1.Introduction
1.1. Sunita Finlease Limited (“SFL”) is an RBI-registered Non-Banking Financial Company (“NBFC”) under the Master Direction – Reserve Bank of India (Non-Banking Financial Company– Scale Based Regulation) Directions, 2023 dated October 19, 2023 (“SBR”), categorized as a Base Layer (“NBFC-BL”), Non-Deposit Taking (“NBFC-ND”), and Investment Credit Company (“NBFC-ICC”).

2. Objective
2.1. This Policy for Monitoring Online Transactions (“Policy”) aims to monitor, detect and prevent fraudulent transactions, mitigate the risk of money laundering and terrorism financing, and track and identify suspicious online transactions. Through this Policy, SFL aims to implement processes and procedures to identify unusual patterns and anomalies in transactions, ensuring that fraud and suspicious transactions are promptly flagged and addressed, in compliance with relevant legal and regulatory standards.

2.2. This Policy is applicable to all categories of products and services offered by the SFL.

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3. Online Transaction Monitoring Systems

3.1. This Policy covers the online transactions facilitated by SFL in relation to all the loan products and services offered by SFL, including the disbursals and collections on any loan product offered to end-customers or corporate entities.

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3.2. As part of an online transaction, SFL shall ensure that any form of disbursal is only made to and from verified bank accounts, which are verified by SFL through the penny drop verification process. Further, SFL shall also ensure that the bank account details provided by its customers matches with the Know-Your-Customer (“KYC”) documents shared by the customers with SFL, in accordance with SFLs KYC Policy.

3.3. All online transactions are automatically processed through the Loan Management System SFL, and the systems do not allow any form of manual processing in relation to the transactions.

3.4. All loan disbursals are processed directly from two designated bank accounts of SFL to the verified bank accounts of borrowers without any pass through/pool account.

3.5. All collections are processed through SFL’s payment aggregators and settlements for the same are received in the designated bank accounts of SFL.

3.6. Any amount to be repaid by a third party on behalf of the borrower shall be permitted to be accepted  only from the whitelisted accounts of such third party.

3.7. SFL shall carry out monthly accounting and monitoring checks to verify all debits and credits to its bank account. 

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3.8. All online transactions shall be processed through the API provided by an RBI registered payment aggregator integrated in the platforms and applications of SFL. 

3.9. All verifications procedures required to be followed by an RBI registered payment aggregator shall be applied by SFL to all online transactions. 

3.10. SFL may impose restrictions on the quantum and frequency of online transactions (including limitation on maximum transaction amount per beneficiary per day/week/month) through the systems provided by an RBI registered payment aggregator. 

3.11. SFL shall use the ‘Risk Shield’ provided by the RBI registered payment aggregator to be used to identify suspicious transactions (Please refer to risk shield provided by a partner payment aggregator available here). In the event that risk shield of the payment aggregator flags any transaction as a ‘suspicious transaction’, such transaction is highlighted to SFL to enable its Regional Office (“RO”) and Head Office (“HO”) to review the transaction. Pursuant to the review by RO and HO of SFL, if any transaction is identified as a suspicious transaction in terms of the Prevention of Money Laundering Act, 2002, such transaction is reported to the Financial Intelligence Unit-India (“FIU-IND”).

3.12. While undertaking lending and monitoring activities, SFL shall comply with the outsourcing guidelines prescribed under the SBR.