Policy Statement
Asia Capital Limited is committed to preventing the use of our services for money laundering and terrorist financing activities. This policy establishes comprehensive measures to detect, prevent, and report suspicious activities in compliance with applicable laws and regulations.
Note: This policy has been superseded by the updated AML Policy version 6.0, effective January 1, 2025. Please refer to the current version for operational guidance.
Regulatory Framework
This policy is designed to comply with:
- Prevention of Money Laundering Act (PMLA), 2002
- Prevention of Money Laundering Rules (PMLA Rules), 2005
- Foreign Exchange Management Act (FEMA), 1999
- RBI Master Directions on Know Your Customer (KYC)
- Financial Intelligence Unit - India (FIU-IND) guidelines
Risk Assessment Framework
Customer Risk Categories
Low Risk
- Salaried employees of reputable organizations
- Government employees
- Public sector undertakings
- Customers with long banking relationships
Medium Risk
- Self-employed professionals
- Small business owners
- Cash-intensive businesses
- Customers from moderate-risk geographic locations
High Risk
- Politically Exposed Persons (PEPs)
- Non-resident Indians (NRIs)
- Customers from high-risk countries
- Cash-intensive businesses (money changers, dealers in precious metals)
Geographic Risk Assessment
- Countries identified by FATF as high-risk
- Jurisdictions with inadequate AML controls
- Countries subject to sanctions
- Border areas and free trade zones
Product and Service Risk
- High-value transactions
- Cross-border payments
- Cash transactions above threshold limits
- Complex or unusual transaction patterns
Customer Due Diligence (CDD)
Standard KYC Requirements
- Identity verification through valid documents
- Address verification
- Photograph and signature
- PAN or Form 60/61 as applicable
Enhanced Due Diligence (EDD)
Required for high-risk customers:
- Additional identification documents
- Source of income verification
- Source of wealth documentation
- Business relationship purpose
- Regular review and updating
Simplified Due Diligence (SDD)
Available for low-risk customers:
- Basic identification requirements
- Reduced documentation
- Threshold-based monitoring
- Periodic review
Transaction Monitoring
Automated Systems
- Real-time transaction screening
- Pattern recognition algorithms
- Threshold-based alerts
- Risk scoring models
Manual Review Process
- Investigation of system-generated alerts
- Customer profile analysis
- Transaction pattern review
- Decision documentation
Suspicious Activity Indicators
- Unusual transaction patterns
- Transactions inconsistent with customer profile
- Structuring of transactions to avoid reporting
- Transactions with high-risk countries
Reporting Requirements
Suspicious Transaction Reports (STRs)
- Filed with FIU-IND within 7 days
- All suspicious activities reported regardless of amount
- Detailed narrative and supporting documents
- Confidentiality maintained
Cash Transaction Reports (CTRs)
- All cash transactions of ₹10 lakh and above
- Reported to FIU-IND monthly
- Includes connected cash transactions
- Electronic filing through prescribed format
Cross-Border Wire Transfer Reports
- All inward and outward remittances
- Monthly reporting to FIU-IND
- Special attention to high-risk corridors
- Documentation of economic purpose
Record Keeping Requirements
Transaction Records
- All transactions maintained for 5 years
- Supporting documentation preserved
- Retrieval systems in place
- Audit trail maintenance
Customer Records
- KYC documents retained for 5 years after account closure
- Periodic updates documented
- Access controls implemented
- Confidentiality protected
Correspondence Records
- All customer communications
- Internal investigation notes
- Regulatory correspondence
- Training records
Training and Awareness
Staff Training Program
- AML awareness for all employees
- Role-specific training modules
- Regular update sessions
- Competency assessments
Training Components
- Money laundering typologies
- Red flag indicators
- Reporting procedures
- Regulatory requirements
Training Frequency
- Initial training for new employees
- Annual refresher training
- Ad-hoc training for regulatory updates
- Specialized training for high-risk areas
Compliance Monitoring
Internal Audit
- Regular AML compliance audits
- Risk-based audit approach
- Finding remediation tracking
- Management reporting
Independent Testing
- Annual independent AML testing
- System effectiveness evaluation
- Process validation
- Compliance assessment
Regulatory Examination
- Cooperation with regulatory inspections
- Document production
- Interview facilitation
- Remediation planning
Technology Systems
AML Software
- Automated transaction monitoring
- Customer risk scoring
- Case management system
- Regulatory reporting tools
Data Management
- Centralized customer database
- Transaction data warehouse
- Document management system
- Audit trail capabilities
System Validation
- Regular system testing
- Performance monitoring
- Accuracy verification
- Update management
Governance Structure
AML Officer
- Designated compliance officer
- Regulatory liaison
- Policy implementation oversight
- Staff training coordination
AML Committee
- Senior management representation
- Quarterly review meetings
- Policy approval authority
- Strategic guidance
Board Oversight
- Annual AML program review
- Resource allocation approval
- Risk appetite setting
- Regulatory communication
Sanctions Screening
Sanctions Lists
- UN Security Council sanctions
- Government of India sanctions
- US OFAC sanctions (where applicable)
- EU sanctions (where applicable)
Screening Process
- Real-time transaction screening
- Customer onboarding screening
- Periodic customer rescreening
- Watch list management
Match Investigation
- Alert investigation procedures
- False positive management
- Escalation protocols
- Decision documentation
Foreign Exchange Compliance
FEMA Compliance
- Authorized dealer obligations
- Liberalized Remittance Scheme
- Export-import transactions
- Documentation requirements
Reporting to RBI
- Foreign exchange transactions
- Cross-border payments
- Statistical returns
- Compliance certificates
Penalties and Enforcement
Internal Sanctions
- Employee disciplinary actions
- Performance impact
- Training requirements
- Capability enhancement
Regulatory Penalties
- Monetary penalties
- License restrictions
- Regulatory sanctions
- Reputational impact
Policy Review and Updates
Review Schedule
- Annual policy review
- Regulatory update incorporation
- Best practice adoption
- Stakeholder feedback integration
Approval Process
- Risk Committee review
- Senior management approval
- Board ratification
- Staff communication
Important Notice: This version of the AML Policy has been superseded. Please refer to AML Policy Version 6.0 for current operational requirements and procedures. This document is maintained for historical reference and audit purposes only.