Last Updated: 1st June 2025
1. Introduction
InstaFlexi Pay Solutions Private Limited ("FUPAY", "We", "Our") is fully committed to complying with the Prevention of Money Laundering Act, 2002 (PMLA), RBI Master Directions, FIU-IND guidelines, and other applicable laws and regulations in India to prevent and detect any money laundering or terrorist financing activities.
This AML Policy sets out our framework for customer due diligence, transaction monitoring, reporting obligations, record keeping, and staff responsibilities to ensure we maintain the highest standards of integrity and regulatory compliance.
2. Purpose
- Prevent our platform and services from being used for money laundering or terrorist financing activities.
- Ensure effective detection and reporting of suspicious activities.
- Comply with all applicable KYC, AML, and CFT (Combating Financing of Terrorism) regulations.
- Protect our clients and stakeholders from reputational and financial risks.
3. Customer Due Diligence (CDD)
We follow robust Know Your Customer (KYC) processes for all Merchants and where applicable for End Users.
- Verify identity and address using valid government-issued documents (PAN, Aadhaar, GST, bank accounts).
- Conduct enhanced due diligence (EDD) for high-risk merchants or transactions.
- Screen against negative lists such as OFAC, UN sanctions, or other regulatory watchlists.
- Monitor onboarding to ensure accurate and updated KYC information.
No account will be activated without satisfactory KYC verification in compliance with RBI and NPCI guidelines.
4. Ongoing Monitoring
- Continuous monitoring of transactions to identify unusual patterns, high-risk activities, or suspicious transactions.
- Automated rules and AI/ML tools may be used to detect anomalies in payment flows, payout requests, and settlement cycles.
- Transactions that exceed set thresholds or deviate from expected business activities are flagged for further review.
5. Reporting of Suspicious Transactions
We comply with all obligations under the PMLA, 2002 and RBI guidelines:
- Suspicious Transaction Reports (STRs) will be submitted promptly to the Financial Intelligence Unit – India (FIU-IND).
- Large Cash Transaction Reports (where applicable) will be filed as per prescribed norms.
- Any attempted or actual fraudulent transactions will be escalated to relevant law enforcement agencies.
6. Record Keeping
- KYC records, transaction data, and related communications will be securely maintained for at least five (5) years from the date of transaction or closure of account, whichever is later.
- All records shall be made available to RBI, FIU-IND, or other competent authorities upon request.
7. Employee Training and Awareness
- All relevant employees and stakeholders are trained on AML compliance, red flag indicators, and reporting obligations.
- Training is refreshed regularly to incorporate changes in laws, techniques, and best practices.
8. Roles and Responsibilities
- A designated Principal Officer is appointed to oversee AML compliance and act as the main point of contact for FIU-IND.
- The Principal Officer ensures timely submission of STRs, coordinates internal investigations, and reports to the Board/Management.
9. Merchant Responsibilities
- Merchants must comply with KYC/AML norms during onboarding and maintain valid business licenses.
- Merchants are required to report any suspicious activities observed in transactions processed through FUPAY's platform.
- Failure to comply may lead to suspension or termination of services.
10. Review and Updates
This AML Policy will be reviewed at least annually and updated as necessary to reflect regulatory changes, new risks, or operational requirements. All updates will be communicated internally and published on www.fupay.in as appropriate.
11. Contact Information
- info@instaflexi.in
- InstaFlexi Pay Solutions Private Limited, Shop No: 320, 3rd Floor, Krish Square, Opp. MPS School, Bhagat Singh Colony, Bhiwadi, Alwar, Rajasthan, India, 301019
FUPAY – Fast Unique Payments
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