The primary objective is to prevent the Company from being used, intentionally or unintentionally, by criminal elements for money laundering activities or terrorist financing activities.

• To lay down explicit criteria for acceptance of customers.
• To establish procedures to verify the bona-fide identification of individuals/non individuals for opening of accounts.
• To establish processes and procedures to monitor high value transactions and/or transactions of a suspicious nature in accounts.
• To develop measures for conducting due diligence in respect of customers and reporting of such transactions.

For the purpose of Purvaja Investments Pvt Ltd KYC policy a ‘Customer’ means a person defined under the KYC policy of the RBI and any amendment from time to time by the RBI which are at present as follows:

• A person or entity that maintains an account and/or has a business relationship with the Company;
• One on whose behalf the account is maintained (i.e. the beneficial owner)
• Any other person or entity connected with a financial transaction which can pose significant reputation or other risks to the Company, for example, a wire transfer or issue of high value demand draft as a single transaction.

The guidelines for Customer Acceptance Policy (CAP) for the Company are as follows:

• No account may be opened in an anonymous or fictitious/ benami name(s).
• The Company shall classify customers into various risk categories and based on risk perception decide on the acceptance criteria for each customer category.
• Accept customers only after verifying their identity as laid down in the customer identification procedures.
• While carrying out due diligence the Company will ensure that the procedures adopted will not result in the denial of services to genuine customers.
• For the purpose of risk categorisation of customers, the Company shall obtain the relevant information from the customer at the time of account opening.

Customer identification means identifying the customer and verifying his/her identity by using reliable, independent source documents, data or information Puvaja Investments Pvt Ltd shall obtain sufficient information necessary to verify the identity of each new customer along with brief details of its promoters and management, whether regular or occasional and the purpose of the intended nature of the business relationship. The requirement as mentioned herein may be moderated according to the risk perception; for example, in the case of a public listed company it will not be necessary to identify all the shareholders.

Proof of Identity and Proof of Address in case of Individuals

Proof of Identity:
One Self Attested copy of any one of the following: 

1. Passport
2. Photo Pan Card
3. Voter’s ID
4. Driving License
5. ID card issued by any central/state govt.
6. Letter issued by Unique Identification Authority of India (UIDAI) containing details of name, address and Aadhaar number.

Proof of Address:
One Self Attested copy of any one of the following:

1. Passport
2. Telephone bill (not later than three month)
3. Electricity bill (not later than three month)
4. Bank Account statement (not later than one month)
5. Letter issued by Unique Identification Authority of India (UIDAI) containing details of name, address and Aadhaar number.

Proof of Identity and Principal place of Business in case of non-Individuals
1. Company
A certified true copy of all the below documents, duly signed and stamped by a Company Secretary or a Director of the applicant company:

1. Certificate of Incorporation and Certificate of Commencement of Business (if applicable)
2. Memorandum and Articles of Association
3. PAN card
4. List of Directors
5. Latest shareholding structure
6. Resolution of the Board of Directors to borrow the loan amount u/s 179 of the Companies Act, 2013.

If any of the above documents are in any language other than English, it must be translated into English along with a certificate from a translator / notary public.
1. Partnership Firms:

1. Registration certificate, if registered
2. Copy of PAN card. of firm & partners
3. Partnership deed
4. Power of Attorney granted to a partner or an employee of the firm to transact business on its behalf
5. Any officially valid document identifying the partners and the persons holding the Power of Attorney and their addresses.
6. List of partners along with addresses.
7. PAN Card of partners.

2. Trust & Foundations:

1. Certificate of registration, if registered.
2. Copy of PAN Card of Trust.
3. Trust Deed
4. Power of Attorney granted to transact business on its behalf
5. Any officially valid document to identify the trustees, settlers, beneficiaries and those holding Power of Attorney, founders/ managers/ directors and their addresses.
6. PAN Card of trustee.
7. List of trustees

Other mandatory documents are mentioned in Annexure

Important: Puvaja Investments Pvt Ltd will follow clear NBFC guidelines on the Customer Identification Procedures to be carried out at different stages, i.e. while establishing a relationship; carrying out a financial transaction or when Puvaja Investments Pvt Ltd has a doubt about the authenticity/veracity or the adequacy of the previously obtained customer identification data. Customer identification means identifying the customer and verifying his/ her identity by using reliable, independent source documents, data or information. Puvaja Investments Pvt Ltd will obtain sufficient information necessary to establish, to its satisfaction, the identity of each new customer, whether regular or occasional and the purpose of the intended nature of relationship. Being satisfied means that Puvaja Investments Pvt Ltd must be able to satisfy the competent authorities that due diligence was observed based on the risk profile of the customer in compliance with the extant guidelines in place. Besides risk perception, the nature of information/documents required would also depend on the type of customer (individual, corporate etc). For customers that are natural persons, Puvaja Investments Pvt Ltd will obtain sufficient identification data to verify the identity of the customer, his address/location, and also his recent photograph. For customers that are legal persons or entities, Puvaja Investments Pvt Ltd will:

• verify the legal status of the legal person/ entity through proper and relevant documents;
• verify that any person purporting to act on behalf of the legal person/entity is so authorized and identify and verify the identity of that person; and
• understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person

Where Puvaja Investments Pvt Ltd is unable to apply appropriate KYC measures due to non-furnishing of information and /or non-cooperation by the customer, Puvaja Investments Pvt Ltd may consider closing the account or terminating the business relationship after issuing due notice to the customer explaining the reasons for taking such a decision.

Monitoring of transactions will be conducted taking into consideration the risk profile of the account. Puvaja Investments Pvt Ltd shall make endeavours to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified, Special attention will be paid to all complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose.

