KNOW YOUR CUSTOMER (KYC) AND
ANTI-MONEY LAUNDERING (AML) POLICY
OF
FINAGLE FINANCIAL SERVICES PRIVATE LIMITED
(FINAGLE)
SUMMARY OF THE POLICY
Policy Name |
Know Your Customer and Anti Money Laundering Policy |
Issue and Effective date |
01/04/2023 |
Date of next review |
01/04/2024 |
Periodicity of review |
Annually |
Owner / Contact |
Compliance Department |
Approver |
Board of Directors |
Annexure |
|
TABLE OF CONTENTS
SR. NO. |
PARTICULARS |
1. |
Introduction |
2. |
Objective |
3. |
Definitions |
4. |
Key Elements |
|
a. Customer Acceptance Policy (CAP) |
|
b. Risk management |
|
c. Customer Identification Procedures (CIP) |
|
d. Monitoring of Transactions |
5. |
Designated Director |
6. |
Principal Officer |
7. |
Money Laundering and Terrorist Financing Risk Assessment by Regulated Entities |
8. |
Due Diligence Of Business Partners |
9. |
Identification of Beneficial Ownership |
10. |
Record Retention |
11. |
Reporting to Central KYC Registry (CKYCR) |
12. |
General |
|
Annexure-A- List of KYC documents for different type of customers |
|
Annexure-B- Procedure for obtaining identification information for undertaking CDD |
|
Annexure-C- Indicative list for risk categorization |
Glossary
RBI |
Reserve Bank of India |
CAP |
Customer Acceptance Policy |
CIP |
Customer Identification Procedures |
PMLA |
Prevention of Money Laundering Act |
PEP |
Politically Exposed Person |
KYC |
Know Your Customer |
AML |
Anti-Money Laundering |
FINAGLE |
FINAGLE FINANCIAL SERVICES PRIVATE LIMITED |
NBFC |
Non-Banking Financial Companies |
CTR |
Cash Transaction Report |
STR |
Suspicious Transaction Report |
FIU – IND |
Financial Intelligence Unit – India |
CIBIL |
Credit Information Bureau (India) Limited |
UIDAI |
Unique Identification Authority of India |
OVD |
Officially Valid Document |
CERSAI |
Central Registry of Securitization Asset Reconstruction and Security Interest |
CDD |
Customer Due Diligence |
NRI |
Non Resident Indian |
PIO |
Person of Indian Origin |
V-CIP |
Video based Customer Identification Process |
LE |
Legal Entity |
UCIC |
Unique Customer Identification Code |
1. INTRODUCTION
The master direction on Know Your Customer (KYC) issued by the Reserve Bank of India and Anti-Money Laundering (AML) standards advised all Non-banking financial companies ensure that a proper policy framework on KYC and AML measures be formulated and put in place with the approval of the Board of the company.
In view of the master direction on Know Your Customer DBR.AML.BC.No.81/14.01.001/2015-16 dated February 25, 2016, with any amendment/re-enactment thereof issued by Reserve Bank of India from time to time and Prevention of Money Laundering Act, 2002 (“Act”) read with the PreventionofMoney-laundering(MaintenanceofRecords)Rules,2005(“Rules”)withanyfurtheramendments/re-enactments thereof issued from time to time, the Board of Directors of FINAGLE FINANCIAL SERVICES PRIVATE LIMITED has adopted a policy on Know Your Customer (KYC) &Anti-Money Laundering (AML) norms.
FINAGLE FINANCIAL SERVICES PRIVATE LIMITED(hereinafter referred to as “the Company” or “FINAGLE”) is a Non-Deposit taking Non-Systematically important Non- Banking Finance Company registered with the Reserve Bank of India (“RBI”) to carry out the business of a Non-banking financial company with an objective to provide financial assistance to the individuals, MSMEs, and Corporates.
This policy is applicable to all categories of products and services offered by the Company.
2. Objective
Objective of RBI guidelines is to prevent NBFCs being used, intentionally or unintentionally by criminal elements for money laundering activities.
The guidelines also mandates making reasonable efforts to determine the true identity and beneficial ownership of accounts, source of funds, the nature of customer’s business, reasonableness of operations in the account in relation to the customer’s business, etc. which in turn helps the Company to manage its risks prudently.
Accordingly, the main objective of this policy is to enable the Company to have positive identification of its customers.
