HAR SHREEJEE FINANCE & LEASING COMPANY LIMITED

PREAMBLE

Harshreejee Finance & Leasing Company Limited (“the Company”) is committed to preventing its products and services from being used, intentionally or unintentionally, for money laundering or terrorist financing. This policy has been prepared in compliance with RBI guidelines, the Prevention of Money Laundering Act (PMLA), 2002, and other applicable regulations. It focuses on robust procedures for Know Your Customer (KYC) and Anti-Money Laundering (AML) for individual borrowers availing payday loans.

OBJECTIVES

• Ensure the Company is not used for money laundering or terrorist financing activities.
• Comply with all regulatory requirements under RBI guidelines and PMLA.
• Establish procedures for identification, verification, and monitoring of individual customers.

DEFINITION OF CUSTOMER

For this Policy, a “Customer” refers to any individual who applies for or maintains a payday loan account with the Company. This includes the borrower themselves.

CUSTOMER ACCEPTANCE POLICY (CAP)

• No account or loan shall be provided in fictitious, anonymous, or benami names.
• Customers categorized into risk levels (low, medium, high) based on profile, transaction patterns, and background.
• Loans approved only after proper verification of identity and address.
• Procedures ensure genuine customers are not denied services.
• Risk information collected at the time of loan application.

CUSTOMER IDENTIFICATION PROCEDURES (CIP)

• Verify identity using reliable, independent documents.
• Obtain information regarding purpose and expected nature of loan.
• Apply enhanced due diligence for higher-risk customers.
• Maintain photographs, identity, and address proof for all customers.

KYC DOCUMENT REQUIREMENTS FOR INDIVIDUALS

Proof of Identity (at least two, self-attested):

• Passport
• PAN Card (with photograph)
• Voter’s ID
• Driving License
• Aadhaar letter issued by UIDAI

Proof of Address (any one, self-attested):

• Passport
• Electricity bill (not older than 3 months)
• Telephone bill (not older than 3 months)
• Bank statement (not older than 3 months)
• Aadhaar letter issued by UIDAI
• Rent Agreement
• Water Bill
• Wifi Bill

Additional Documents for Payday Loan Application:

• Salary slips of the last three months.
• Bank Statements of salary account of last 6 months; if required, bank statements of savings account(s) of last 6 months.

MONITORING AND REPORTING OF TRANSACTIONS

• All transactions monitored in line with customer’s risk profile.
• Special attention to unusually large or irregular payments.
• Risk factors (background, source of income, repayment pattern) determine monitoring intensity.
• Risk categorization and due diligence reviewed every six months.
• Suspicious transactions reported to FIU-IND by Principal Officer.

RISK MANAGEMENT

• Board ensures effective KYC & AML procedures, internal controls, and segregation of duties.
• Internal audit and compliance departments evaluate adherence.
• All employees undergo regular KYC/AML training.

CUSTOMER EDUCATION

Customers informed about purpose of KYC documentation; frontline staff trained to handle queries.

INTRODUCTION OF NEW TECHNOLOGIES

Potential money laundering risks from digital channels or online loan applications will be reviewed and addressed.

APPOINTMENT OF PRINCIPAL OFFICER

Principal Officer appointed at head office to monitor KYC/AML compliance and report suspicious transactions to FIU-IND. Maintains liaison with enforcement agencies and ensures timely submission of CTRs and STRs.

MAINTENANCE OF RECORDS

Records of cash and suspicious transactions maintained as per PMLA Rules. Customer identification and transaction records preserved for at least 10 years and retrievable for regulatory purposes.

UPDATING OF KYC POLICY

Board authorized to update/amend policy to comply with RBI or statutory amendments.

REPORTING TO FIU-IND

All qualifying cash and suspicious transactions reported to:
Director, FIU-IND
Financial Intelligence Unit – India
6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110021
Website: http://fiuindia.gov.in

APPROVAL & ADOPTION

Approved by the Board of Directors of Harshreejee Finance & Leasing Company Limited and effective from the date of adoption: _______
Board of Directors, Harshreejee Finance & Leasing Company Limited