Background of the customer, country of origin, sources of funds, the type of transactions involved and other risk factors shall determine the extent of monitoring. Higher risk accounts shall be subjected to intensify monitoring. Puvaja Investments Pvt Ltd shall carry out the periodic review of risk categorization of transactions/customers and the need for applying enhanced due diligence measures at a periodicity of not less than once in six months.

Puvaja Investments Pvt Ltd shall explore the possibility of validating the new accounts opening application with various watch lists available in the public domain, including the RBI watch list. After due diligence, any transactions of a suspicious nature will be duly reported by a principal officer to Director, Financial Intelligence Unit- India (FIU-IND).

To ensure monitoring and reporting of all transactions and sharing of information as required under the law for KYC, the Board may nominate any Director or authorized any other officer(s) to be designated as Puvaja Investments Pvt Ltd’s Principal Officer with respect to KYC/ AML/ CFT.

The Board of Directors of the Company ensures that an effective KYC programme is put in place by establishing appropriate procedures and ensuring their effective implementation. It will cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility would be explicitly allocated within the Company for ensuring that the Company’s policies and procedures are implemented effectively. The Company may, in consultation with its board, devise procedures for creating Risk Profiles of its existing and new customers and apply various Anti Money Laundering measures keeping in view the risks involved in a transaction, account or business relationship. The Company’s internal audit and compliance functions have an important role in evaluating and ensuring adherence to the KYC policies and procedures. As a general rule, the compliance function provides an independent evaluation of the Company’s own policies and procedures, including legal and regulatory requirements. Concurrent/ internal auditors should specifically check and verify the application of KYC procedures and comment on the lapses observed in this regard. The compliance in this regard may be put up before the Audit Committee of the Board on quarterly intervals.

The Company has an ongoing employee training programme so that the members of the staff are adequately trained in KYC procedures. Training requirements will have different focuses for frontline staff, compliance staff and staff dealing with new customers. It is crucial that all those concerned fully understand the rationale behind the KYC policies and implement them consistently.

Customer Education:

Implementation of KYC procedures requires the Company to demand certain information from customers which may be of a personal nature or which has hitherto never been called for. This can sometimes lead to a lot of questioning by the customer as to the motive and purpose of collecting such information. The Company will prepare specific literature/ pamphlets etc. so as to educate the customer on the objectives of the KYC programme. The front desk staff needs to be specially trained to handle such situations while dealing with customers.

Introduction of New Technologies

The Company will pay special attention to any money laundering threats that may arise from new or developing technologies including internet transactions that might favour anonymity, and take measures, if needed, to prevent their use in money laundering schemes.

Employees Training/Hiring of Employees:

Puvaja Investments Pvt Ltd shall have an ongoing employee training programme so that the team members are adequately trained in KYC/ AML/ CFT procedures. Training requirements shall have different focuses for frontline staff, compliance staff and officer/staff dealing with the new customers. It is crucial that all those concerned fully understand the rationale behind the KYC policies and implement them.

Appointment of Principal Officer

1. To ensure the monitoring and reporting of all transactions and sharing of information as required under Rule 7 of the Prevention of Money Laundering (Maintenance of Records etc.) 2005.
2. Principal Officer for KYC will act independently and report directly to the concerned Director/MD/CMD or to the Board of Directors.
3. Principal Officer shall be located at the head/corporate office of Puvaja Investments Pvt Ltd.
4. Principal Officer shall be responsible for monitoring and reporting of all transactions and sharing of information as required under the law.
5. He/ She will maintain close liaison with enforcement agencies, Puvaja Investments Pvt Ltd and any other institution which are involved in the fight against money laundering and combating financing of terrorism.
6. Further, the role and responsibilities of the Principal Officer shall include overseeing and ensuring overall compliance with regulatory guidelines on KYC/AML/CFT issued from time to time and obligations under the Prevention of Money Laundering Act, 2002, rules and regulations made there under, as amended form time to time.
7. The Principal Officer will also be responsible for timely submission of CTR, STR to FIU-IND.
8. With a view to enabling the Principal Officer to discharge his responsibilities effectively, the Principal Officer and other appropriate staff shall have timely access to customer identification data and other CDD information, transaction records and other relevant information

Updating of the KYC Policy of the Company

The Board of Puvaja Investments Pvt Ltd will be authorized to amend/modify the KYC/ AML/ CFT Policy or such other related guidance notes of Company, to be in line with RBI or such other statutory authority’s requirements/updates/ amendments from time to time.

Reporting to Financial Intelligence Unit-India

In terms of PMLA Rules, Puvaja Investments Pvt Ltd shall be required to report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) in respect of transactions referred to in Rule 3 at the following address:

Director, FIU-IND
Financial Intelligence Unit-India
6th Floor, Hotel Samrat
Chanakyapuri
New Delhi – 110 021
Website – http://fiuindia.gov.in

Puvaja Investments Pvt Ltd will ensure that the provisions of the PMLA Rules and the Foreign Contribution and Regulation Act, 1976, wherever applicable, are adhered to strictly.

Puvaja Investments Pvt Ltd shall strictly comply with all formalities including timely submission of all applicable reports and returns in the prescribed format with regards to cash and suspicious transaction qualifying under the PML Rules directly to FIU-IND through the designated Principal Officer(s) of the Company. However, as has been earlier advised, there is no need for submission of any NIL report in respect to the above. Further, Puvaja Investments Pvt Ltd and its employees shall maintain strict confidentiality of the fact of furnishing/reporting details of suspicious transactions