3. KEY DEFINITIONS
Explanation:
“Provided also that where the client submits his proof of possession of Aadhaar number as an officially valid document, he may submit it in such form as are issued by the Unique Identification Authority of India”.
Explanation:
For the purpose of this clause, a document shall be deemed to be an OVD even if there is a change in the name subsequent to its issuance provided it is supported by a marriage certificate issued by the State Government or Gazette notification, indicating such a change of name.
Explanation: Transaction involving financing of the activities relating to terrorism includes transactions involving funds suspected to be linked or related to, or to be used for terrorism, terrorist acts or by a terrorist, terrorist organization or those who finance or are attempting to finance terrorism.
All other expressions unless defined herein shall have the same meaning as have been assigned to them under the applicable Master direction on NBFC or the Reserve Bank of India Act, or the Prevention of Money Laundering Act and Prevention of Money Laundering (Maintenance of Records) Rules, any statutory modification or re-enactment thereto or as used in commercial parlance, as the case may be.
4. KEY ELEMENTS
The Company has framed its KYC policy incorporating the following four key elements:
For the purpose of the KYC policy, a ‘Customer' is defined as per Clause 3 i.e., Definitions.
“FINAGLE” lays down criteria for acceptance of customers. While taking the decision to grant any facilities to the customers as well as during the continuation of any facilities the following norms and procedures will be followed by the company
The Customer Acceptance Policy will ensure that explicit guidelines are in place on the following aspects of customer relationship in the Company:
In compliance of above requirements the employees and staffs of the company make sure that the while complying with the aforementioned requirement does not result in any type of harassment or inconvenience to bona fide and genuine customers who should not feel discouraged while dealing with the Company and the adherence of customer acceptance policy must not result in denial of the company’s services to general public, especially to those, who are financially or socially disadvantaged.
Customer identification means identifying the customer and verifying his/ her identity by using reliable, independent source documents, data or information. Company need to obtain sufficient information necessary to establish, to their satisfaction, the identity of each new customer, whether regular or occasional, and the purpose of the intended nature of relationship.
Copies of the documents produced as Proof of Identity and Address shall be obtained and retained with the Company, wherein a responsible Company Official has to attest such copies certifying that the Originals thereof have been verified.
The periodicity of updating of customer’s identification data should be done once in ten years in case of low risk category customers, once in eight years in case of medium risk category customers and once in two years in case of high risk categories.
Besides risk perception, the nature of information/documents required would also depend on the type of customer (individual, corporate etc).
An indicative list of the nature and type of documents/information that may be relied upon for customer identification is given in Annexure-A
Also, the information collected from the customer for the purpose of opening of account should be kept as confidential and any details thereof should not be divulged for cross selling or any other purposes.
It will be ensured that information sought from the customer is relevant to the perceived risk, is not intrusive, and is in conformity with the guidelines issued in this regard. Any other information from the customer should be sought separately with his /her consent and after opening the account.
VIDEO – CUSTOMER IDENTIFICATION PROCEDURE
As per the section 18 of the amended Master Direction on KYC dated 10th May 2021, the company shall undertake V-CIP to carry out the following:
Further the Company shall adhere to the minimum standards specified in the Master Directions amendment w.r.t V-CIP infrastructure, procedure, record and data management.
The Company shall take assistance of Banking Correspondents (BCs) in facilitating the V-CIP only at the customer end. However, the company shall maintain the details of the BC assisting the customer, in case the service of BCs are utilized. The ultimate responsibility for customer due diligence will be the Company.
VIDEO – CUSTOMER IDENTIFICATION PROCEDURE
“FINAGLE” may undertake live V-CIP, to be carried out by an official of the “FINAGLE”, for establishment of an account based relationship with an individual customer, after obtaining his informed consent and shall adhere to the following stipulations:
Further, the Company shall adhere to the minimum standards specified in the Master Directions amendment w.r.t V-CIP infrastructure, procedure, record, and data management.
The Company shall take the assistance of Banking Correspondents (BCs) in facilitating the V-CIP only at the customer end. However, the company shall maintain the details of the BC assisting the customer, in case the service of BCs is utilized. The ultimate responsibility for customer due diligence will be the Company.
CUSTOMER DUE DILIGENCE PROCEDURES (“CDD”)
The true identity and bonafide of the existing customers and new potential customers opening loan accounts with the Company and obtaining basic background information would be of paramount importance.
