AML & CFT Policy

1. INTRODUCTION

PROSPER PROFESSIONAL DEVELOPMENT LIFE PRIVATE LIMITED (“Prosper” or “the Company”) is committed to maintaining the highest standards of Anti-Money Laundering (“AML”) and Counter Financing of Terrorism (“CFT”) compliance. Prosper recognizes the critical importance of preventing its products, services, systems, infrastructure, agents, distributors, merchants, and payment channels from being misused for money laundering, terrorist financing, fraud, or other unlawful activities.

This Anti-Money Laundering and Counter Financing of Terrorism Policy (“Policy”) establishes the governance framework, internal controls, procedures, monitoring mechanisms, and reporting obligations adopted by Prosper to identify, prevent, detect, monitor, investigate, and report suspicious financial activities.

The Company is committed to maintaining a strong compliance culture and implementing risk-based controls to ensure compliance with all applicable legal, regulatory, and supervisory requirements relating to AML/CFT obligations in India and internationally.

2. LEGAL AND REGULATORY FRAMEWORK

This Policy has been formulated in accordance with the following laws, regulations, standards, and guidelines:

• Prevention of Money Laundering Act, 2002 (PMLA), including amendments;
• Prevention of Money Laundering (Maintenance of Records) Rules, 2005;
• Reserve Bank of India (RBI) Master Direction on Know Your Customer (KYC);
• Reserve Bank of India AML/CFT Guidelines;
• Financial Intelligence Unit – India (FIU-IND) Rules and Circulars;
• Financial Action Task Force (FATF) Recommendations;
• Payment and Settlement Systems Act, 2007;
• Information Technology Act, 2000;
• Digital Personal Data Protection Act, 2023;
• United Nations Security Council (UNSC) Sanctions Lists;
• RBI Directions issued from time to time;
• Any other applicable laws, notifications, circulars, or regulatory requirements.

3. OBJECTIVES AND SCOPE

The primary objectives of this Policy are:

1. To prevent Prosper’s products, services, payment channels, agents, distributors, merchants, and business operations from being used for money laundering, terrorist financing, fraud, or other illegal activities.
2. To ensure full compliance with all applicable AML/CFT laws, regulations, and supervisory requirements.
3. To establish a risk-based compliance framework for identifying and mitigating money laundering and terrorist financing risks.
4. To promote a culture of compliance, accountability, transparency, and ethical conduct throughout the organization.
5. To protect the integrity, reputation, and operational stability of Prosper.

This Policy applies to:

• Directors;
• Employees;
• Agents;
• Distributors;
• Merchants;
• Business Correspondents;
• Service providers;
• Vendors;
• Contractors;
• Third-party partners;
• Affiliates;
• Any person acting on behalf of Prosper.

4. DEFINITIONS

5. GOVERNANCE STRUCTURE

The Board of Directors of Prosper shall have overall responsibility for:

• AML/CFT governance;
• Risk oversight;
• Compliance monitoring;
• Policy approval;
• Internal controls;
• Regulatory compliance.

The Company hereby appoints:

Principal Officer and AML Compliance Officer
Name: Mr. Divyanshu Kumar

The Principal Officer shall be responsible for:

• Implementing AML/CFT controls;
• Monitoring transactions;
• Regulatory reporting;
• Internal investigations;
• Suspicious transaction reporting;
• Liaising with regulators;
• Coordinating with FIU-IND;
• Ensuring employee training;
• Conducting risk assessments.

6. CUSTOMER ACCEPTANCE POLICY

Prosper shall maintain a robust Customer Acceptance Policy.

The Company shall not:

• Open anonymous accounts;
• Open fictitious accounts;
• Establish relationships with prohibited entities;
• Deal with sanctioned persons or organizations.

Customers shall be accepted only after:

• Completion of due diligence;
• KYC verification;
• Risk assessment;
• Screening against sanctions databases.

Enhanced scrutiny shall apply to:

• Politically Exposed Persons (PEPs);
• Non-resident customers;
• High-risk jurisdictions;
• Trusts and societies;
• NGOs and NPOs;
• High-risk businesses;
• Cash-intensive businesses.

