1. Introduction

At Payomatix Private Limited (“Payomatix,” “we,” “our,” or “us”), we are committed to maintaining the highest standards of integrity and ensuring full compliance with applicable Anti-Money Laundering (AML) laws and Counter-Terrorism Financing (CTF) regulations.

This AML Policy outlines our commitment to:

• Preventing the misuse of Payomatix’s services for money laundering, terrorist financing, and other financial crimes.
• Ensuring compliance with relevant laws, including:
  • The Prevention of Money Laundering Act, 2002 (PMLA, India)
  • Financial Intelligence Unit – India (FIU-IND)
  • Reserve Bank of India (RBI) Guidelines
  • Financial Action Task Force (FATF) Recommendations
  • General Data Protection Regulation (GDPR) (where applicable)

This policy applies to all employees, merchants, partners, and service providers associated with Payomatix.

2. Purpose and Objectives

The purpose of this AML Policy is to:

• Establish a framework for identifying, preventing, and reporting suspicious activities.
• Implement a robust customer due diligence (CDD) process to assess customer risk.
• Outline the roles and responsibilities of Payomatix’s personnel in ensuring AML compliance.
• Ensure timely reporting of suspicious transactions to relevant authorities.

3. Roles and Responsibilities

3.1 Board of Directors and Senior Management

The Board of Directors is responsible for:

• Establishing and endorsing Payomatix’s AML framework.
• Providing oversight and ensuring sufficient resources for AML compliance.

3.2 Compliance Officer (MLRO – Money Laundering Reporting Officer)

The Compliance Officer is responsible for:

• Overseeing the implementation of the AML policy.
• Ensuring adherence to RBI, FIU-IND, and FATF guidelines.
• Conducting risk assessments, audits, and policy reviews.
• Filing Suspicious Activity Reports (SARs) and Threshold Transaction Reports (TTRs) with the FIU-IND.
• Ensuring staff receive regular AML training.

3.3 Employees

All Payomatix employees are responsible for:

• Identifying potential money laundering risks.
• Reporting suspicious activities to the Compliance Officer.
• Following AML procedures during customer interactions and transactions.

4. Customer Due Diligence (CDD) and Know Your Customer (KYC) Procedures

4.1 Customer Identification Process (CIP)

All customers must undergo identity verification before accessing Payomatix services. The following documentation is required:

✔ Individuals: PAN, Aadhaar, Passport, or Voter ID.
✔ Businesses/Corporates: GSTIN, Incorporation Certificate, Tax Identification Number, and ownership details.
✔ Proof of Address: Utility bills, bank statements, or rental agreements.

4.2 Risk-Based Approach (RBA)

Payomatix applies a risk-based approach to assess customer profiles and determine the level of due diligence required:

• Low-Risk Customers: Basic KYC procedures.
• Medium-Risk Customers: Enhanced monitoring and periodic reviews.
• High-Risk Customers: Subject to Enhanced Due Diligence (EDD).

4.3 Enhanced Due Diligence (EDD)

EDD is required for customers identified as high-risk, including:

• Politically Exposed Persons (PEPs)
• Non-profit organizations (NPOs) operating in high-risk sectors.
• Customers involved in high-value or complex transactions.

EDD includes:
✔ Additional documentation to verify source of funds.
✔ Enhanced transaction monitoring and periodic reviews.

5. Ongoing Monitoring of Transactions

Payomatix uses AI-powered transaction monitoring systems to identify unusual or suspicious activities in real-time.

5.1 Red Flag Indicators for Suspicious Transactions

The following activities will trigger alerts for further investigation:

✔ Large or frequent high-value transactions inconsistent with customer profiles.
✔ Multiple transactions below reporting thresholds to evade detection.
✔ Sudden spikes in transaction volume or unexplained fund transfers.
✔ Transactions involving high-risk jurisdictions or tax havens.
✔ Customers who provide incomplete or inconsistent information.

5.2 Transaction Review Process

• All flagged transactions are reviewed by the Compliance Officer.
• Where necessary, suspicious transactions are reported to the Financial Intelligence Unit – India (FIU-IND).

6. Reporting Obligations

6.1 Suspicious Activity Reports (SARs)

Payomatix will submit a SAR if any transaction or customer behavior raises suspicion of money laundering or terrorism financing.

✔ SARs must be filed with the FIU-IND within 7 calendar days of detection.
✔ Details of the transaction, customer profile, and investigation must be documented.

6.2 Threshold Transaction Reports (TTRs)

• Transactions involving ₹10 lakh (₹1 million) or above must be reported to FIU-IND.
• Cross-border wire transfers exceeding ₹5 lakh must also be reported.

6.3 Cash Transaction Reports (CTRs)

All cash transactions above ₹10 lakh in a single day will be reported.

7. Training & Awareness

To ensure compliance across the organization, Payomatix will:

• Conduct mandatory AML training programs for all employees.
• Provide specialized training for staff handling high-risk transactions or KYC procedures.
• Conduct annual refresher courses to update employees on emerging AML threats.

8. Record Keeping & Documentation

Payomatix maintains comprehensive records to comply with RBI, PMLA, and FIU-IND guidelines.

✔ Customer identification records are retained for 5 years after account closure.
✔ Transaction records are retained for a minimum of 7 years.
✔ All SARs, CTRs, and TTRs are securely archived for regulatory audits.

Records are stored securely with AES-256 encryption to protect sensitive data.

9. Internal Audits & Policy Review

✔ Payomatix conducts annual AML audits to assess the effectiveness of its policies and controls.
✔ The AML policy is reviewed annually or upon significant regulatory changes.
✔ Audit results are documented, and improvements are implemented as needed.

10. Non-Compliance & Penalties

Failure to comply with this AML policy may result in:

• Account suspension or termination.
• Legal penalties as per PMLA, 2002 and RBI guidelines.
• Disciplinary action for employees found violating AML procedures.

11. Conclusion

Payomatix is committed to ensuring its services are never used to facilitate money laundering, terrorist financing, or illegal activities. By implementing robust AML procedures, we aim to protect our platform, customers, and financial ecosystem from financial crime.

12. Contact Information

For AML-related concerns or reporting suspicious activity, contact:

📧 Email: compliance@payomatix.com

This AML policy applies to all employees, merchants, and partners. By using Payomatix’s services, you acknowledge your responsibility to comply with these guidelines.