Procedure for Obtaining Identification Information
For undertaking CDD, the Company will obtain the information from an individual, Sole Proprietary Firms, partnership firms, and Legal Entities while establishing an account-based relationship or while dealing with the individual who is a beneficial owner, authorized signatory, or the power of attorney holder related to any legal entity. A detailed procedure to be followed by the Company is attached as Annexure-B.
Ongoing monitoring is an essential element of effective KYC procedures. The Company can effectively control and reduce its risk only if it has an understanding of the normal and reasonable activity of the customer so that it can identify transactions that fall outside the regular pattern of activity. However, the extent of monitoring will depend on the risk sensitivity of the account. Since the Company may not have any deposit accounts, this situation will not arise, but the Company shall pay special attention to depleting financial ratios, adequacy of collaterals etc. The Company will put in place a system of half-yearly review of risk categorization of all outstanding accounts and the need for applying enhanced due diligence measures.
The Company must pay special attention to all complex, unusually large transactions and all unusual patterns which have no apparent economic or visible lawful purpose. The Company must also have an understanding of the normal and reasonable activity of the customer so that they have the means of identifying transactions that fall outside the regular pattern of activity in order to effectively control and reduce the risk. Transactions that involve large amounts of cash inconsistent with the normal and expected activity of the customer should be noted and must be reported.
The Company will ensure that record of transactions in the accounts is preserved and maintained as required under Section 12 of the PML Act, 2002 and Rule 3, 4, and 5 of the PMLA Rules 2005 (Refer Point 8 for maintenance of records and Point 9 for preservation of records under the PML Act) in a separate register at the registered office of the Company in physical or electronic form and make it available to the regulatory and investigating authorities. It will also ensure that transactions of suspicious nature and/or any other type of transaction notified under section 12 of the PML Act, 2002, and Rules 3, 4, and 5 of the PMLA Rules, 2005 is reported to the appropriate law enforcement authority.
The Board of Directors of FINAGLE has ensured adopt a risk-based approach to ensure that an effective KYC programme is put in place by establishing appropriate procedures and ensuring their effective implementation. The company will adhere to the following for effective implementation of Risk Management.
The Company’s internal control and compliance functions have an important role in evaluating and ensuring adherence to the KYC policies and procedures. The compliance function will provide an independent evaluation of the Company’s policies and procedures, including legal and regulatory requirements.
1. Originals of the KYC documents shall be verified by officials of the Company and copies thereof shall be obtained and retained with the Company. Such copies shall be attested by the Company officials certifying that they have been verified with the originals.
2. KYC documents so obtained shall be properly arranged and filed in order so that they shall be available for verification any time.
3. Company’s Internal Auditors/Management shall ensure an independent evaluation of compliance of KYC/AML policy including legal and regulatory requirements. They shall report Lapses observed in this regard as Irregularities in their Audit Reports.
4. Adverse features noted by the Internal Auditors/ Management shall be brought to the attention of the Principal Officer.
5. Summary of serious Irregularities/deviations shall be placed before the Audit Committee of the Board by the Internal Audit Department at quarterly intervals.
6. Review of implementation of KYC/AML guidelines shall also be placed before the Audit Committee of the Board by the Principal Officer at quarterly intervals.
7. The Company shall have an on-going employee training programme so that members of the staff are adequately trained in KYC/AML procedures.
8. The Principal Officer designated by the Company in this regard shall have responsibility in managing oversight and coordinating with various functionaries in the implementation of KYC/AML Policy.
9. Designated Director shall be responsible for the overall compliance with the obligations under the Act and Rules.
RISK PROFILING
Risk Category |
Category of Customers |
Low Risk Customers |
individuals (other than High Net Worth) and entities whose identities and sources of wealth can be easily identified and transactions in whose accounts by and large conform to the known profile may be categorised as low risk. In such cases, the policy requires only the basic requirements of verifying the identity and location of the customer. |
Medium Risk Customers & High-Risk Customers |
Customers that are likely to pose a higher than average risk to the Company may be categorised as medium or high risk depending on the customer's background, nature and location of activity, country of origin, sources of funds and his client profile, etc. The Company will apply enhanced due diligence measures based on the risk assessment, thereby requiring intensive ‘due diligence' for higher risk customers, especially those for whom the sources of funds are not clear. |
PERIODIC UPDATION OF KYC
S.No. |
Basis Risk category |
Frequency |
1. |
High risk customers |
Once every two years from the date of opening of the account / last KYC updation |
2. |
Medium risk customers |
Once every eight years from the date of opening of the account / last KYC updation |
3. |
Low risk customers |
Once every ten years from the date of opening of the account / last KYC updation |
5. DESIGNATED DIRECTOR
FINAGLE shall appoint ‘Designated Director’ who will be responsible for overall compliance with the obligation imposed under Chapter IV of the PML Act.
