Anti-Money Laundering Policy

1. Introduction

REMITNIX Pvt. Ltd. ("REMITNIX", "we", "us") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy sets forth the principles, procedures, and controls we have implemented to prevent our platform from being used for money laundering, terrorist financing, or any other financial crime.

2. Scope

This AML Policy applies to:

• All customers, users, and account holders of REMITNIX
• All employees, officers, and directors of REMITNIX
• All transactions processed through the REMITNIX platform, including utility payments, mobile recharges, wallet top-ups, cross-border gifts, and travel bookings
• All third-party partners and service providers integrated with our platform

3. Know Your Customer (KYC)

REMITNIX implements a robust KYC program to verify the identity of all users:

• Basic Verification: Email verification and phone number verification (via OTP) are required for all accounts to access basic services such as utility payments and mobile recharges.
• Enhanced KYC: Government-issued photo ID verification through our DIDIT KYC integration is mandatory for cross-border gift transfers, wallet withdrawals, and high-value transactions.
• Ongoing Monitoring: User accounts are subject to continuous monitoring. Changes in transaction patterns may trigger additional verification requirements.

4. Customer Due Diligence (CDD)

We perform Customer Due Diligence at the following stages:

• At the time of account registration
• Before enabling cross-border gift transfer features
• When a user's transaction activity exceeds predefined thresholds
• When there is suspicion of money laundering or terrorist financing
• When there are doubts about the accuracy of previously obtained customer identification data

5. Transaction Monitoring

REMITNIX employs automated and manual transaction monitoring systems to detect suspicious activity:

• Real-time monitoring of all payment transactions for unusual patterns
• Flagging of transactions that exceed prescribed daily, weekly, or monthly limits
• Detection of structuring attempts (splitting transactions to avoid reporting thresholds)
• Monitoring cross-border gift transfers for patterns indicative of money laundering
• Regular review of high-risk accounts and transactions by our compliance team

6. Suspicious Activity Reporting

When suspicious activity is identified, REMITNIX will:

• Immediately freeze the involved account(s) pending investigation
• Conduct an internal investigation within 48 hours
• File a Suspicious Transaction Report (STR) with the Financial Intelligence Unit – India (FIU-IND) and/or the relevant regulatory authority in the user's country
• Cooperate fully with law enforcement agencies and regulatory bodies
• Maintain all records of suspicious activity reports for a minimum of 5 years

7. Risk Assessment

REMITNIX conducts periodic risk assessments to evaluate our exposure to money laundering and terrorist financing risks. These assessments consider:

• Geographic Risk: Countries and regions with higher AML risk profiles as identified by FATF
• Customer Risk: Risk profiles based on user behaviour, transaction volumes, and KYC information
• Product/Service Risk: Inherent risks associated with specific services (e.g., cross-border transfers carry higher risk than domestic bill payments)
• Channel Risk: Risks associated with non-face-to-face customer relationships

8. Record Keeping

In compliance with regulatory requirements, REMITNIX maintains the following records:

• KYC documents and verification records for a minimum of 5 years after account closure
• Full transaction records including amounts, dates, parties involved, and payment methods for at least 5 years
• All suspicious activity reports and investigation outcomes
• Correspondence and communications related to compliance matters

9. Sanctions Screening

REMITNIX screens all users against applicable sanctions lists, including:

• United Nations Security Council Consolidated List
• OFAC (Office of Foreign Assets Control) Specially Designated Nationals List
• EU Consolidated Financial Sanctions List
• Reserve Bank of India restricted entities list

Users identified on any sanctions list will be immediately blocked from using our platform, and relevant authorities will be notified.

10. Employee Training

All REMITNIX employees receive comprehensive AML/CTF training that covers:

• Identification and reporting of suspicious activities
• KYC procedures and customer due diligence requirements
• Understanding of money laundering typologies and red flags
• Compliance obligations and penalties for non-compliance

Training is conducted at onboarding and refreshed annually, with additional training provided when regulations or policies change.

11. Compliance Officer

REMITNIX has appointed a dedicated Compliance Officer responsible for:

• Overseeing the implementation and enforcement of this AML Policy
• Reviewing and filing Suspicious Transaction Reports (STRs)
• Coordinating with regulatory bodies and law enforcement
• Conducting periodic internal audits of AML procedures
• Ensuring all staff are adequately trained on AML obligations

12. Penalties for Non-Compliance

Failure to comply with this policy may result in:

• Temporary or permanent suspension of your REMITNIX account
• Forfeiture of wallet balance
• Reporting to relevant law enforcement and regulatory authorities
• Civil and/or criminal prosecution under applicable laws

13. Updates to This Policy

This AML Policy is reviewed and updated annually or whenever significant changes in regulations or business operations occur. Users will be notified of material changes through email or platform notifications.

14. Contact Us

For any questions or concerns about our AML Policy, please contact our Compliance team at our contact page or email compliance@remitnix.com.