KYC Policy

1. Objective

The Company shall undertake customer identification and verification procedures to prevent the Company from being used, intentionally or otherwise, by criminal elements for money laundering or terrorist financing activities, and to enable the Company to know and understand its customers and their financial dealings.

2. Customer Acceptance Policy

• No account shall be opened in anonymous or fictitious/benami names.
• No account shall be opened where the Company is unable to apply appropriate customer due diligence (CDD).
• No transaction shall be carried out where the identity of the customer matches with any entity in the sanction list.
• Customer acceptance is subject to assessment of risk perception (low/medium/high).

3. Customer Identification Procedure (CIP) — Officially Valid Documents (OVDs)

For Individuals, at least one OVD is collected:

• Aadhaar number (with consent, voluntarily) / Aadhaar e-KYC
• Passport
• Voter ID issued by Election Commission of India
• Driving Licence
• NREGA Job Card duly signed by an authorised officer
• Letter issued by National Population Register containing details of name and address

PAN / Form 60 is mandatorily collected for all customers.

For Non-Individual customers (Companies, Partnerships, LLPs, Trusts, HUFs, Proprietorships, Associations), constitution documents, registration certificates, board resolutions, and PAN are collected as applicable.

4. Customer Due Diligence (CDD)

• Identification of the customer and verification of identity using reliable, independent source documents/data.
• Identification and verification of the beneficial owner.
• Understanding the purpose and intended nature of the business relationship.
• Ongoing monitoring of transactions to ensure consistency with the customer's profile.

5. Risk Categorisation

Customers are categorised as Low, Medium or High Risk based on profile, nature of activity, geography, business volume, and other risk indicators. Periodic KYC updates are carried out at the following minimum frequency:

• High Risk: every 2 years
• Medium Risk: every 8 years
• Low Risk: every 10 years

6. Record Keeping

Records of customer identification and transactions are preserved for a minimum period of 5 years from the date of cessation of the relationship or the date of transaction, as required under the PMLA, 2002 and applicable RBI Directions.

7. CKYC, Aadhaar e-KYC and Video KYC

The Company uploads KYC records of individual customers to the Central KYC Records Registry (CKYCR) operated by CERSAI. Aadhaar based e-KYC and Video-based Customer Identification Process (V-CIP) may be carried out where permitted by RBI guidelines and with explicit customer consent.

8. Reporting to FIU-IND

Cash Transaction Reports (CTR), Suspicious Transaction Reports (STR), Non-Profit Organisation Transaction Reports (NTR) and Cross Border Wire Transfer Reports (CBWTR), as applicable, are filed with the Financial Intelligence Unit — India (FIU-IND) within the prescribed timelines under the PMLA Rules.

9. Designated Director, Principal Officer & KYC Officer

The Company has designated a Director and Principal Officer responsible for compliance with KYC/AML obligations and for reporting to FIU-IND. Contact: info@rughwanifinance.com.

10. Training and Customer Awareness

Employees are trained periodically on KYC/AML obligations. Customers are educated on the importance of KYC, the prohibition on sharing OTPs/sensitive credentials, and the safe handling of their identity documents.

11. Policy Review

This KYC Policy is reviewed annually or earlier upon any regulatory amendment, by the Board of Directors of Emm Dee R Finance Limited.