KYC AND AML POLICY
PRIMEPAY

1. Introduction

This KYC and AML Policy outlines the framework adopted by PrimePay operated by Prime Finverse Private Limited for customer identification, verification, and prevention of money laundering and financial crimes

Registered Address OU 727, 7th Floor, Esplanade One, Rasulgarh, Khorda, Bhubaneswar, Odisha, 751010, India

Head Office Building 4, North Wing, NESCO IT Park, WEH, Goregaon East, Mumbai, 400063, India

Website www.primepay.co.in

Grievance Email grievance@primepay.co.in

2. PLATFORM ROLE

PrimePay acts as a technology platform and aggregator facilitating access to

• UPI payments
• BBPS bill payments
• Recharges
• Loans via banks and NBFCs
• Insurance via insurers
• Travel bookings
• PrimePay is not a regulated financial institution and does not independently undertake lending or underwriting
• KYC verification and AML compliance obligations are primarily executed by regulated partnerentities

3. REGULATORY FRAMEWORK

This policy is aligned with

• This policy is aligned with.
• Rules and guidelines issued by the Reserve Bank of India.
• Applicable guidelines issued by the National Payments Corporation of India.
• Framework of the Bharat Bill Payment System.
• The Digital Personal Data Protection Act, 2023.

4. OBJECTIVES

• To establish customer identity verification mechanisms
• To prevent misuse of the platform for money laundering or fraud.
• To ensure compliance with applicable laws and partner requirements .
• To enable secure onboarding of users.

5. CUSTOMER IDENTIFICATION PROGRAM

PrimePay facilitates KYC through authorized partners

User may be required to submit

• Full name
• Date of birth .
• Address.
• Mobile number and email.
• PAN.
• Aadhaar where legally permitted.
• Photograph or live verification.
• Verification may include.
• OTP based verification.
• Document verification.
• Video KYC or biometric verification conducted by partners.

6. ROLE OF PARTNERS

• All KYC verification is conducted by
• Banks
• NBFCs
• Insurance providers
• Authorized KYC agencies
• PrimePay acts only as a facilitator and transmits user data securely to partners
• Final acceptance or rejection of KYC is determined by the respective partner

7. RISK BASED APPROACH

Users may be classified based on risk

• Low risk
• Medium risk
• High risk
• Risk classification may depend on
• Nature of transactions
• Geographic location
• User behavior patterns
• Enhanced due diligence may be applied for high risk users

8. AML MONITORING AND CONTROLS

• PrimePay implements monitoring mechanisms including
• Transaction pattern analysis.
• Fraud detection systems.
• Suspicious activity identification.
• Suspicious transactions may be flagged and reported to relevant authorities or partners.

9. PROHIBITED ACTIVITIES

• Users are prohibited from.
• Using the platform for illegal transactions May be reversed in case of.
• Money laundering or fraud
• Identity misuse or impersonation
• Circumventing KYC processes

10. DATA SHARING FOR COMPLIANCE

In case of

• User data may be shared with .
• Banks and NBFCs for verification .
• KYC registration agencies
• Government and regulatory authorities
• Law enforcement agencies where required
• Such sharing is done in compliance with applicable laws

11. RECORD RETENTION

User must

• KYC and transaction records are retained.
• As required under applicable laws including PMLA.
• For audit and compliance purposes.
• For fraud prevention and dispute resolution.

12. USER RESPONSIBILITY

User must

• Provide accurate information.
• Update information when required
• Cooperate with verification processes
• Failure to comply may result in
• Restriction of services
• Account suspension or termination

13. LIMITATION OF LIABILITY

Typical timelines

• PrimePay shall not be liable for.
• KYC rejection by partners .
• Delays in verification .
• Decisions taken by regulated entities.

14. GRIEVANCE REDRESSAL

For KYC related issuess

• Email grievance@primepay.co.in.
• Issues will be handled in accordance with regulatory timelines.

15. POLICY UPDATES

• This policy may be updated periodically.
• Continued use of the platform constitutes acceptance.

16. GOVERNING LAW AND JURISDICTION

• This policy is governed by laws of India.
• Courts in Khorda Odisha shall have exclusive jurisdiction and regulatory compliance..