Our methodology towards obtaining paramount solutions for the clients demonstrates our quality and excellence. 
Ensuring successful business in long run requires adherence to values and we at Nikki Global Finance Limited are essentially guided by our core values. 
Steered by a young team of like-minded people, we have been able to work with our clients in the true sense of the word. ANTI MONEY LAUNDERING POLICY
This policy shall be called the fox DigiTech Finance Limited Policy on Know your customer and Anti Money Laundering Policy (herein after as KYC & AML Policy).
PREAMBLE
This Policy has been framed keeping in mind the requirements of the Prevention of Money Laundering Act, 2002 and Banking Regulation Act, 2005 and the rules made thereunder.
The matters covered in this policy are of outmost importance to the Company, shareholders, and other stakeholders of the Company and thus expedient for the company to incorporate the values that the company strives by this policy of conduct for board of directors and senior management.
The application of AML measures to non-depository financial institutions generally, and to the insurance companies, has also been emphasized by international regulatory agencies as a key element in combating money laundering. Establishment of AML program by financial institutions is one of the central recommendations of the Financial Action Task Force (FATF).
The company is fully committed to comply globally with all applicable laws designed to combat money laundering and any activity which facilitates the funding of terrorist or criminal activities. Company endeavors to meet the extant regulatory requirements and the framework would be amended from time to time as may be required by the Authority and Compliance with Financial Action Task Force requirements.
The Company will also communicate its policy to its clients by uploading it on its website.
OBJECTIVES
- To lay down the detailed AML Framework for the company.
- To ensure that none of its products are vulnerable to Money Laundering.
- To ensure that company is not used as a conduit for Money laundering.
- To ensure compliance with the AML laws and regulations in force from time to time.
- To protect company’s reputation from external monetary aggression.
- To assist law enforcement agencies in their effort to investigate and track money launderers.
- To lay down AML compliance norms for the employees of the Company.
DEFINITIONS
“Compliancerisk” means risk of loss due to failure of compliance with key Regulations governing the company’s operations.
“Financial risk” means risk of loss due to any of the above risks or combination there of resulting into negative financial impacton the Company.
“Integration” means creating the impression of apparent legitimacy to criminally derived wealth.
“Layering” includes separating illicit proceeds from their source by creating complex layers of financial transactions designed to disguise the source of money, subvert the audit trail, and provide anonymity;and
“Legal Risk” means risk of loss due to any of the above risks or combination thereof resulting into the failure to comply with Law and having a negative legal impact on the Company. The specific types of negative legal impacts could arise by way of fines, confiscation of illegal proceeds,and suspension/termination of licenses by the regulators,criminal liability,etc.
“Money Laundering” Whosoever directly or indirectly attempts to indulge or knowingly assists or knowingly is aparty or is involved in any processor activity connected with the proceed so fcrimeand projecting it as untainted property shall be guilty of offence of money-laundering and includes moving illegally acquired cash through financial systems so that it appears to be legally acquired.
"Operations Risk" means risk of loss resulting from inadequate or failed internal processes,people,and systems,or from external events.
“Placement” includes the physical disposal of cash proceeds derived from illegal activity.
“ReputationRisk” means risk of loss due to severe impact on Company’s business.This requires maintaining the confidence of authority,customers,creditors,and the general marketplace.
ANTI MONEY LAUNDERINGGOVERNANCE POLICY FRAMEWORK: As required by guidelines,company’s AML Framework is broadly divided into the following main components:
- i. BASIC DUE DILIGENCE[KNOW YOUR CUSTOMER(KYC)]: The company adopting the best corporate governance practices and keeping in view the specific requirements of the guidelines issued by RBI and other regulatory bodies and considering the potential threat of usage of financial services by a moneylaunderer,company shall make reasonable efforts to determine the identity of all customers by doing proper Customer Due Diligence(CDD).In case of new contracts,KYC/CDD shall be done before entering any contract per taining to insurance with new customer.
ii. KYC STANDARDS WITH RESPECT TO AML POLICY:
Effective procedures should be putinplaceto obtain requisite details for proper identification of new customers. The company has adopted the following guidelines:
a) The company shall endeavor to develop a mechanism where the agents / Financial Consultant’s (hereinafter as FCs) shall be required to provide information to indicate any behavioral aspects of a customer that are found to be suspicious at the time of their interaction.
