1. Purpose
This Know Your Customer (KYC) Policy ("Policy") is adopted by Loanwalle.com framed in accordance with the applicable laws, rules, regulations, and guidelines issued by the Reserve Bank of India ("RBI"), including the Master Direction – Know Your Customer (KYC) Directions, 2016, as amended from time to time, and other applicable regulatory requirements. The objective of this Policy is to prevent the Company from being used, intentionally or unintentionally, for money laundering, terrorist financing, fraud, or other unlawful activities, and to ensure compliance with statutory and regulatory obligations.
2. Applicability
- Loanwalle.com, being an Indian fintech loan provider ("Company");
- All customers/borrowers, co-borrowers, guarantors, lenders, vendors, partners, and other persons or entities with whom the Company establishes a business relationship; and
- All directors, officers, employees, agents, service providers, and authorized representatives of the Company involved in customer onboarding, operations, compliance, or risk management.
3. Definitions
Unless the context otherwise requires, terms used in this Policy shall have the same meaning as assigned to them under the RBI KYC Directions and applicable laws, including but not limited to the Prevention of Money Laundering Act, 2002 ("PMLA").
4. Regulatory Framework
This Policy is guided by and shall be read in conjunction with:
- Prevention of Money Laundering Act, 2002 and rules framed thereunder;
- RBI Master Direction – Know Your Customer (KYC) Directions, 2016 (as amended);
- Information Technology Act, 2000 and applicable data protection and privacy laws;
- Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 and rules thereunder (where applicable);
- Any other circulars, guidelines, or directions issued by RBI or other competent authorities from time to time.
5. Customer Acceptance Policy (CAP)
The Company shall follow a clear Customer Acceptance Policy to ensure that:
- No account or loan relationship is established in anonymous or fictitious names;
- Customers are onboarded only after completion of due KYC verification;
- The identity of the customer is verified using reliable, independent source documents, data, or information;
- Enhanced due diligence is carried out for high-risk customers;
- The Company reserves the right to refuse or discontinue a customer relationship where KYC requirements are not met or where the risk is deemed unacceptable.
6. Customer Identification Procedure (CIP)
For individuals, the Company shall obtain and verify the following officially valid documents ("OVDs"), as applicable:
- Proof of Identity: Aadhaar (offline/voluntary), Passport, Voter ID, Driving Licence, PAN Card, or any other document permitted by RBI;
- Proof of Address: Aadhaar, Passport, Driving Licence, Voter ID, utility bills, or other RBI-recognized documents.
7. Beneficial Owner Identification
The Company shall identify and verify the beneficial owner(s) of non-individual customers in accordance with RBI guidelines, including thresholds prescribed for ownership or control. Enhanced due diligence shall be undertaken where beneficial ownership is complex or opaque.
8. Risk-Based Approach
The Company shall adopt a risk-based approach for KYC and AML compliance, classifying customers into low, medium, or high risk based on factors such as:
- Customer profile and occupation;
- Nature and purpose of the loan or business relationship;
- Geographical location;
- Transaction behavior and volume.
- High-risk customers shall be subject to enhanced due diligence, including additional documentation, senior management approval, and closer monitoring.
9. Ongoing Due Diligence and Monitoring
The Company shall:
- Conduct ongoing monitoring of customer transactions to ensure consistency with the customer’s profile and risk category;
- Periodically update KYC records and documents as per RBI-prescribed timelines;
- Review and reclassify customer risk where necessary;
- Identify and report suspicious transactions to the Financial Intelligence Unit – India (FIU-IND) in accordance with PMLA requirements.
10. Video KYC and Digital KYC
Where permitted under applicable RBI guidelines, the Company may undertake Video-based Customer Identification Process (V-CIP) and other digital KYC methods, subject to:
- Explicit customer consent;
- Secure technology infrastructure;
- Proper audit trails and record retention;
- Compliance with data privacy and information security standards.
11. Record Keeping
The Company shall maintain:
- Records of customer identification data, account files, and business correspondence;
- Transaction records sufficient to permit reconstruction of individual transactions;
- Such records for a minimum period as prescribed under PMLA and RBI guidelines, even after the end of the customer relationship.
12. Data Privacy and Confidentiality
Customer information obtained for KYC purposes shall be:
- Used solely for lawful and regulatory purposes;
- Kept confidential and shared only with regulators, statutory authorities, or service providers on a need-to-know basis;
- Protected through appropriate technical and organizational security measures in compliance with applicable data protection laws.
13. Reporting of Suspicious Transactions
The Company shall establish internal mechanisms for identifying, escalating, and reporting suspicious transactions, including:
- Cash Transaction Reports (CTR);
- Suspicious Transaction Reports (STR);
- Any other reports as required under applicable laws.
14. Roles and Responsibilities
- The Board of Directors shall approve and oversee the implementation of this Policy;
- A designated Principal Officer/Compliance Officer shall be responsible for ensuring compliance with KYC and AML obligations;
- Employees and agents shall adhere strictly to this Policy and undergo periodic training.
15. Training and Awareness
The Company shall provide regular training to its employees and relevant stakeholders to ensure awareness of KYC, AML, and CFT obligations and emerging risks.
16. Review and Amendment
This Policy shall be reviewed periodically and updated as and when required to align with changes in regulatory requirements, business operations, or risk profile. Any amendments shall be approved by Loanwalle.
