KYC & AML Policy
1. Introduction & Purpose
Indie Hub Private Limited is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our procedures for verifying customer identities and monitoring transactions in compliance with:
- Prevention of Money Laundering Act, 2002 (PMLA)
- Securities and Exchange Board of India (SEBI) regulations
- Foreign Exchange Management Act (FEMA)
- Financial Action Task Force (FATF) recommendations
- Reserve Bank of India (RBI) Master Directions
2. Scope & Applicability
This policy applies to:
Founders & Entrepreneurs
All founders applying for funding, grants, or credits from Indie Hub
Investors & LPs
Individuals and entities investing in Indie Hub's funds or portfolio companies
Service Providers
Third-party vendors, consultants, and business partners
Portfolio Companies
Startups and companies receiving investment or support
3. KYC Requirements
3.1 Individual Customers
Required Documents:
- Identity Proof
- •
- Aadhaar Card
- •
- PAN Card (mandatory)
- •
- Passport
- •
- Voter ID
- •
- Driving License
- Address Proof
- •
- Aadhaar Card
- •
- Utility Bills (< 3 months)
- •
- Bank Statement
- •
- Rental Agreement
- •
- Property Documents
- Financial Proof
- •
- Bank Statements (6 months)
- •
- ITR Documents (2 years)
- •
- Form 16
- •
- Salary Slips
- •
- Net Worth Certificate
- Additional Info
- •
- Professional Details
- •
- Source of Income
- •
- LinkedIn Profile
- •
- Business Plan (if applicable)
- 3.2 Business Entities
Required Documents:
- Certificate of Incorporation
- Memorandum and Articles of Association (MoA/AoA)
- PAN Card of the company
- GST Registration Certificate
- Board Resolution authorizing the transaction
- List of Directors/Partners with KYC documents
- Ultimate Beneficial Ownership (UBO) Declaration
- Financial Statements (last 2-3 years)
- Bank Account Details and statements
- 3.3 High-Risk Customers
Enhanced due diligence (EDD) required for:
- •
- Politically Exposed Persons (PEPs)
- •
- High-value transactions (>₹10 lakh)
- •
- Non-resident Indians (NRIs) and foreign nationals
- •
- Customers from high-risk jurisdictions
- •
- Cash-intensive businesses
- •
- Customers with complex ownership structures
4. Verification Process
- Step 1
- Document Submission
Upload required documents via secure portal
- Step 2
- Document Verification
AI-powered document authenticity check
- Step 3
- Identity Verification
Video KYC or in-person verification
- Step 4
- Risk Assessment
AML screening and risk profiling
Timeline: KYC verification typically takes 24-72 hours. Enhanced due diligence may take up to 7 business days.
5. Anti-Money Laundering Procedures
5.1 Transaction Monitoring
We monitor all transactions for suspicious activity, including:
- Unusually large or frequent transactions
- Transactions inconsistent with customer profile
- Structuring (breaking transactions to avoid reporting)
- Transactions involving high-risk jurisdictions
- Rapid movement of funds
- Transactions lacking economic rationale
- 5.2 Sanctions Screening
All customers are screened against:
UNSC Sanctions List
UN Security Council designations
OFAC List
US Treasury sanctions
Interpol List
International criminal database
PEP Database
Politically exposed persons
Adverse Media
Negative news screening
National Lists
India-specific watch lists
5.3 Suspicious Activity Reporting (SAR)
Suspicious transactions are reported to the Financial Intelligence Unit (FIU-IND) within prescribed timelines:
- Cash transactions > ₹10 lakh (7 days)
- Suspicious transactions (30 days)
- Cross-border wire transfers > $5,000 (7 days)
6. Customer Due Diligence (CDD)
- Simplified DD
- Low Risk
Government entities, listed companies, low-value transactions
- Standard DD
- Medium Risk
Regular customers, standard transactions
- Enhanced DD
- High Risk
PEPs, high-value transactions, complex structures
- Ongoing Monitoring:
- Periodic review of customer information (annually or as needed)
- Continuous transaction monitoring
- Regular re-screening against sanctions lists
- Updates to risk profiles based on activity
7. Record Keeping & Data Retention
We maintain comprehensive records as required by law:
- KYC Records
- PMLA Requirement
- 5 years after account closure
- Transaction Records
- PMLA Requirement
- 5 years from transaction date
- Correspondence
- Regulatory Requirement
- 5 years
- SAR Reports
- FIU-IND Requirement
- 5 years
All records are stored securely with encryption and access controls.
8. Right to Refuse or Terminate
We reserve the right to refuse service or terminate relationships if:
- KYC documents are incomplete, invalid, or suspicious
- Customer refuses to provide required information
- Customer is on sanctions lists or involved in illegal activities
- Source of funds cannot be adequately verified
- Transaction patterns indicate money laundering
- Enhanced due diligence reveals unacceptable risk
9. Training & Compliance Culture
Indie Hub maintains a strong compliance culture through:
Regular Training
Mandatory AML/KYC training for all employees
Compliance Officer
Designated officer responsible for KYC/AML compliance
Internal Audits
Periodic reviews of compliance procedures
Policy Updates
Regular updates to reflect regulatory changes
10. Compliance Contact
Chief Compliance Officer:
Indie Hub Private Limited
Email:
contact@indiehub.co.in / contact@mantej.in
KYC Support:
contact@indiehub.co.in / contact@mantej.in