6. PRINCIPAL OFFICER
FINAGLE shall appoint ‘Principal Officer’ who will be responsible for reporting all transactions and sharing of information. He/ She will also be responsible to ensure that proper steps are e taken to fix accountability for serious lapses and intentional contraventions of the KYC guidelines.
Maintenance of records of transactions and reporting.
“FINAGLE” has a system of maintaining a proper record of transactions prescribed under Rule 3 of PMLA rules and transaction, procedure, manner of maintaining transactions, and manner of furnishing prescribed under rule 3, 4, 5, 6, 7 and 8 of PML Rules 2005 mentioned below:
The records shall be preserved in the following manner:
The information in respect of the transactions referred to in clauses I, II and III referred above will be submitted to the Director - FIU every month by the 15th day of the succeeding month.
The information in respect of the transactions referred to in clause IV referred above will be furnished promptly to the Director - FIU in writing, or by fax or by electronic mail not later than seven working days from the date of occurrence of such transaction.
The information in respect of the transactions referred to in clause V referred above will be furnished promptly by the Director - FIU in writing, or by fax or by electronic mail not later than seven working days on being satisfied that transaction is suspicious.
Strict confidentiality will be maintained by the Company and its employees of the fact of furnishing / reporting details of such suspicious transactions.
As advised by the FIU-IND, New Delhi; the Company will not be required to submit 'NIL' reports in case there are no Cash / Suspicious Transactions, during a particular period.
The required information will be furnished by the Company directly to the FIU-IND, through the designated Principal Officer.
REPORTING REQUIREMENTS TO FINANCIAL INTELLIGENCE UNIT - INDIA
“FINAGLE” shall furnish to the Director, Financial Intelligence Unit-India (FIU-IND), information referred to in Rule 3 of the PML (Maintenance of Records) Rules, 2005 in terms of Rule 7 thereof.
Explanation: In terms of Third Amendment Rules notified September 22, 2015 regarding amendment to sub rule 3 and 4 of rule 7, Director, FIU-IND shall have powers to issue guidelines to the REs for detecting transactions referred to in various clauses of sub-rule (1) of rule 3, to direct them about the form of furnishing information and to specify the procedure and the manner of furnishing information.
The reporting formats and comprehensive reporting format guide prescribed/ released by FIU-IND and Report Generation Utility and Report Validation Utility developed to assist reporting entities in the preparation of prescribed reports shall be taken note of. The editable electronic utilities to file electronic Cash Transaction Reports (CTR) / Suspicious Transaction Reports (STR) which FIU-IND has placed on its website shall be made use of by REs which are yet to install/adopt suitable technological tools for extracting CTR/STR from their live transaction data. The Company’s Principal Officers, whose all branches are not fully computerised, shall have suitable arrangement to cull out the transaction details from branches which are not yet computerized and to feed the data into an electronic file with the help of the editable electronic utilities of CTR/STR as have been made available by FIU-IND on its website http://fiuindia.gov.in.
While furnishing information to the Director, FIU-IND, delay of each day in not reporting a transaction or delay of each day in rectifying a misrepresented transaction beyond the time limit as specified in the Rule shall be constituted as a separate violation. The Company shall not put any restriction on operations in the accounts where an STR has been filed. The Company shall keep the fact of furnishing of STR strictly confidential. It shall be ensured that there is no tipping off to the customer at any level.
However, robust software throwing alerts when the transactions are inconsistent with risk categorization and updated profile of the customers shall be put in to use as a part of effective identification and reporting of suspicious transactions.
The Principal Officer can also report information relating to cash and suspicious transactions if detected, to the Director, Financial Intelligence Unit-India (FIU-IND) as advised in terms of the PML rules, 2005 in the prescribed formats at the following address:
Director, FIU-IND,
Financial Intelligence Unit, India,
6th Floor, Hotel Samrat, Chanakyapuri,
New Delhi – 110021
A copy of information furnished shall be retained by the Principal Officer for the purposes of official record.
