Policy Name:
“Know Your Customer (KYC) & Anti-Money Laundering (AML) Compliance Policy”
(As per Reserve Bank of India Guidelines)
In Compliance With:
- Reserve Bank of India (RBI) Master Direction on KYC, 2016 (updated)
- Prevention of Money Laundering Act (PMLA), 2002
- RBI Guidelines on Regulation of Payment Aggregators and Payment Gateways
1. POLICY STATEMENT
Entellus Apparel Private Limited (“the Company”) is committed to complying with the Know Your Customer (KYC) and Anti-Money Laundering (AML) guidelines issued by the Reserve Bank of India (RBI). This policy establishes procedures for customer identification, verification, and ongoing monitoring to prevent financial crimes, including money laundering and terrorist financing.
2. PURPOSE
This policy aims to:
- Establish customer identification and verification procedures
- Detect and report suspicious transactions
- Comply with the Prevention of Money Laundering Act (PMLA), 2002 and RBI guidelines
- Maintain records as required by law
3. SCOPE
This policy applies to:
- All customers (individuals and entities) using our e-commerce platform
- All financial transactions conducted through https://entellusapparel.com
- All employees and third parties handling customer information
4. CUSTOMER IDENTIFICATION PROCEDURE (CIP)
4.1 For Individual Customers:
- Mandatory Documents:
- PAN Card (as per RBI guidelines for all transactions)
- Officially Valid Document (OVD) for address proof:
• Aadhaar Card (with masked details)
• Passport
• Voter ID
• Driving License
• Utility bills (not older than 3 months)
4.2 For Business Entities:
- Certificate of Incorporation
- GST Registration Certificate
- PAN of the entity
- Board Resolution for authorized signatories
- KYC documents of all beneficial owners holding more than 25% shares
5. RISK-BASED APPROACH
Customers are categorized based on risk:
Risk Category | Criteria | Verification Level |
---|---|---|
Low Risk | Transactions < ₹10,000 | Basic KYC |
Medium Risk | Transactions ₹10,000-₹50,000 | Full KYC |
High Risk | Transactions > ₹50,000 or suspicious patterns | Enhanced Due Diligence |
6. ONGOING MONITORING
- Regular review of customer transactions
- Automated system alerts for unusual activity
- Annual KYC updates for high-risk customers
7. RECORD KEEPING
- All KYC records maintained for minimum 5 years from termination of business relationship
- Digital copies stored in secure, encrypted format
8. SUSPICIOUS TRANSACTION REPORTING
- Designated Compliance Officer to report suspicious transactions to Financial Intelligence Unit (FIU-IND)
- STRs filed within 7 working days of suspicion
9. EMPLOYEE TRAINING
- Mandatory AML training for all relevant employees
- Quarterly refresher courses
10. POLICY REVIEW
This policy will be reviewed:
- Annually
- Whenever there are changes in RBI regulations
11. CONTACT INFORMATION
For KYC/AML related queries:
Compliance Officer
Entellus Apparel Private Limited
N16, 2nd Floor, Site-5, Kasna Industrial Area,
Greater Noida, Gautam Buddha Nagar,
Uttar Pradesh, India – 201306
Email: info@entellusapparel.com
Annexures:
- List of Officially Valid Documents (OVDs)
- KYC Update Form
- Suspicious Transaction Report (STR) Format
Note: This policy supersedes all previous versions and shall be read in conjunction with RBI’s Master Direction on KYC dated February 25, 2016 (as amended from time to time).