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

1. Introduction

Fundcrest Capital Private Limited ("Company") is a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI). The Company is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes through effective implementation of Know Your Customer (KYC) and Anti-Money Laundering (AML) measures.

This Policy is framed in accordance with the provisions of the Prevention of Money Laundering Act, 2002 (PMLA), the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, and the RBI Master Direction – Know Your Customer (KYC) Direction, 2016, as amended from time to time.

2. Customer Due Diligence (CDD)

The Company undertakes appropriate customer identification and verification procedures before establishing a business relationship and as may be required during the course of such relationship.

The Company may obtain and verify identity, address, beneficial ownership and other information/documents as prescribed under applicable laws and regulatory guidelines.

3. Customer Acceptance Policy

The Company shall:

• Not open or maintain accounts in anonymous or fictitious names.
• Conduct customer due diligence in accordance with applicable regulatory requirements.
• Apply a risk-based approach for customer onboarding and monitoring.
• Reserve the right to reject or discontinue relationships where required KYC information is not available or where regulatory concerns arise.

4. Risk-Based Approach

Customers may be classified into different risk categories based on factors such as customer profile, occupation, geography, nature of business, transaction pattern and other relevant parameters.

Enhanced due diligence may be carried out for higher-risk customers, including Politically Exposed Persons (PEPs) and other categories as prescribed under applicable regulations.

5. Ongoing Monitoring

The Company monitors customer relationships and transactions on a risk-sensitive basis to identify unusual, suspicious or potentially fraudulent activities and to ensure consistency with the customer's profile and source of funds.

6. Reporting and Regulatory Compliance

The Company shall maintain records and report prescribed transactions to the appropriate authorities, including the Financial Intelligence Unit – India (FIU-IND), as required under applicable laws and regulations.

7. Record Retention

Customer identification records, transaction records and related documents shall be maintained for the period prescribed under applicable laws and regulatory guidelines.

8. Employee Training and Internal Controls

The Company maintains internal controls and compliance mechanisms and provides periodic training to relevant employees to ensure effective implementation of AML/KYC requirements. Compliance with AML/KYC obligations is subject to oversight by the Company's designated officials and management.

9. Policy Review

This Policy shall be reviewed periodically and may be amended to align with changes in applicable laws, regulations, RBI directions, and business requirements.