7. CUSTOMER DUE DILIGENCE (CDD)

Prosper shall conduct Customer Due Diligence before establishing any business relationship.

8. RISK CATEGORIZATION

Customers shall be categorized based on risk exposure into:

Risk assessment factors include:

• Geographic location;
• Occupation;
• Nature of business;
• Transaction behavior;
• Volume of transactions;
• Customer profile;
• Source of funds;
• Political exposure;
• Regulatory history.

Enhanced Due Diligence (EDD) shall apply to all high-risk customers.

9. TRANSACTION MONITORING

Prosper shall implement both automated and manual monitoring mechanisms.

Transactions shall be monitored for:

• Large-value transactions;
• Unusual transactions;
• Structured transactions;
• Frequent cash transactions;
• Circular transactions;
• Rapid movement of funds;
• Transactions inconsistent with customer profiles;
• Suspicious merchant activity;
• Cross-border risk indicators.

Suspicious transactions shall be investigated and escalated immediately.

10. REPORTING TO FIU-IND

Prosper shall submit reports to the Financial Intelligence Unit – India (FIU-IND) as required by law. These include:

All reports shall be submitted by the Principal Officer.

11. SANCTIONS SCREENING

Prosper shall maintain screening procedures against:

• UNSC sanctions lists;
• Domestic sanctions lists;
• FIU-IND notifications;
• RBI alerts;
• Regulatory watchlists;
• Internal blacklists.

Any positive matches shall be immediately escalated and investigated.

12. RECORD MAINTENANCE

Prosper shall maintain:

• Transaction records;
• KYC records;
• Audit trails;
• Customer communications;
• Investigation reports;
• Regulatory submissions.

Such records shall be retained for a minimum period of five (5) years after the termination of the business relationship or longer if required by law.

Records shall remain available for:

• Regulatory inspections;
• Investigations;
• Audits;
• Legal proceedings.

13. EMPLOYEE TRAINING AND AWARENESS

Prosper shall conduct regular AML/CFT training programs for:

• Employees;
• Agents;
• Distributors;
• Compliance personnel;
• Customer service teams.

Training shall cover:

• AML regulations;
• Suspicious transaction indicators;
• Customer due diligence;
• Internal reporting mechanisms;
• Regulatory obligations;
• Emerging financial crime risks.

14. INTERNAL CONTROLS AND AUDIT

Prosper shall establish robust internal controls including:

• Internal compliance reviews;
• Risk assessments;
• Transaction monitoring;
• Audit mechanisms;
• Independent testing.

Internal audits shall be conducted periodically and independent AML reviews shall be performed annually.

Any deficiencies identified shall be promptly rectified.

15. CONFIDENTIALITY AND DATA PROTECTION

All AML-related information shall remain strictly confidential.

Information shall only be disclosed to:

• FIU-IND;
• RBI;
• Law enforcement agencies;
• Courts;
• Other competent authorities.

Data protection practices shall comply with:

• Digital Personal Data Protection Act, 2023;
• Information Technology Act, 2000;
• RBI cybersecurity guidelines.

16. PENALTIES AND DISCIPLINARY ACTION

Failure to comply with this Policy may result in:

• Warning notices;
• Suspension;
• Termination;
• Financial penalties;
• Regulatory action;
• Criminal prosecution.

Such actions shall be taken in accordance with:

• PMLA, 2002;
• RBI regulations;
• Internal disciplinary policies.

17. POLICY REVIEW AND UPDATES

This Policy shall be reviewed:

• Annually;
• Upon regulatory changes;
• Upon introduction of new products;
• Upon identification of new risks.

All amendments shall be approved by the Board of Directors.

18. APPROVAL AND EFFECTIVE DATE

This AML & CFT Policy has been approved by the Board of Directors of PROSPER PROFESSIONAL DEVELOPMENT LIFE PRIVATE LIMITED and shall remain effective until amended, replaced, or withdrawn.