The Company shall keep the fact of furnishing of STR strictly confidential. It shall be ensured that there is no tipping off to the customer at any level.
However, robust software throwing alerts when the transactions are inconsistent with risk categorization and updated profile of the customers shall be put in to use as a part of effective identification and reporting of suspicious transactions.
7. MONEY LAUNDERING AND TERRORIST FINANCING RISK ASSESSMENT
The Company shall apply a Risk Based Approach (RBA) for mitigation and management of the identified risk and have Board approved policies, controls and procedures in this regard. Further, the company shall monitor the implementation of the controls and enhance them if necessary.
8. DUE DILIGENCE OF BUSINESS PARTNERS
The following due diligence must also be performed on prospective Business Partners.
A) Verify Identity:
i. Obtain and file legible copies of corporate formation and registration documents or public company prospectuses and government filings.
ii. PAN card of the Directors etc.
iii. Wherever possible (in the case of privately owned entities), arrange for a recommendation from legal counsel to the company.
iv. Wherever possible (in the case of privately owned entities), obtain from appropriate government entity confirmation of due incorporation and existence of the corporation.
V. Wherever possible (in the case of privately owned entities), Verify the identity of All directors, Shareholders, UBO of body corporate through various online sources.
B) Verify Source of Income:
i. Research for the Company details in available news or business databases and obtain all corporate earnings information available.
The Company shall maintain files on each Business Partner with copies of all data obtained and memorialize in writing all the verification efforts. These files may be maintained electronically and should be accessible quickly when needed.
PURPOSEFUL IMPLEMENTATION
The purpose of adopting the above measures and norms while taking decisions on the issue of customer acceptance is twofold. Firstly, the Company should not suffer financially at later stage due to lack of proper due diligence exercise and lack of information which is the exclusive possession of the customers.
9. IDENTIFICATION OF BENEFICIAL OWNERSHIP
The Company will determine the beneficial ownership and controlling interest in case of applicants who are not individuals and the KYC of the beneficial owners will be completed. In the case of beneficial owners, Yes/No authentication provided by UIDAI shall suffice.
Applicable |
Guidelines |
|
Where the client is a company |
The beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has a controlling ownership interest or who exercises control through other means. |
a. Ownership of/entitlement to more than 25 % of shares or capital or profits of the company b. Control shall include the right to appoint majority of the directors or to control the management or policy decisions including by virtue of their shareholding or management rights or shareholders agreements or voting agreements |
Where the client is a partnership firm or a company |
The beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person |
Ownership of/entitlement to more than 15% of the capital or profits of the partnership. |
Where no natural person is identified under (i) or (ii) above |
The beneficial owner is the relevant natural person who holds the position of senior managing official |
There are certain indicative guidelines issued by RBI from time to time for customer identification requirements for matters such as Trust / Nominee or Fiduciary Accounts, Accounts of companies & firms, Client Accounts opened by professional intermediaries, Accounts of Politically Exposed Persons resident outside India and Accounts of non-face-to-face customers. The Company will adhere to these guidelines to the extent applicable.
10. RECORDS RETENTION
Records pertaining to identification of the customer and their address obtained while opening their loan account and during course of business relationship will be preserved five years from the date of transaction between a client and the reporting entity accordance with the Section 12 of the PLM Act, 2002 and the records mentioned under clause (e) of sub section 1 of PMLA rules 2005 shall retainfor a period of at least five years after the business relationship has ended or the account has been closed, whichever is later.
11. REPORTING TO CENTRAL KYC REGISTRY (CKYCR)
The customer KYC information will be shared with the CKYCR in the manner mentioned in the RBI Directions in the RBI’s KYC templates prepared for ‘individuals’ and ‘Legal Entities (LE)’ as the case may be with Central Registry of Securitization Asset Reconstruction and Security Interest of India (CERSAI).
The customer information related to LEs (Legal Entities) will be submitted to CKYCR for accounts of LEs (Legal Entities) opened on or after commencement of NBFI business activities.
Further, during periodic updation, customers’ KYC details will be migrated to current Customer Due Diligence (CDD) standards.
If a customer submits KYC Identifier, with explicit consent to download records from CKYCR, KYC records could be retrieved online from CKYCR and customer will not be required to submit any KYC records unless in the following events:
KYC Identifier generated by CKYCR will be communicated to the Individual/LE.
