1. Introduction

Sunita Finlease Ltd. (the "Company") is committed to upholding the highest standards of integrity, transparency, and compliance with all applicable laws and regulations, including those pertaining to Anti Money Laundering (AML) and Countering the Financing of Terrorism (CFT). Money laundering and terrorist financing activities pose significant risks to the financial system's integrity and stability, and the Company recognizes the importance of implementing robust AML measures to mitigate these risks.

2. Objectives

The objectives of this AML policy are as follows:

To establish a comprehensive framework for preventing and detecting money laundering and terrorist financing activities within the Company.
To ensure compliance with all relevant AML and CFT laws, regulations, guidelines, and industry best practices.
To conduct thorough risk assessments to identify and mitigate AML/CFT risks associated with the Company's operations.
To implement effective customer due diligence (CDD) and enhanced due diligence (EDD) procedures to verify the identity of customers and assess the nature and purpose of their transactions.
To monitor transactions effectively for suspicious activities and report such activities to the appropriate authorities.
To maintain accurate records of customer due diligence, transaction monitoring, and suspicious activity reports (SARs) as required by law.
To provide regular training and awareness programs to employees to ensure they understand their AML/CFT obligations and can fulfill their roles effectively.
To conduct periodic reviews and assessments of the Company's AML/CFT policies, procedures, and controls to ensure their effectiveness and compliance with regulatory requirements.
To cooperate fully with law enforcement agencies, regulatory authorities, and other financial institutions in the investigation and prosecution of money laundering and terrorist financing activities.

3. Regulatory Framework

The Company shall adhere to all applicable AML/CFT laws, regulations, guidelines, and directives issued by relevant regulatory authorities, including but not limited to:

The Prevention of Money Laundering Act (PMLA) and its subsequent amendments.
The Financial Action Task Force (FATF) recommendations and guidance.
Guidelines issued by the Reserve Bank of India (RBI) and other regulatory bodies.
Any other relevant laws and regulations applicable to the Company's operations.

The Company shall also monitor and stay abreast of any changes or updates to the regulatory framework and promptly update its policies, procedures, and controls accordingly.

4. Risk Assessment

The Company shall conduct periodic risk assessments to identify, assess, and mitigate the money laundering and terrorist financing risks associated with its products, services, customers, and geographical locations of operation. The risk assessment shall take into account various factors, including:

The nature and complexity of the Company's business activities.
The types of customers served by the Company, including their risk profiles and jurisdictions of operation.
The delivery channels used by the Company to provide its products and services.
The effectiveness of existing AML/CFT policies, procedures, and controls.
Any emerging money laundering or terrorist financing threats and vulnerabilities.

Based on the risk assessment findings, the Company shall design and implement appropriate risk-based controls and mitigation measures to address identified risks effectively.

5. Customer Due Diligence (CDD)

The Company shall conduct customer due diligence (CDD) on all new and existing customers to verify their identities and assess the nature and purpose of their business relationships with the Company. CDD measures shall include:

Collecting sufficient information to identify and verify the customer's identity, including name, address, date of birth, and other relevant information.
Verifying the customer's identity using reliable and independent sources, such as government-issued identification documents, utility bills, or other official records.
Assessing the risk associated with the customer based on factors such as their business activities, geographical location, and transaction patterns.
Obtaining information on the source of funds and wealth of the customer, especially in cases involving high-risk customers or transactions.

6. Enhanced Due Diligence (EDD)

The Company shall apply enhanced due diligence (EDD) measures to customers and transactions presenting higher money laundering or terrorist financing risks. EDD measures may include:

Obtaining additional information and documentation from the customer to verify their identity and assess the nature and purpose of their transactions.
Conducting more thorough background checks on high-risk customers, including politically exposed persons (PEPs) and customers from high-risk jurisdictions.
Implementing enhanced transaction monitoring and scrutiny for transactions involving high-risk customers or unusual patterns of activity.

7. Transaction Monitoring

The Company shall implement robust systems and controls to monitor transactions for suspicious activities, including but not limited to:

Monitoring transactions for unusual or suspicious patterns of activity that may indicate potential money laundering or terrorist financing.
Conducting ongoing reviews and analyses of customer transactions to identify anomalies or red flags.
Using automated transaction monitoring tools and systems to enhance the effectiveness and efficiency of transaction monitoring processes.

Any transactions identified as suspicious or unusual shall be promptly investigated, and appropriate action shall be taken in accordance with the Company's policies and procedures.

8. Reporting Procedures

Employees of the Company are required to report any suspicions or knowledge of money laundering or terrorist financing activities to the designated Money Laundering Reporting Officer (MLRO) or the appropriate compliance officer. Suspicious activity reports (SARs) shall be filed with the Financial Intelligence Unit-India (FIU-IND) or other relevant authorities as required by law.

The Company shall ensure that employees are aware of their obligations to report suspicious activities and provide them with the necessary training and guidance to fulfill these obligations effectively.

9. Recordkeeping

The Company shall maintain accurate and up-to-date records of customer due diligence, transaction monitoring, and suspicious activity reports (SARs) as required by law. Records shall be retained for the prescribed period as per regulatory requirements and made available to regulatory authorities upon request.

10. Training and Awareness

The Company shall provide regular training and awareness programs to employees to ensure they understand their AML/CFT obligations and are equipped to identify and report suspicious activities effectively. Training programs shall cover topics such as:

The nature and risks of money laundering and terrorist financing activities.
The Company's AML/CFT policies, procedures, and controls.
Customer due diligence (CDD) and enhanced due diligence (EDD) requirements.
Transaction monitoring and reporting procedures.
Employee roles and responsibilities in combating money laundering and terrorist financing.

11. Compliance Monitoring and Review

The Company shall conduct periodic reviews and assessments of its AML/CFT policies, procedures, and controls to ensure their effectiveness and compliance with regulatory requirements. Compliance monitoring activities shall include:

Conducting internal audits and reviews of AML/CFT controls and processes.
Assessing the adequacy and effectiveness of existing controls in mitigating money laundering and terrorist financing risks.
Identifying any deficiencies or gaps in the Company's AML/CFT framework and implementing corrective actions as necessary.

12. Cooperation with Authorities

The Company shall cooperate fully with law enforcement agencies, regulatory authorities, and other financial institutions in the investigation and prosecution of money laundering and terrorist financing activities. This includes:

Sharing information and intelligence with relevant authorities as required by law.
Responding promptly and effectively to requests for information or assistance from regulatory authorities.
Participating in joint initiatives and collaborations with other stakeholders to combat money laundering and terrorist financing activities.

13. Conclusion

This AML policy reflects Sunita Finlease Ltd.'s commitment to integrity, compliance, and ethical business conduct. All employees are expected to adhere to this policy and play their part in safeguarding the Company against the risks of money laundering and terrorist financing. By implementing robust AML/CFT measures and fostering a culture of compliance, the Company aims to uphold the highest standards of integrity and contribute to the integrity and stability of the financial system.