (KYC): All clients must complete the KYC process before onboarding. This includes:
- Submission of valid identification documents (e.g., Aadhaar, PAN).
- Verification of the client’s identity and business details.
- Enhanced Due Diligence (EDD): Additional checks for high-risk clients or transactions.
b. Monitoring Transactions
- Transactions are monitored for patterns indicative of suspicious activity, such as:
- Large or unusual transactions inconsistent with a client’s profile.
- Repeated small transactions aimed at evading reporting thresholds.
- Automated tools and manual reviews are used to identify red flags.
c. Record Keeping
- Records of transactions, KYC documents, and reports are retained for 5 years, as required under the PMLA.
- All records are securely stored to ensure confidentiality.
4. Reporting Obligations
a. Suspicious Transaction Reports (STRs)
- Any suspicious activities or transactions are reported to the Financial Intelligence Unit-India (FIU-IND) without delay.
b. Threshold Reporting
- Transactions above the prescribed threshold (e.g., ₹10 lakh) are reported as per RBI guidelines.
c. Employee Responsibility
- Employees must report suspicious activity to the designated AML officer immediately.
5. AML Compliance Officer
- The Company appoints a dedicated AML Compliance Officer responsible for:
- Overseeing AML compliance efforts.
- Ensuring proper implementation of this policy.
- Liaising with regulatory authorities and managing audits.
6. Training and Awareness
- Employees are trained annually on AML regulations and their responsibilities under this policy.
- Training includes recognizing suspicious activity and understanding reporting obligations.
7. Non-Compliance and Penalties
a. Client Non-Compliance
- Failure to complete the KYC process or engaging in suspicious activities may result in:
- Suspension or termination of services.
- Reporting to relevant authorities.
b. Internal Non-Compliance
- Employees or contractors found violating this policy will face disciplinary action, including termination.
8. Updates to This Policy
The Company reserves the right to update this policy periodically to reflect changes in Indian laws or operational requirements. Updates will be communicated via email or posted on our website.
9. Contact Us
For questions or concerns regarding this AML Policy, please contact us:
STAAR PAYOUT PRIVATE LIMITED
A-1/2, First Floor, Shakti Nagar Extension, Ashok Vihar, North West Delhi, Delhi, Delhi, India, 110052