b) The company shall endeavor to give special attention to all complex and unusually large transactions and patterns which appears to have no apparent economic or visible lawful purpose.
c) The company shall endeavor to not to enter a contract with a customer whose identity matches with any person with known criminal background or with banned entities and those reported to have links with terrorists or terrorist organizations.
d) The company shall endeavor to assure that customer’s name screening will be done daily against the negative list. In case any matching records are identified, it will be reported to the relevant authority in shortest time possible.
e) The company shall remain vigilant that in case of receipt of order to freeze / unfreeze account is received under section 51A of the UAPA, it will be implemented without prior notice to the designated individuals / entities.
f) The company shall endeavor to assure that the measures will be taken to identify beneficial ownership in case of non-individual customers.
iii. KYC ON ONGOING BASIS.
a) In NBFC, a huge number of financial transactions conducted by the customers are of a very high magnitude. Regulations require the Company to monitor all policy issuances and transactions there under for any suspected incident of money laundering. However, considering the spirit as well as the requirements under the regulations, the monitoring efforts are directed more towards the customers and transactions with higher risk of money laundering, being the Risked Based Approach (RBA) for monitoring and controls. Thus, by adopting an RBA implies the adoption of a risk management process for dealing with Money Laundering (ML) / Terrorist Financing (TF), keeping in mind the magnitude of risk involved.
b) A risk analysis would be performed to determine where the ML/TF risks are the greatest based on customers, products, and services, including delivery channels, and geographical locations.
c) The companyendeavors to classify the customer into high risk and low risk, based on customer category / nature / occupation / geography / sourcing channel / products features / premium payment modes / review of sanctions lists for money laundering or terrorism.
v. ENHANCEDDUEDILIGENCE
As NBFC and a good corporate citizen, it is imperative toensurethatthefinancial productsbeingby the clients are purchasedreasonably and thus customer’s source of funds, his estimated net worth,and previous returns etc., shall be appropriately documentedand company obtains income proofs and details of sources of funds for all policies as specifiedbytheCompanyfromtimetotime.It is a common practice that premium payments are received or can be received through various modes, including, DemandDrafts (DD), cheques, online transfers, etc. Thus, keeping in view, the company has the power to prescriberules / limits etc. for any payment mode, or to disallow any payment mode(s) for anyone or more channel. The cash acceptance limit / rules etc. shall be such, as may be decidedfromtimetotime, keepinginviewbusinessrequirements and regulatoryprovisions.The company shall obtainPAN and KYC documents of the payor to be obtained in case of third-party payment (other thanproposer).
vi. SUSPICIOUSTRANSACTIONS(INCLUDINGSUSPICIOUSCASHTRANSACTIONS)
The AML program envisages submission of Suspicious Transaction Reports(STR)/Cash Transactions Reports (CTR) / Counter feit Currency Report (CCR) / Non-Profitable Organization Transactions Report(NTR) to the Financial Intelligence Unit-India(FIU-IND) setup by the Government of India to track possible money laundering attempts and for further investigation and action. The company endeavors to provide its co-operation to the company in this regard.
vii. PROHIBITIONFROM“TIPPINGOFF”
The company endeavors through its policy that employees (permanent and temporary) be prohibited and further shall maintain strict confidentiality from disclosing the fact that a Suspicious Transactions Reportor related information of a policyholder/ prospectis being report edorprovided to the FIU-IND.
viii. RECORD MAINTAINENCE
a) The company through this policy endeavors that it shall in course of business maintain the records (either in electronic or in paper form) of types of transactions mentioned under Rules 3 and 4 of PMLA Rules 2005 and the copies of the Cash / Suspicious Transactions reports submitted to FIU as well as those relating to the verification of identity of customers for a period of five years in order to enable company to comply swiftly with information requests from the competent authorities.
b) Further that such records shall be sufficient to permit reconstruction of individual transactions (including the amounts and types of currency involved (if any) to provide, if necessary, evidence for prosecution of criminal activity.
c) Further the company endeavors that will retain the records of those contracts, which have been settled by maturity or claim, surrender or cancellation, for a period of at least five years after that settlement.
