EXLPAYLITE

ExlPayLite, operated by Excel Core Solutions, is committed to preventing the use of its services for money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy outlines our approach to detecting and preventing money laundering activities in compliance with the applicable laws and regulations.

1. Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to outline the steps that ExlPayLite has implemented to prevent, detect, and report any money laundering or suspicious activities within our platform. We are committed to complying with all applicable laws and regulations, including those under the Prevention of Money Laundering Act (PMLA), 2002 and other relevant regulatory requirements.

2. Scope

This policy applies to all users of ExlPayLite’s platform, including individual account holders, businesses, and merchants. It covers all transactions, including wallet loading, fund transfers, and investments made within the ExlPayLite ecosystem.

3. Customer Due Diligence (CDD)

ExlPayLite adheres to strict Customer Due Diligence (CDD) procedures to verify the identity of its users and assess the potential risks they may pose. We require the following information from users before their account can be activated:

• Full name
• Address
• Date of Birth
• PAN card details
• Aadhar card details (for Indian residents)
• Proof of address (utility bills, bank statements, etc.)

In cases where higher risk is identified, additional due diligence measures will be implemented.

4. Suspicious Activity Monitoring

We have implemented a monitoring system to detect suspicious activities that may indicate money laundering or fraud. These activities may include, but are not limited to:

• Large or rapid transactions that are inconsistent with a user's profile or transaction history.
• Transactions involving high-risk jurisdictions or countries known to have weak AML controls.
• Structured or tiered transactions designed to avoid detection (also known as "smurfing").
• Unusual patterns of transactions that suggest an attempt to obscure the origin or destination of funds.

If any suspicious activity is detected, the transaction will be flagged, and further investigation will be conducted.

5. Reporting Suspicious Activities

ExlPayLite is required by law to report any suspicious transactions to the appropriate authorities, including the Financial Intelligence Unit (FIU-IND) or other relevant government agencies. If a transaction is deemed suspicious, we will:

• Temporarily suspend the transaction.
• Investigate the activity in detail.
• Report the activity to regulatory authorities if required.

ExlPayLite will fully cooperate with law enforcement agencies and regulators in their investigations of suspicious activity.

6. Risk-Based Approach

ExlPayLite employs a risk-based approach to AML compliance, which means we assess the risk level of each user and transaction and tailor our monitoring and verification processes accordingly. The risk assessment factors may include:

• The user's geographical location.
• The nature of the user’s business (if applicable).
• The frequency and size of transactions.
• The user's transaction history.

Higher-risk users may be subject to enhanced due diligence (EDD) procedures.

7. Employee Training and Awareness

ExlPayLite ensures that all employees and agents are properly trained in AML laws and procedures. Regular training sessions will be conducted to ensure that our staff can:

• Identify red flags for suspicious activity.
• Understand the importance of complying with AML regulations.
• Follow the correct procedures for reporting suspicious activity.

8. Record-Keeping

ExlPayLite maintains comprehensive records of customer identification, transactions, and any reports of suspicious activities for a minimum period of five years as per regulatory requirements. These records are securely stored and made available for inspection by regulatory authorities when required.

9. AML Compliance Officer

ExlPayLite has appointed a designated Anti-Money Laundering Compliance Officer (AMLCO) to oversee the implementation of this policy and ensure compliance with relevant regulations. The AMLCO is responsible for:

• Monitoring and reporting suspicious activities.
• Ensuring that staff are properly trained on AML compliance.
• Coordinating with regulatory authorities when necessary.

10. Risk-Based Approach to Transactions

ExlPayLite uses a risk-based approach to assess the risk level associated with each transaction and user. Based on this assessment, we may take the following actions:

• Implement additional verification measures (e.g., requesting additional identification documents).
• Monitor certain transactions more closely for unusual activity.
• Report high-risk transactions to regulatory authorities.

11. International Transactions

ExlPayLite complies with international anti-money laundering standards when dealing with cross-border transactions. We ensure that:

• All international transactions are screened for any potential link to money laundering or terrorist financing.
• Customers are subject to enhanced due diligence procedures when conducting transactions with high-risk countries or jurisdictions.

12. Non-Compliance

Failure to comply with ExlPayLite’s Anti-Money Laundering Policy may result in severe consequences, including the suspension or termination of the user's account. Users found to be involved in money laundering activities will be reported to the relevant authorities and may face legal action.

13. Policy Review

ExlPayLite’s Anti-Money Laundering Policy will be reviewed and updated regularly to ensure compliance with changing regulatory requirements. Any changes to this policy will be communicated to users, and the revised policy will be posted on our website.

11. Contact Information

For any inquiries related to our Anti-Money Laundering Policy or to report suspicious activity, please contact us at:

• Email: aml@excelcoresolutions.com
• Phone: +91 7478824360
• Address: Netaji Park (Near Netaji Statue), Chakdaha, Nadia, West Bengal 741222
• Working Hours: Monday - Friday, 9:00 AM - 05:00 PM