AML & KYC Policy

1. ⁠Purpose

To prevent GenZCash from facilitating illicit finance by establishing robust customer identification, due-diligence, and transaction-monitoring procedures.

2.⁠ Scope

Applies to all Clients (businesses) and their end-customers whose branded-coin wallets are funded or redeemed through GenZCash, as well as all RSK IT Support Services Pvt. Ltd. personnel and third-party providers.

3.⁠ Customer Identification & Verification

  • Corporate Clients: Collect and verify Certificate of Incorporation, Company PAN, proof of Authorized Signatory, and recent bank statement. Perform beneficial-ownership screening for any individual owning ≥25% equity.
  • End-Customers: For redemptions ≥₹50,000, Clients must collect government-issued ID and address proof. Enhanced due-diligence for PEPs and sanctioned individuals.

4.⁠ ⁠Risk Assessment & Due-Diligence

  • Classify Clients as Low, Medium, or High risk based on business profile, transaction volumes, and geographic exposure.
  • For Medium/High risk: quarterly transaction reviews and annual KYC re-verification.

5.⁠ Transaction Monitoring

Automated flags for:

  • Unusual funding/redemption spikes month-over-month).
  • Frequent redemptions just thresholds (e.g. repeated requests).
  • Compliance Officer reviews alerts within 24 hours.

6.⁠ ⁠Suspicious Activity Reporting (SAR)

  • Report confirmed or suspected illicit activity to FIU-IND within 7 business days.
  • Retain SAR records and supporting evidence for 8 years.

7.⁠ Record-Keeping

  • Retain Client KYC files, transaction logs, and monitoring reports for 8 years post-activity.
  • Store data securely with strict access controls and audit trails.

8.⁠ Training & Governance

  • Annual AML/KYC training for staff and onboarding partners.
  • Quarterly internal audits of compliance processes and periodic policy review.

9.⁠ Contact & Escalation

  • Compliance Officer: aml-compliance@genzcash.com
  • Escalation: Head of Risk at risk-head@genzcash.com