(Pursuant to the provisions of circular No. RBI/2005-06/224 dt. 02.12.2005 & as amended by Circular No. 39 issued by RBI dated 26.06.2006)

Introduction
This policy has been made in compliance with the instructions of the Reserve Bank of India vide its circular no. RBI/2005-06/224 dated 02.12.2005 and it will come into force w.e.f. 1st April 2006.

Objective
In view of the increased concerns regarding money-laundering activities and to prevent the Company from being misused for such activities, it was felt that it is necessary for the Company to formulate suitable policies and procedures in this regard. This policy is an effort to develop a system in the Company to prevent Money Laundering Activities. The objective of this policy is to formulate such Anti-Money Laundering measures, which can prevent the Company from being misused for the Money Laundering activities.

Money Laundering - Money Laundering can be called a process by which money or other assets obtained as proceeds of crime are exchanged for “Clean Money” or other assets with no obvious link to their criminal origins.

Scope of Policy
The policy is being made to formulate necessary measures for prevention of Money Laundering activities and these measures include the following:-

• Customer Identification Procedure- “Know Your Customer” norms
• Recognition, handling and disclosure of suspicious transactions
• Appointment of Money Laundering Reporting Officer (MLRO)
• Staff Training
• Maintenance of records
• Audit of transactions.
  

Key Policies

The Company hereby adopts the following key policies.

 KNOW YOUR CUSTOMER (KYC)

• All employees of the Company, engaged in the money transfer/changing services shall execute any transaction only after verifying and obtaining a photocopy of a valid identification proof of the customer. The Branch will invariably retain photocopies of proof of identification after verifying the document in original. The identification proof must have a photograph of the customer.
  
  
• Full details of name and address as well as the details of the identity documents provided will be kept on record by the Branches.
  

 TO RECEIVE MONEY FORM (TRM FORM)

Every money transfer transaction will be done after fulfillment of following conditions:-

> Duly filled “To Receive Money Form” should be accepted
> It must be dated
> It must be properly signed by the customer
> It must be accompanied by a valid ID of the receiver
> Only following documents can be accepted as ID proof:-

• Passport
• Driving License
• Voters ID
• PAN Card
• Refugee Card
• Bank Pass Book (photograph is mandatory)
• Army card
• Photo ID Cards issued by Central or State Government to its employees. This includes photo ID cards of Police or Army personnel. (Any ID issued to non employees will not be accepted).

 Payments

• Indian Customer - In case of payment of INR 50,000/- or above, the branch must make payment through an account payee cheque/ DD and a photocopy of the same will be kept in record by the branch.
  
• Foreigners - In case of payment of INR 100,000/- or above, the branch must make payment through an account payee cheque/ DD and a photocopy of the same will be kept in record by the branch.

 RBI Guidelines

• Limit on Amount of transfer - Any particular transaction should not exceed USD 2500/-
  
• Number of transaction - A person can do a maximum 12 transactions in a financial year.