ClearCred adheres to stringent KYC and Anti-Money Laundering standards in compliance with RBI and global regulatory frameworks.

1. Introduction

At ClearCred Technology Private Limited (“ClearCred”), we are fully committed to maintaining the highest standards of integrity and transparency in all our operations. In compliance with the Prevention of Money Laundering Act (PMLA), 2002, guidelines issued by the Reserve Bank of India (RBI), and international standards such as those prescribed by the Financial Action Task Force (FATF), ClearCred has established a robust Anti-Money Laundering (AML) and Know Your Customer (KYC) policy.

This policy is designed to prevent the misuse of our platform by individuals or entities seeking to engage in money laundering, terrorist financing, or any other form of financial crime.

2. Purpose

The objectives of this policy are to:

• Define the AML/KYC framework for merchant onboarding and monitoring.
• Prevent the use of ClearCred systems for unlawful financial activities.
• Ensure compliance with applicable AML/CFT laws, rules, and regulations.
• Facilitate timely cooperation with regulatory and law enforcement authorities.

3. Scope

This policy applies to:

• All merchants onboarded on the ClearCred platform.
• All employees, agents, consultants, and representatives engaged in merchant acquisition, verification, and transaction processing.
• All services offered by ClearCred that involve fund movement, payouts, collections, or settlement processing.

4. What is Money Laundering?

Money laundering is the process of disguising the origin of illegally obtained funds to make them appear legitimate. It typically involves three stages:

• Placement – Introducing illegal funds into the financial system.
• Layering – Concealing the source through complex transactions.
• Integration – Reintroducing funds into the legitimate economy.
  

ClearCred is committed to identifying and disrupting these stages.

5. AML Risk Management

We recognize and actively mitigate the following AML-related risks:

• Reputational Risk
• Compliance Risk
• Operational Risk
• Legal Risk
• Financial Risk               

A comprehensive, risk-based approach is applied across all merchant onboarding and transaction monitoring processes.

6. AML Governance Framework

Our AML governance is structured as follows:

• Defined AML/KYC standards for merchants
• Appointment of a Designated Director and Principal Officer for Compliance
• Periodic training and awareness for relevant staff and agents

Ongoing internal audits and policy reviews

7. KYC and Customer Due Diligence (CDD)

7.1 KYC Verification

• All merchants undergo KYC verification prior to activation.
• KYC includes verification of business registration, identity/address proof, bank details, and nature of operations.
• Merchants are screened against government-provided sanction, watch, and negative lists on a daily basis.
  

7.2 Beneficial Ownership

ClearCred identifies and verifies beneficial owners for all non-individual merchant accounts:

• Companies – Individuals with >25% ownership/control.
• Partnerships – Individuals with >15% ownership or entitlement to profits.
• Trusts – Authors, trustees, and beneficiaries with >15% interest.
• Unincorporated Bodies – Individuals with >15% ownership or control.
  

If no individual is identifiable, the senior managing official is deemed the beneficial owner.

8. Risk-Based Classification

All merchants are assigned a risk rating (Low / Medium / High) based on:

• Business type and operating model
• Transaction volume and patterns
• Geographic risk (e.g., high-risk countries)

Delivery channel risk (e.g., APIs, automation)

High-risk merchants undergo Enhanced Due Diligence (EDD).

9. Enhanced Due Diligence (EDD)

EDD is applied in the following cases:

• High-risk merchants
• Unusual transaction behavior
• High-value or complex fund flows

As part of EDD, ClearCred may request additional documentation such as income proofs, source of funds, and business financials.

10. Monitoring & Reporting of Suspicious Transactions

ClearCred uses automated and manual monitoring systems to detect:

• Transactions inconsistent with the merchant’s known profile
• Unusually large or complex transactions
• Activity without clear economic rationale

Any such transactions are escalated to the Compliance Officer, and Suspicious Transaction Reports (STRs) are filed with the appropriate authorities as per legal obligations.

10.1 Prohibition on Tipping-Off

All employees are strictly prohibited from disclosing any information related to the filing or review of an STR to the merchant or any unauthorized party.

11. Freezing of Accounts under UAPA

Upon receiving directions under Section 51A of the Unlawful Activities (Prevention) Act, 1967, ClearCred shall immediately freeze/unfreeze merchant accounts and funds without prior notice and in strict compliance with regulatory directives.

12. Record Retention

ClearCred will retain the following records for a minimum of 5 years:

• Merchant onboarding and KYC documentation
• Transaction records and audit logs

Reports filed under PMLA (e.g., STRs, freezing instructions)
These records shall be adequate to reconstruct transactions and support investigations, if required.

13. Roles and Responsibilities

13.1 Designated Director & Principal Officer

• Ensure overall implementation of AML/CFT measures.
• Liaise with regulatory and law enforcement bodies.
• Oversee internal AML audits and reviews.
  
  

13.2 Compliance Officer

• Review flagged transactions and report STRs.
• Maintain access to merchant KYC and transaction data.
• Train internal staff on AML/KYC compliance. 

Employee Training

• All relevant personnel undergo mandatory AML/KYC training.
• Training includes identification of suspicious behavior, documentation standards, and reporting mechanisms.
• Refresher sessions are conducted at regular intervals.
  

15. Internal Audit & Policy Review

• AML/KYC processes are subject to regular internal audits.
• Any deviations or gaps are documented and addressed promptly.
• The AML policy is reviewed at least annually, and updated in line with regulatory changes and operational learnings.
  

16. Conclusion

ClearCred is fully committed to safeguarding its platform against any misuse for financial crime. This AML & KYC Policy reflects our commitment to transparency, regulatory compliance, and responsible financial conduct.

For any questions or concerns regarding our AML/KYC practices, please contact our Compliance team at: info@clearcred.net