KYC / AML Policy

Last Updated: [Insert Date]

1. Purpose

This KYC / AML Policy outlines the framework adopted by Flonix (“Company”, “we”, “us”) to prevent money laundering, terrorist financing, fraud, and other financial crimes in compliance with:

• Prevention of Money Laundering Act, 2002 (PMLA)

• RBI Master Directions on KYC

• FIU-IND guidelines

• Other applicable Indian laws and regulations

2. Scope

This policy applies to:

• All customers, merchants, businesses, employers, vendors, and beneficiaries

• All payout, payroll, vendor payment, wallet, and API-based services

• All employees, agents, and third-party service providers involved in customer onboarding or transaction processing

3. Regulatory Framework

Flonix complies with:

• RBI KYC Master Directions (as amended from time to time)

• PMLA, 2002 and associated Rules

• Guidelines issued by FIU-IND

• Information Technology Act, 2000

4. Customer Identification Program (CIP)

4.1 Individual Customers

We collect and verify:

• Full name

• Date of birth

• Address

• PAN (mandatory where applicable)

• Aadhaar (only where legally permitted)

• Mobile number and email address

4.2 Business / Corporate Customers

We collect and verify:

• Legal entity name

• Certificate of incorporation / registration

• PAN, GST (if applicable)

• Registered office address

• Authorized signatory details

• Board resolution / authorization letter

• Ownership and control structure

5. KYC Verification Process

• KYC is completed before enabling payouts or wallet usage

• Verification may be manual or electronic (eKYC) as permitted by RBI

• Enhanced Due Diligence (EDD) may be applied for high-risk customers

• Flonix reserves the right to reject or suspend accounts if KYC is incomplete or unsatisfactory

6. Whitelisting of Bank Accounts

• Funds can be loaded or settled only through verified and whitelisted bank accounts

• Changes to bank accounts require re-verification

• Third-party or anonymous accounts are strictly prohibited

7. Risk Categorization

Customers are classified as:

• Low Risk

• Medium Risk

• High Risk

Risk assessment is based on:

• Nature of business

• Transaction volume and frequency

• Geographic location

• Regulatory exposure

Higher-risk customers are subject to:

• Enhanced monitoring

• Periodic KYC updates

• Transaction limits

8. Ongoing Monitoring

Flonix continuously monitors:

• Transaction patterns

• Unusual or suspicious activity

• Large-value or structured transactions

Monitoring includes:

• Automated systems

• Manual review by compliance personnel

9. Suspicious Transaction Reporting (STR)

In compliance with PMLA:

• Suspicious transactions are reported to FIU-IND

• Users may not be informed of such reporting (“tipping off” is prohibited)

• Accounts may be frozen or restricted during investigations

10. Record Keeping

Flonix maintains:

• KYC records for at least 5 years after account closure

• Transaction records as mandated by law

• Audit trails for regulatory inspection

11. Prohibited Activities

The platform must not be used for:

• Money laundering or terrorist financing

• Shell companies or fictitious entities

• Illegal businesses, gambling, or prohibited activities

• Transactions violating RBI or Indian law

12. Employee Training

• Employees receive regular AML/KYC training

• Training includes identification of suspicious behavior and regulatory obligations

13. Data Privacy & Security

• KYC data is handled in accordance with the Privacy Policy

• Access to sensitive information is restricted

• Data is stored securely with encryption and access controls

14. Non-Compliance & Enforcement

Flonix may:

• Suspend or terminate accounts

• Freeze transactions

• Report users to regulatory authorities

• Take legal action where required

15. Policy Review & Updates

This policy is reviewed periodically and updated in line with regulatory changes. Continued use of the Services constitutes acceptance of updated policies.

16. Grievance & Compliance Contact

Compliance Officer
Email: compliance@flonix.com