KYC and AML Policy

Established by DIVINE ADVENTURES AND HOSPITALITY PRIVATE LIMITED (“Company”).


Introduction

The Company is committed to complying with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations in India. This policy ensures:

  • Prevention of money laundering and illicit activities.
  • Safety, legality, and transparency of operations.
  • Regular review and updates of AML/CFT policies.

Key Requirements:

  • Users must provide accurate information during registration.
  • Non-compliance may result in account closure and fund forfeiture.

KYC POLICY

1. Customer Identification & Verification Program

Document Requirements:

  • ID Proof: PAN, Aadhaar, Passport, Voter ID, Driving License.
  • Address Proof: Passport, Aadhaar, Voter ID, Ration Card, Bank Statement, Utility Bills.

Mandatory PAN Submission:

  • Required if cumulative withdrawals exceed ₹10,000 or single withdrawals exceed ₹1,000.

Verification Timeline:

  • Complete KYC within 30 days of registration.
  • Unverified accounts face restricted access.

Account Restrictions:

  • Accounts are individual-use only. Sharing accounts leads to lockout and balance forfeiture.

2. Verified Account Withdrawal Policy

  1. First Withdrawal/Deposit Threshold:
    • KYC verification required if cumulative deposits exceed ₹50,000.
  2. Document Validity:
    • Name, date of birth, and address must match account details.
    • Documents must be unedited and clearly visible.
  3. Geographic Restrictions:
    • Withdrawals blocked for users from Assam, Odisha, Telangana, Andhra Pradesh, Nagaland, Sikkim.

3. Enhanced Due Diligence (EDD)

  • Applies to high-risk customers:
    • Politically Exposed Persons (PEPs).
    • Users from high-risk countries.
    • Complex/unusual transactions.
  • Additional checks include:
    • Source of funds verification.
    • Frequent transaction monitoring.

AML POLICY

1. Risk Assessment

  • Identify and mitigate risks via:
    • Customer due diligence.
    • Transaction monitoring.
    • Suspicious activity reporting.

2. Ongoing Monitoring

  • Monitor transactions exceeding ₹50,000 within 24 hours.
  • Track activities in high-risk territories.

3. Reporting

  • Report suspicious activities to Financial Intelligence Unit-India (FIU-IND).

4. Employee Training

  • Regular training on AML/KYC policies and procedures.

5. Record Keeping

  • Maintain records for 7 years (or as per legal requirements).
  • Ensure records are accurate and accessible for audits.

6. Compliance Officer

  • Designated officer ensures policy adherence.
  • Conduct regular audits and updates.

7. Third-Party Obligations

  • Third-party service providers must comply with AML/KYC policies.

8. Review & Update

  • Policies reviewed annually to align with legal changes.

Conclusion

  • Adherence is mandatory for all employees and users.
  • Non-compliance may lead to disciplinary action and legal consequences.

Contact:

Last Updated: 17 May 2025