12. GENERAL
The Company shall ensure that the provisions of PMLA and the Rules framed thereunder and the Foreign Contribution and Regulation Act, 1976, wherever applicable, are adhered to strictly. Where the Company is unable to apply appropriate KYC measures due to non-furnishing of information and /or non-cooperation by the customer, the Company may consider closing the account or terminating the business relationship after issuing due notice to the customer explaining the reasons for taking such a decision. Such decisions need to be taken at a reasonably senior level.
ANNEXURE-A
List of KYC Documents for Different Types of Customers
1. ACCOUNTS OF INDIVIAUAL
A. Permanent Account Number (with photo and signature) or Form 60.
B. One certified copy of an Officially Valid Document (OVD”) containing details of the borrower’s identity for legal name, and any other names used and address:
• Proof of possession of Aadhaar number in such form as are issued by the Unique Identification Authority of India
• Valid Indian Passport (with photo and signature)
• Valid Voter’s ID card issued by the Election Commission of India
• Valid Permanent Driving License (with photo and signature)
• Letter issued by the National Population Register containing details of name and address.
In case of OVD furnished by the customer does not contain updated address, the following documents shall be deemed to be OVD for limited purpose of proof of address:
• Bank Account Statement
• Letter from any recognised public authority
• Utility Bill not more than two months old (electricity, telephone, post-paid mobile phone, piped gas, water bill) of any service provider
• Property or Municipal tax receipt
A copy of the borrower’s marriage certificate issued by the State Government or Gazette notification representing the change in name of the borrower along with a certified copy of the OVD in the existing name of the person shall be obtained for proof of address and identity to establish an account-based relationship or to periodically update records in case the borrower change their names on account of marriage or otherwise.
The following documents may be obtained in addition to OVD subject to the satisfaction of the Company:
1. Property (including land) registration document containing photograph, name, signature and address.
2. Letter from employer (subject to satisfaction of the Company).
Signature Proof:
1. Valid Indian Passport
2. Valid PAN card
3. Valid Permanent Driving license
4. Banker's letter/ verification letter/ ECS verification in original on Bank’s letter head bearing the authorising officer’s name and signature along with the stamp of the bank. In case the Bank refuses to give the signature verification on the Bank’s letter head, then Signature/ ECS verification shall be obtained in the format prescribed for the said purpose.
5. Property registration document containing photograph, name, signature and address
2. Accounts of Proprietary Concerns
1. Permanent Account Number (with photo and signature) or Form 60.
B. One certified copy of an Officially Valid Document (OVD”) containing details of the borrower’s identity for legal name, and any other names used and address:
• Proof of possession of Aadhaar number in such form as are issued by the Unique Identification Authority of India
• Valid Indian Passport (with photo and signature)
• Valid Voter’s ID card issued by the Election Commission of India
• Valid Permanent Driving License (with photo and signature)
• Letter issued by the National Population Register containing details of name and address.
Entity documents:
Documents of partner:
(i) Pan card of all the partners.
Partnership firm Documents:
ANNEXURE-B
Procedure for Obtaining Identification Information for Undertaking CDD
The Company shall obtain the following information from an individual while establishing an account-based relationship or while dealing with the individual who is a beneficial owner, authorized signatory or the power of attorney holder related to any legal entity:
a. Sufficient information including information about the sources of funds accounts of family members and close relatives is gathered on the PEP;
b. the identity of the person shall have been verified before accepting the PEP as a customer;
c. the decision to open an account for a PEP is taken at a senior level in accordance with the Company’s Customer Acceptance Policy; senior level for this purpose shall include HOD & above.
d. all such accounts are subjected to enhanced monitoring on an on-going basis; e. in the event of an existing customer or the beneficial owner of an existing account subsequently becoming a PEP, senior management’s approval is obtained to continue the business relationship;
the CDD measures as applicable to PEPs including enhanced monitoring on an on-going basis are applicable.
ANNEXURE-C
Indicative List for Risk Categorization
High-Risk Customers
Medium Risk Customers
Low Risk Customers
All other customers (other than High and Medium Risk category) whose identities and sources of wealth can be easily identified and by and large conform to the known customer profile, may be categorized as low risk. In such cases, only the basic requirements of verifying the identity and location of the customer are to be met.