AML

🛡 Anti-Money Laundering (AML) Policy
 

1. Introduction

At Abroces Fintech Services Private Limited, we are aware of the risks involved in money laundering and financing terrorism via Internet platforms. As per the Prevention of Money Laundering Act (PMLA), 2002, and the directions given by the Financial Intelligence Unit – India (FIU-IND), we undertake to identify, prevent, and report any activity that could relate to financial crimes. This Anti-Money Laundering Policy formalizes the company's commitment to compliance and the internal structure for identifying and reporting suspicious activity, thus maintaining the integrity of its business operations.
 

2. Scope

This AML policy applies to:

  • All registered customers and purchasers on https://afs.cool/
  • All self-employed sellers and traders registered on the platform
  • Employees, representatives, and authorized agents of https://afs.cool/
  • Payment gateway and logistics companies are engaged in transaction processing and order fulfillment.
  • The policy extends to all financial transactions and customer interactions carried out via the https://afs.cool/ platform.
     

3. Definitions

  • Money Laundering: The act of hiding the source of illegally gained money.
  • Terrorist Financing: Supplying funds to finance terrorist operations from internal or external sources.
  • Politically Exposed Persons (PEPs): Individuals who occupy major public offices.
     

4. AML Objectives

The main objective of this policy is to prevent the use of Abroces Fintech Services Private Limited services for money laundering and terrorist financing. We aim to detect and report suspicious activities that are conducted through our platform and are not compliant with the Prevention of Money Laundering Act (PMLA), 2002. Our company ensures that every transaction done through our website is compliant with legal and regulatory requirements. We provide regular training to all our employees to recognize and respond to AML risks.
 

5. Customer Due Diligence (CDD)/ Know Your Customer (KYC)

To provide transparency and guard the platform against illicit activities, we adhere to rigorous CDD processes for all customers and sellers.

The major activities are:

  • Identity Verification: Obtaining official government-issued identity proofs (Aadhaar, PAN, Passport) and address proofs at customer registration, seller onboarding, and high-value transactions.
  • Risk-Based Customer Classification: Classifying customers and sellers as low, medium, and high risk based on transaction behavior, geographic location, and nature of business.
  • Increased Due Diligence (EDD): Additional verification, source of funds declaration, and periodic monitoring will be conducted for high-risk entities.
  • Continuous Due Diligence: Periodic review and updating of customer and seller data to maintain records as current and accurate.
  • CDD ensures the identity of buyers and sellers is established before a financial transaction can be allowed.
     

6. Appointment of a Principal Officer

A committed Principal Officer is appointed to manage AML-related business and compliance obligations:

  • Formulating and putting into practice AML policies and procedures.
  • Monitoring of high-value and suspicious transactions.
  • Review and report patterns suggestive of money laundering or suspicious activity.
  • Filing Suspicious Transaction Reports and other regulatory reports.
  • Serving as a single point of contact for every AML compliance matter, law enforcement, and regulatory institutions.
     

7. Record Keeping

Abroces Fintech Services Private Limited keeps records of all transactions that can help in the detection, prevention, and investigation of financial crimes, including:

  • Keeping KYC information, identification documents, and CDD/EDD reports for at least 5 years after the business relationship has terminated.
  • Records of all purchase and sale transactions, including amount, parties involved, date/time, and payment method.
  • Keeping records of transactions that have been reported as suspicious, including the nature of suspicion, reporting dates, and internal actions.
     

8. Suspicious Transaction Monitoring and Reporting

We continuously track, monitor, and report any suspicious transactions on our website with:

  • Real-time transaction monitoring
  • Behavioral analysis of transaction behavior deviates from their declared business profiles. Or historical behavior.
  • Reporting Suspicious Transaction Reports (STRs) for any detected suspicious transactions.
     

9. Employee Training & Awareness

Abroces Fintech Services Private Limited keeps up with training related to educating its representatives and employees regarding their responsibilities and duties in order to prevent money laundering and terrorism financing, including:

  • Compulsory AML Training Programs
  • Practical Workshops
  • Policy Updates
  • Whistleblower Protection
     

10. Internal Controls and Audits

We implement internal controls to prevent and detect AML risks, including periodic audits to evaluate the effectiveness of the AML program.
 

11. Non-Compliance and Disciplinary Actions

Failure to comply with this policy may result in disciplinary action, including termination of employment, legal action, and regulatory penalties to all related parties.
 

12. Policy Review and Updates

This policy will be reviewed annually or as needed to reflect changes in laws, regulations, or business activities.