Anti-Money Laundering (AML) Policy

1. Introduction

At Zephyrtech, we are fully aware of the risks associated with money laundering and the financing of terrorism on internet platforms. In compliance with the Prevention of Money Laundering Act (PMLA), 2002, and the directives issued by the Financial Intelligence Unit – India (FIU-IND), we are committed to identifying, preventing, and reporting any activities that may be linked to financial crimes. This Anti-Money Laundering Policy formalizes our company's dedication to statutory compliance and establishes the internal framework required to detect and report suspicious activity, thereby safeguarding the integrity of our business operations.

 

2. Scope

This AML policy applies directly to:

  • All registered customers and buyers using “zephyrtech.in”
  • All self-employed sellers and merchants registered on the platform
  • All employees, representatives, and authorized agents of “zephyrtech.in”
  • All payment gateway providers and logistics partners engaged in processing transactions and fulfilling orders

The mandates of this policy extend to every financial transaction and customer interaction executed through “zephyrtech.in” platform.

 

3. Definitions

  • Money Laundering: The process of concealing the illicit origins of illegally obtained funds.
  • Terrorist Financing: The provision of funds, from either internal or external sources, to finance terrorist acts or organizations.
  • Politically Exposed Persons (PEPs): Individuals who are or have been entrusted with prominent public functions.

 

4. AML Objectives

The primary objective of this policy is to prevent Zephyrtech services from being utilized for money laundering or terrorist financing. We aim to actively detect and report any suspicious activities conducted on our platform that do not comply with the Prevention of Money Laundering Act (PMLA), 2002. Our company ensures that all transactions processed through our website align strictly with legal and regulatory standards. Furthermore, we provide mandatory, regular training to our workforce to ensure they can effectively recognize and mitigate AML risks.

 

5. Customer Due Diligence (CDD)/ Know Your Customer (KYC)

To maintain complete operational transparency and protect our platform from illicit activities, we implement rigorous CDD protocols for all buyers and sellers.

The core components of this process include:

 

  • Identity Verification: Collecting official government-issued identity proofs (Aadhaar, PAN, Passport) and address verification documents during customer registration, seller onboarding, and high-value transactions.
  • Risk-Based Customer Classification: Categorizing customers and sellers into low, medium, or high-risk profiles based on their transactional behavior, geographic patterns, and business type.
  • Increased Due Diligence (EDD): Applying enhanced verification measures, mandatory source-of-funds declarations, and continuous monitoring for any high-risk entities.
  • Continuous Due Diligence: Periodically reviewing and updating customer and merchant information to ensure all records remain accurate and current.

 

-CDD protocols guarantee that the identities of both buyers and sellers are firmly established before any financial transaction is authorized.

 

6. Appointment of a Principal Officer

A dedicated Principal Officer has been appointed to manage our AML operations and oversee institutional compliance obligations.

The responsibilities of this role include:

  • Formulating and implementing robust AML policies and compliance procedures.
  • Monitoring high-value transactions and identifying anomalous account behavior.
  • Reviewing transaction patterns and reporting trends indicative of money laundering or suspicious activity.
  • Filing Suspicious Transaction Reports (STRs) along with other mandatory regulatory filings.
  • Serving as the primary point of contact for all AML compliance issues, law enforcement queries, and regulatory authorities.

 

7. Record Keeping

Zephyrtech maintains comprehensive records of all transactions to assist in the detection, prevention, and investigation of financial crimes.

Our record retention framework requires:

  • Retaining all KYC information, official identification documents, and CDD/EDD evaluation reports for at least 3 years after the business relationship has officially ended.
  • Preserving complete records of all buy and sell transactions, including total amounts, participating parties, exact timestamps, and chosen payment methods.
  • Archiving detailed records of any transactions flags as suspicious, including the underlying reasons for concern, reporting timelines, and internal actions taken.

 

8. Suspicious Transaction Monitoring and Reporting

We proactively track, analyze, and report suspicious activities on our website by utilizing:

  • Real-time transaction monitoring systems.
  • Behavioral analysis focused on identifying transaction patterns that deviate significantly from historical data or declared business profiles.
  • The swift submission of Suspicious Transaction Reports (STRs) whenever suspicious activity is confirmed.

 

9. Employee Training & Awareness

Zephyrtech provides continuous educational training to ensure its representatives and employees fully understand their duties under the law to prevent money laundering and terrorist financing.

This program features:

  • Compulsory AML Training Programs for all staff members.
  • Practical Workshops focused on real-world risk scenarios.
  • Regular Policy Updates to address shifting regulatory landscapes.
  • Clear Whistleblower Protection guidelines to ensure safe internal reporting.

 

10. Internal Controls and Audits

We deploy stringent internal controls designed to uncover and mitigate AML risks. This includes scheduling periodic independent audits to objectively assess the performance and overall effectiveness of our AML program.

 

11. Non-Compliance and Disciplinary Actions

Any failure to adhere to the terms of this policy will result in swift disciplinary action. This may include the immediate termination of employment, formal legal proceedings, and the enforcement of regulatory penalties against any involved parties.

 

12. Policy Review and Updates

This policy is scheduled for a formal review on an annual basis, or more frequently as required, to ensure it remains aligned with evolving laws, regulatory mandates, and overall business activities.