Anti-Money Laundering Policy

1. Introduction

BAGUVIX TECHNOLOGIES PRIVATE LIMITED ("TreatyPay", "we", "us", or "our") is committed to complying with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations. This policy outlines our commitment to preventing money laundering and terrorist financing activities through our payment platform.

2. Policy Statement

TreatyPay maintains a zero-tolerance approach toward money laundering and terrorist financing. We are committed to:

• Implementing robust customer identification and verification procedures
• Monitoring transactions for suspicious activities
• Maintaining comprehensive records of customer transactions
• Reporting suspicious activities to relevant authorities
• Training our employees on AML/CTF compliance
• Regularly reviewing and updating our AML policies and procedures

3. Regulatory Framework

Our AML program complies with:

• The Prevention of Money Laundering Act (PMLA), 2002
• Prevention of Money Laundering (Maintenance of Records) Rules, 2005
• Foreign Exchange Management Act (FEMA), 1999
• Reserve Bank of India (RBI) guidelines and circulars
• Financial Intelligence Unit-India (FIU-IND) requirements
• Know Your Customer (KYC) norms
• International standards and best practices

4. Customer Due Diligence (CDD)

4.1 Customer Identification Program

We implement a comprehensive Customer Identification Program that includes:

• Identity Verification: Government-issued photo identification documents
• Address Verification: Utility bills, bank statements, or other official documents
• Business Verification: For business customers, we verify incorporation documents and business licenses
• Beneficial Ownership: Identification of ultimate beneficial owners for corporate customers

4.2 Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for:

• High-risk customers and transactions
• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Non-face-to-face customers
• Complex ownership structures
• Unusual transaction patterns

4.3 Ongoing Monitoring

We continuously monitor customer accounts for:

• Unusual transaction patterns
• Transactions that don't match customer profiles
• Rapid movement of funds
• Transactions involving high-risk jurisdictions
• Changes in customer behavior or transaction patterns

5. Transaction Monitoring

5.1 Automated Monitoring Systems

We employ advanced technology to monitor transactions, including:

• Real-time transaction screening
• Pattern recognition algorithms
• Risk scoring models
• Sanctions screening
• Threshold-based alerts

5.2 Suspicious Activity Indicators

We monitor for various suspicious activity indicators, including but not limited to:

• Transactions that are inconsistent with customer's known business or income
• Rapid movement of funds between accounts
• Structuring transactions to avoid reporting thresholds
• Transactions involving known high-risk countries or entities
• Multiple transactions just below reporting limits
• Unusual geographic patterns in transactions
• Transactions involving shell companies or complex structures

6. Record Keeping

We maintain comprehensive records including:

• Customer Records: Identity documents, verification records, and account information
• Transaction Records: Details of all transactions processed through our platform
• Monitoring Records: Documentation of ongoing monitoring activities
• Investigation Records: Records of suspicious activity investigations
• Training Records: Documentation of employee AML training
• Audit Records: Results of internal and external AML audits

All records are maintained for a minimum of five years or as required by applicable regulations.

7. Suspicious Activity Reporting

7.1 Reporting Obligations

We are committed to reporting suspicious activities to:

• Financial Intelligence Unit-India (FIU-IND)
• Reserve Bank of India (RBI)
• Other relevant regulatory authorities as required

7.2 Reporting Timeline

Suspicious Transaction Reports (STRs) are filed within the prescribed timelines:

• Within 7 working days of arriving at a conclusion that a transaction is suspicious
• Monthly nil reports when no suspicious transactions are identified
• Immediate reporting for transactions involving terrorism financing

8. Sanctions Screening

We maintain and regularly update our sanctions screening program to check against:

• United Nations Security Council sanctions lists
• Government of India sanctions lists
• Reserve Bank of India restricted/prohibited lists
• Other relevant international sanctions lists
• Politically Exposed Persons (PEP) databases

9. Training and Awareness

We provide regular AML training to all employees covering:

• Legal and regulatory requirements
• Company policies and procedures
• Identification of suspicious activities
• Reporting procedures
• Customer due diligence requirements
• Record keeping obligations
• Consequences of non-compliance

10. Governance and Oversight

10.1 AML Compliance Officer

We have designated an AML Compliance Officer responsible for:

• Overseeing the AML program
• Ensuring regulatory compliance
• Coordinating with regulatory authorities
• Managing suspicious activity reporting
• Conducting employee training
• Regular policy reviews and updates

10.2 Independent Testing

We conduct regular independent testing of our AML program through:

• Internal audits
• External compliance reviews
• Third-party assessments
• Regulatory examinations

11. Customer Obligations

Our customers are required to:

• Provide accurate and complete information during onboarding
• Update their information when changes occur
• Comply with all applicable laws and regulations
• Not use our services for illegal activities
• Cooperate with our due diligence and monitoring activities
• Report any suspicious activities they become aware of

12. Consequences of Non-Compliance

Non-compliance with this policy may result in:

• Account suspension or termination
• Reporting to regulatory authorities
• Legal action
• Regulatory penalties
• Reputational damage

13. Policy Review and Updates

This policy is reviewed annually or more frequently as needed to ensure it remains effective and compliant with current regulations. Updates are communicated to all relevant stakeholders.

14. Contact Information

For AML-related queries or to report suspicious activities, please contact our AML Compliance Officer:

Last updated: May 10, 2025