1. INTRODUCTION:
1.1. Winners Royal Varsha Credit Cooperative Society Limited (the "Society") is committed to implementing effective measures to prevent money laundering and terrorist financing activities in accordance with the Prevention of Money Laundering Act, 2002 (PMLA), and the guidelines issued by the Government Authorities from time to time.
1.2. This AML and KYC Policy outlines the Society's approach towards AML and KYC measures and procedures in place to ensure compliance with the applicable laws and regulations.
2. POLICY OBJECTIVES:
The objectives of the Society's AML and KYC Policy are:
2.1.To identify and verify the identity of the members, beneficial owners, and authorized signatories of the Society.
2.2.To understand the nature of the business relationship and the transactions undertaken by the members.
2.3.To identify and report any suspicious activities, including attempted or completed transactions that may involve money laundering, terrorist financing, or other illegal activities.
2.4.To ensure compliance with the PMLA and other relevant laws, regulations, and guidelines.
3. KYC PROCEDURES:
3.1. Member Acceptance Policy:
The Society will only accept members who have completed the KYC process and provided all the required documentation. The Society will conduct a risk-based assessment of the member's profile and transactions to determine the level of due diligence required.
3.2. Customer Identification Procedure:
The Society will obtain the following information and documents for identification and verification purposes:
(i) For Individuals: Name, Address, Date of Birth, Photograph, PAN Card, Aadhaar Card, Passport, and other KYC documents as deemed necessary.
(ii) For Entities: Name, Registered Office Address, PAN Card, Registration Certificate, Memorandum and Articles of Association, List of Directors, and other KYC documents as deemed necessary.
3.3. Risk Assessment:
The Society will conduct a risk assessment of the members based on the following criteria:
(i) Nature of Business Activities
(ii) Geographical location of the member
(iii) Reputation of the member
(iv) Politically Exposed Persons (PEPs)
(v) Source of Funds
(vi) Volume and Frequency of Transactions.
3.4. Ongoing Monitoring:
The Society will continuously monitor the members' transactions and update their KYC information periodically. The Society will also verify the source of funds and the purpose of transactions.
4. AML PROCEDURES:
4.1. Reporting Obligations:
The Society will report any suspicious transactions to the Financial Intelligence Unit - India (FIU-IND) as per the guidelines issued by the RBI.
4.2. Record-Keeping:
The Society will maintain proper records of all transactions and KYC documents for a minimum of 10 years as per the PMLA.
4.3. Training and Awareness:
The Society will provide regular training to its employees and staff on AML and KYC policies and procedures.
4.4. Compliance Officer:
The Society will appoint a Compliance Officer (CO) who will be responsible for ensuring compliance with the PMLA and other relevant laws and regulations.
5. CONCLUSION:
The Society recognizes the importance of implementing effective AML and KYC policies and procedures to prevent money laundering and terrorist financing activities. The Society will review and update its policies and procedures periodically to ensure
compliance with the applicable laws and regulations.