KYC & AML Policy

Welcome to Fin 100X.AI — India’s First Protocol-Governed AI Financial Operating System. By using our app or platform, you agree to the following terms:

  1. Introduction Fin 100X.AI (“we,” “our,” “us”) is India’s first protocol-governed AI Financial Operating System, empowering Youth, Gen Z, Gen Alpha, and first-time earners with financial dignity, security, and freedom. As a platform integrated with regulated financial institutions (banks, NBFCs, insurance companies, AMCs, and pension funds), we are bound by strict obligations under: The Prevention of Money Laundering Act, 2002 (PMLA) The Prevention of Money Laundering (Maintenance of Records) Rules, 2005 (PML Rules) Directions issued by RBI, SEBI, IRDAI, and PFRDA Global standards set by the Financial Action Task Force (FATF)

This KYC & AML Policy sets forth the principles, systems, and procedures adopted by Fin 100X.AI to: Verify and identify customers (Know Your Customer – KYC) Prevent money laundering and terrorist financing (AML/CFT) Report suspicious transactions to FIU-IND Ensure compliance with all applicable laws and regulations

  1. Scope This Policy applies to: All customers using the Fin 100X.AI platform. All products and services, including: Credit Score & Loans (via RBI-regulated lenders) Investments & SIPs (via SEBI-registered intermediaries) Insurance (via IRDAI PoSP partners) Retirement & NPS (via PFRDA intermediaries)

All employees, advisors, contractors, and third parties engaged in processing KYC/AML data.

  1. Regulatory Framework 3.1 Key Legislations & Guidelines PMLA, 2002 & Rules, 2005 RBI Master Direction – KYC, 2016 (updated 2023) SEBI Master Circular on AML/CFT, 2023 IRDAI AML Guidelines, 2022 PFRDA AML Guidelines, 2021 FATF Recommendations (2012, updated 2020)

3.2 Applicability Fin 100X.AI, as a technology platform, operates through licensed financial partners. While we are not an NBFC, insurer, or AMC ourselves, our platform must ensure that all KYC/AML integrations align with partner and regulator requirements.

  1. Objectives To prevent the use of Fin 100X.AI for money laundering or terrorist financing. To establish a risk-based KYC framework for onboarding users. To ensure Customer Due Diligence (CDD) in line with Indian and global standards. To enable ongoing monitoring of transactions and detection of suspicious activity. To comply with record-keeping and reporting obligations under FIU-IND.
  2. KYC Policy Framework 5.1 Elements of KYC As per RBI/SEBI/IRDAI/PFRDA guidelines, our KYC framework consists of:
  3. Customer Acceptance Policy (CAP)
  4. Customer Identification Procedures (CIP)
  5. Ongoing Due Diligence (ODD)
  6. Risk Management

5.2 Customer Acceptance Policy No account is opened anonymously. Mandatory collection of Officially Valid Documents (OVDs) such as: Aadhaar, PAN, Passport, Driving License, Voter ID. Politically Exposed Persons (PEPs) and high-risk users require enhanced due diligence (EDD). Users must consent to data use in line with the DPDP Act 2023.

5.3 Customer Identification Procedures Digital KYC – Aadhaar e-KYC via UIDAI, DigiLocker pull, CKYC. Video KYC (V-CIP) – Real-time video verification with geo-tagging. PAN Validation – Through NSDL/CDSL APIs. Face Match AI – Biometric verification using AI-powered tools.

5.4 Ongoing Due Diligence Continuous monitoring of transactions. Threshold triggers (₹10 lakh single transaction / structured deposits). Alerts for unusual patterns (sudden spikes, foreign remittances, mismatched IP).

5.5 Risk Categorization Low Risk – Salaried individuals, small SIP investors. Medium Risk – SMEs, self-employed professionals. High Risk – PEPs, NRIs, users from FATF high-risk jurisdictions.