d) Records pertaining to all other transactions, (for which the Company is obliged to maintain records under other applicable Legislations / Regulations / Rules) the Company will retain records as provided in the said Legislations / Regulations / Rules but not less than five years from the date of end of the business relationship with the customer.
ix. APPOINTMENT OF ‘DESIGNATEDDIRECTOR’ AND PRINCIPAL COMPLIANCE OFFICER
a) The Company in course of business endeavors to appoint the Designated Director, Principal Compliance Officer and staff assisting in execution of AML guidelines should have timely access to customer identification data, other KYC information and records.
b) The Company envisions that it will designate ‘Designated Director’ and ‘Principal Compliance Officer’ and intimate the names of the ‘Designated Director’ and ‘Principal Compliance Officer’ to RBI and other requisite authorities. Any change in incumbency will be intimated to RBI and otherauthorities immediately.
c) The ‘Designated Director’ may be Managing Director or a whole-time Director duly authorized by Board of Directors or other such person as the board from time to time may specify.
d) The company envisions that the Principal Compliance Officer will be at a senior level and preferably not below the Head- Audit / Compliance / Chief Risk Officer level and should be able to act independently and report to senior management or any such person as the board of directors may from time to time specify.
x. RESPONSIBILITIES
a) The Designated Director shall, subject to limitation as the board and law may from time to time prescribe shall endeavor to ensure overall compliance with the obligations imposed under Prevention of Money Laundering Act, 2002 and the rules made thereunder. Broadly, the Principal Compliance Officer:
b) Shall ensure the implementation of the AML Program effectively, includingmonitoring compliance by the company’s insurance agents with their obligations under the program.
c) Shall ensure that employees and agents of the company have appropriate resources and are well trained to address questions regarding the application of the program considering specific facts.
d) Shall be responsible for regulatory reporting, as prescribed under the RBI guidelines, for Cash Transactions, Suspicious Transactions, Counterfeit Currency Notes and Non-ProfitOrganization details.
xi. RECRUITMENTANDTRAININGOFEMPLOYEES/AGENTS:
a) The company shall in future envisions to monitor the selection process of its agents and further ensure that if any unfair practice is being reported, then action is taken after due investigation.
b) The concept of AML will be part of in-house training curriculum for agents.
c) Company envisions to have adequate screening procedures when hiring employees / agents.
d) Company envisions that Instruction manuals on the procedures for selling insurance products, customer identification, record keeping, acceptance and processing of insurance proposals, issue of insurance policies are set out in near future.
e) The company shall in near future specify the training requirements are considered essential based on the class of employees, sales, and advisory staff.
f) The company ensures that ongoing training at regular intervals is made part and parcel to the training program of the company.
xii. INTERNALCONTROL/AUDIT:
As a corporate compliant NBFC, the company shall verify on a regular basis, compliance with policies,procedures and controls relating to money laundering activities.Exception reporting under anti money laundering framework shall be done to Audit Committee of the Board or to such committee as the board may specify from time to time.
COMPLIANCE WITH THE CODE
The Board of Directors is responsible to ensure compliance with the Prevention of Money Laundering Act and similar code of Conduct and take necessary steps in the event of default. The Company shall abide by all guidelines, directives, instructions and advice of Prevention of Money Laundering Authority and Reserve Bank of India and authorities under the Banking Regulation Act, 2005 and the rules made thereunder as will be in force from time to time. The contents in this document shall be read in conjunction with these guidelines, directives, instructions, and advice. The Company shall apply better practice so long as such practice does not conflict with or any of the above-mentioned regulations.
WAIVER AND AMENDMENTS TO THE CODE
This policy is subject to the modifications and no amendment/waiver of any provision of the code is possible unless approved in writing by the Board of Directors of the Company.
DISCLOSURES
The Policy shall be disclosed in the Company’s website.
DISCLAIMER
i. That it shall be obligatory on the part of every Director and Senior Management team Member to make an annual disclosure under this policy affirming their adherence to the policy on annual basis in the format appended.
ii. That this policy is in addition to and not in derogation with any Act, Law, rules, and regulations that governs the conduct of Board Directors.
iii. That his disclosure shall be made to the Board of Directors on 01 April, for the financial year preceding the date.