Legal & Compliance

KYC/AML Policy

Know Your Customer (KYC) and Anti-Money Laundering (AML) Compliance Framework

Last Updated: October 24, 2025

Regulatory Compliance

This KYC/AML Policy complies with the Prevention of Money Laundering Act (PMLA) 2002, SEBI regulations, FEMA, and FATF recommendations.

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

Compliance Contact

Chief Compliance Officer:

Indie Hub Private Limited

KYC Support:

kyc@indiehub.in

Related Legal Documents

Terms & Conditions

Our terms of service

Privacy Policy

How we protect your data

Governance

Our corporate framework

This KYC/AML Policy is subject to periodic review and updates to ensure ongoing compliance.

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