Anti-Money Laundering (AML) Policy – India

  1. Introduction

Sharsid is committed to conducting its business in full compliance with the laws of India, including the Prevention of Money Laundering Act, 2002 (PMLA), the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, and other applicable regulations issued by the Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI), and the Financial Intelligence Unit – India (FIU-IND).

Our objective is to ensure that the Company’s products and services are not misused for money laundering, terrorist financing, or any other illegal activity. This policy reflects our commitment to ethical business conduct, regulatory compliance, and the protection of our clients, employees, and stakeholders.

  1. Purpose

The purpose of this Policy is to:

  • Prevent the use of the Company’s services for money laundering or terrorist financing.
  • Establish a framework for detecting and reporting suspicious activities.
  • Comply with Indian AML/KYC regulations and international standards, including Financial Action Task Force (FATF) recommendations.
  • Promote a culture of integrity, transparency, and vigilance within the organization.
  1. Scope

This Policy applies to:

  • All employees, directors, officers, and representatives of [Your Company Name] in India.
  • Contractors, consultants, agents, intermediaries, and third-party service providers.
  • All customers, vendors, and business partners engaging with the Company in India.
  1. Regulatory Framework

The Company adheres to the following regulations and guidelines:

  • Prevention of Money Laundering Act, 2002 and amendments.
  • PML Rules, 2005 (Maintenance of Records).
  • RBI Master Direction – Know Your Customer (KYC) Direction, 2016 (as amended).
  • SEBI AML Guidelines (where applicable).
  • FATF Recommendations and other relevant international best practices.
  1. AML Measures and Controls

5.1 Customer Due Diligence (CDD)

Before establishing a business relationship, we will:

  • Verify the identity of the customer using valid government-issued identification (Aadhaar, PAN, Passport, Voter ID, etc.).
  • Identify and verify the beneficial owner of the entity (25% or more ownership in companies, 15% or more in partnerships/unincorporated bodies).
  • Conduct PEP checks and screen against UN, RBI, SEBI, and domestic sanction lists.
  • Apply Enhanced Due Diligence (EDD) for high-risk customers such as foreign PEPs, high-cash-based businesses, or customers from high-risk jurisdictions.

5.2 Ongoing Monitoring

  • Monitor transactions to ensure they are consistent with the customer’s profile.
  • Pay special attention to large, complex, or unusual transactions without a clear economic purpose.

5.3 Record-Keeping

  • Maintain KYC records, transaction history, and due diligence information for at least 5 years after the end of the business relationship or transaction.

5.4 Regulatory Reporting

  • Cash Transaction Reports (CTR): Report cash transactions above ₹10 lakh (or equivalent in foreign currency) to FIU-IND.
  • Suspicious Transaction Reports (STR): File STRs within 7 working days of detecting suspicious activity, regardless of the amount.
  1. Red Flags – Suspicious Indicators

Employees must remain alert to potential warning signs, such as:

  • Unwillingness to provide complete KYC documentation.
  • Inconsistencies between declared business activities and actual transactions.
  • Multiple accounts with unexplained movement of funds.
  • Transactions involving high-risk jurisdictions or sanctioned individuals/entities.
  • Unusual use of third parties to make or receive payments.
  1. Employee Training & Awareness
  • All employees receive mandatory AML/KYC training upon joining and at regular intervals thereafter.
  • Specialized training is provided to employees handling high-risk customer segments or transaction monitoring.
  1. Whistleblowing & Confidential Reporting
  • Employees and stakeholders can report suspicious activities through the Company’s confidential whistleblowing channel.
  • The identity of whistleblowers will be kept strictly confidential, and no retaliation will be tolerated.
  1. Disciplinary Actions
  • Non-compliance with this Policy may result in disciplinary measures, including suspension, termination, and possible legal action.
  • Third parties found in breach of this Policy may face immediate contract termination.
  1. Policy Review & Approval

This Policy is reviewed annually or earlier if there are significant changes in applicable laws or regulations.
It has been approved by the Board of Directors of Sharsid, and all employees are required to comply fully.

Last Updated: 10/8/2025