  1. Anti-Money Laundering (AML) Framework 6.1 Core Principles
  2. No Tolerance for Money Laundering
  3. Risk-Based Approach (RBA)
  4. Record-Keeping & Transparency
  5. Collaboration with Regulators

6.2 Customer Due Diligence (CDD) Identity verification before onboarding. Beneficial ownership checks for entities (25%+ shareholding). Screening against UN, OFAC, SEBI, RBI, IRDAI watchlists.

6.3 Enhanced Due Diligence (EDD) Mandatory for high-risk categories. Additional documentation and source of funds verification. Senior management approval required.

6.4 Monitoring & Reporting Suspicious Transaction Reports (STRs) filed with FIU-IND. Cash Transaction Reports (CTRs) for cash >₹10 lakh. NTRs (Non-Profit Organization Transactions) as per PMLA rules.

  1. Roles & Responsibilities AML Officer (CAMLO) – Chief Anti–Money Laundering Officer responsible for compliance. KYC Operations Team – Responsible for user onboarding, verification. Data Protection Officer (DPO) – Ensures lawful handling of KYC data. Employees – Mandatory AML training, reporting suspicious activity.
  2. Record Keeping KYC records maintained for 10 years (as per PMLA). Transaction records preserved for 10 years. Digital logs and audit trails secured with immutable storage.
  3. Technology & AI Safeguards AI-driven fraud detection – anomaly spotting, behavioral biometrics. Sanctions screening APIs – real-time list updates. Multi-agent orchestration – ensuring compliance across modules. Audit dashboards – regulator-ready compliance logs.
  4. Training & Awareness All employees undergo annual AML/KYC training. Specialized modules for handling PEPs, STR filing, and fraud detection. Advisors and Fin Partner teams trained in FIU-IND reporting formats.
  5. Regulatory Reporting STRs & CTRs submitted electronically to FIU-IND. Quarterly AML/KYC reports to RBI/SEBI/IRDAI/PFRDA partners. Immediate reporting of suspicious activities to law enforcement if required.
  6. Grievance Redressal Users may raise KYC/AML concerns at: legal@fin100x.ai +91-XXXXXXXXXX Grievance Officer: [Name], [Designation] Complaints are addressed within 30 days.
  7. Enforcement & Disciplinary Action Employees/partners violating this policy are subject to disciplinary action including termination. Non-compliance may attract penalties under PMLA, DPDP Act, and IT Act.
  8. Policy Review This Policy will be reviewed annually or earlier if required by regulatory changes.

Annexures Annexure A – Sample KYC Form (Individual) Name, Address, DOB Aadhaar/PAN Photograph Occupation & Income Details Signature

Annexure B – Sample STR Reporting Format (FIU-IND)

  1. Reporting Entity Name
  2. Customer Details
  3. Nature of Suspicion
  4. Transaction Details
  5. Reason for Suspicion

Annexure C – Risk Categorization Matrix Low – Salaried, students, SIP < ₹10,000 Medium – Self-employed, loans, SIP > ₹50,000 High – PEPs, cross-border transactions, NRIs

Annexure D – AML Red Flag Indicators Frequent high-value transactions without economic rationale. Multiple accounts with similar credentials. Transactions with sanctioned jurisdictions. Round-tripping of funds.

Fully compliant with RBI, SEBI, IRDAI, PFRDA, PMLA, FIU-IND, FATF

Website + App-ready legal format

Includes annexures for forms, STR formats, and risk matrice

Regulated FinTech / AI OS like Fin 100X.AI is:

6 KYC & AML Policy (Know Your Customer & Anti–Money Laundering)(RBI, SEBI, IRDAI, PFRDA, PMLA-aligned) This policy will cover:

KYC verification methods (CKYC, DigiLocker, Aadhaar XML, PAN validation, Video KYC)

Customer due diligence (CDD & e-KYC rules) Risk categorization (low, medium, high-risk users) Ongoing monitoring & suspicious transaction reporting (STRs) AML/CFT compliance obligations under PMLA, 2002 and FATF guidelines Roles & responsibilities (AML Officer, compliance reporting to FIU-IND) Annexures: Sample KYC forms, STR reporting format, FIU reporting templates

This is the policy regulators look for first when evaluating FinTechs offering credit, investments, or insurance integrations.