AML & Anti-Fraud Policy

Overview

BANQUEEN.IN is committed to conducting its business with integrity and in full compliance with Indian anti-money laundering ("AML") and counter-terrorist financing ("CTF") laws, including the Prevention of Money Laundering Act, 2002 ("PMLA"), the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, and the rules, regulations and guidelines issued by the Reserve Bank of India ("RBI"), Securities and Exchange Board of India ("SEBI"), Insurance Regulatory and Development Authority of India ("IRDAI") and other regulators.

This AML & Anti-Fraud Policy describes the measures we take to prevent, detect and report money laundering, terrorist financing, fraud, identity theft and other financial crimes on our platform. It applies to all users, retailers, partners, employees, agents and service providers associated with BANQUEEN.

Scope

This policy applies to:

• All customers using BANQUEEN to compare, apply for or inquire about financial products.
• All authorised retailers, their staff and agents using the BANQUEEN retailer portal and wallet.
• All product providers, partners and service providers integrated with BANQUEEN.
• All BANQUEEN employees, contractors and representatives.
• All transactions, applications, wallet top-ups, withdrawals, lead purchases and other activities conducted on the Platform.

Customer & Retailer Identification

We collect and verify identity information as part of our KYC Policy. For AML and anti-fraud purposes, we may collect:

• Full name, date of birth, photograph and contact details.
• PAN, Aadhaar, passport, driving licence or other government-issued identity documents.
• Address proof and bank account details.
• Source of income, employment details and business information (for retailers).
• Beneficial ownership information for non-individual applicants.

We verify identity documents through government-authorised databases (UIDAI, NSDL e-Gov, CKYC) and trusted third-party verification providers. Retailers are subject to enhanced KYC and background checks before wallet activation.

Risk Assessment

BANQUEEN follows a risk-based approach to AML. We classify users, transactions and activities into risk categories (low, medium, high) based on factors such as:

• Nature and volume of transactions.
• Geographic location and jurisdiction.
• Type of product or service requested.
• Customer or retailer profile, business and source of funds.
• Sanctions and watch-list screening results.
• History of suspicious activity or chargebacks.

Higher-risk users, transactions and relationships are subject to enhanced due diligence, additional documentation, more frequent monitoring and senior management approval where required.

Transaction Monitoring

We monitor wallet and platform transactions to detect unusual, suspicious or potentially fraudulent activity. This includes:

• Real-time and post-transaction monitoring of wallet top-ups, withdrawals, lead purchases and service payments.
• Velocity checks, amount thresholds and frequency patterns.
• Detection of multiple accounts, device fingerprinting and location anomalies.
• Identification of layering, structuring or rapid movement of funds.
• Analysis of application data inconsistencies or forged documents.

Suspicious transactions may be flagged, held for review, reported to the appropriate authorities and/or result in account suspension or termination.

Reporting & Record Keeping

BANQUEEN maintains complete records of customer identity, KYC documents, transactions and internal AML reviews as required by law. Records are retained for at least 5 years from the date of the transaction or the end of the business relationship, whichever is later.

We are required to report suspicious transactions to the Financial Intelligence Unit-India (FIU-IND) and other competent authorities. Such reports are confidential and may not be disclosed to the customer or retailer involved.

All employees are prohibited from tipping off a customer or retailer about a suspicious transaction report or investigation.

Types of Fraud Prevented

Our AML and anti-fraud framework is designed to detect and prevent various types of fraud and financial crime, including:

Fraud Prevention Controls

We implement a multi-layered control environment to prevent fraud and financial crime:

• Identity verification: Document upload, OCR, liveness detection and database cross-checks.
• Device intelligence: Device fingerprinting, bot detection and geolocation analysis.
• Behavioural analytics: Pattern recognition to detect anomalous activity.
• Multi-factor authentication: OTP, email and mobile verification for high-risk actions.
• Payment controls: 3D Secure, CVV validation, transaction limits and gateway risk checks.
• Access controls: Role-based permissions, audit logs and least-privilege access.
• Document verification: Manual review for high-risk cases and random sampling.
• Third-party screening: Sanctions, PEP (Politically Exposed Persons) and adverse media screening.

Sanctions & Watch-lists

BANQUEEN does not allow its Platform to be used by individuals, entities or countries subject to sanctions, embargoes or prohibitions under Indian law, United Nations Security Council resolutions, or applicable international sanctions. We screen users, retailers and transactions against:

• Indian government and RBI sanctions lists.
• UN Security Council consolidated lists.
• OFAC, EU and other major sanctions lists, as applicable.
• Known fraud databases and law enforcement watch-lists.

Any match or potential match is investigated and, if confirmed, may result in account suspension, transaction blocking and reporting to the relevant authorities.

Training & Awareness

BANQUEEN provides regular AML and anti-fraud training to employees, support staff and retailer managers. Training covers:

• Identification of suspicious transactions and red flags.
• Customer due diligence and KYC requirements.
• Record keeping and reporting obligations.
• Phishing, social engineering and account takeover prevention.
• Ethical handling of confidential information and no tipping-off.

Retailers are provided with onboarding materials and ongoing communications on fraud prevention and compliance obligations.

Cooperation with Authorities

BANQUEEN cooperates fully with law enforcement agencies, regulators, courts, payment gateways and product providers in the investigation and prevention of financial crime. We may:

• Share customer, retailer and transaction information as required by law or court order.
• Freeze or suspend accounts pending investigation.
• File suspicious transaction reports with FIU-IND.
• Support prosecution and recovery proceedings.
• Participate in industry forums and information-sharing arrangements as permitted by law.

We will not disclose the existence of an investigation or report to the affected party unless required by law.

Contact

To report suspected fraud, money laundering or any suspicious activity on the Platform, please contact our compliance team: