1. "Act" and "Rules" means the Prevention of Money-Laundering Act, 2002 and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005, respectively and amendments thereto.
2. "Authentication", in the context of Aadhaar authentication, means the process as defined under sub-section (c) of section 2 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016.
3. "Board" means Board of Directors of the Company.
4. "Central KYC Records Registry" (CKYCR) means an entity defined under Rule 2(1)(aa) of the Prevention of Money Laundering Rules, to receive, store, safeguard and retrieve the KYC records in digital form of a customer.
5. "Certified Copy" means a comparative copy of the proof of possession of Aadhaar number where offline verification cannot be carried out or officially valid document so produced by the customer with the original and recording the same on the copy by the authorized officer of the company.
6. "Company" means Moneygear Fintech Private Limited
7. "Customer" means a person who is engaged in a financial transaction or activity with a company and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting.
8. "Customer Due Diligence (CDD)" means identifying and verifying the customer and the beneficial owner.
9. "Designated Director" means Managing Director or a whole-time Director, or any director duly authorised by the Board of Directors of the Company to ensure overall compliance with the obligations imposed under chapter IV of the Prevention of Money Laundering Act and the Rules;
   Explanation:
   1. For the purpose of this clause, the terms "Managing Director" and "Whole-time Director" shall have the meaning assigned to them in the Companies Act, 2013.
   2. "Directors" means individual Directors or Directors on the Board of the Company.
10. "Digital KYC" means the capturing live photo of the customer and officially valid document or the proof of possession of Aadhaar, where offline verification cannot be carried out, along with the latitude and longitude of the location where such live photo is being taken by an authorised officer of the RE as per the provisions contained in the Act.
11. "Digital Signature" shall have the same meaning as assigned to it in clause (p) of subsection (1) of Section (2) of the Information Technology Act, 2000.
12. "Equivalent e-document" means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the customer as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016.
13. "Know Your Client (KYC) Identifier" means the unique number or code assigned to a customer by the Central KYC Records Registry.
14. "Non-face-to-face Customers" mean customers who open accounts without visiting the branch/offices of the Company or meeting the officials of the Company.
15. "Officially Valid Document" (OVD) means Passport, Driving license, Proof of possession of Aadhaar Number, Voter's Identity Card issued by the Election Commission of India, Job card issued by NREGA duly signed by an officer of the State Government and letter issued by the National Population Register containing details of name and address.
    ‍
    "Provided also that where the client submits his proof of possession of Aadhaar number as an officially valid document, he may submit it in such form as are issued by the Unique Identification Authority of India".
    ‍
    Explanation:
    For the purpose of this clause, a document shall be deemed to be an OVD even if there is a change in the name subsequent to its issuance provided it is supported by a marriage certificate issued by the State Government or Gazette notification, indicating such a change of name.
16. "Person" includes an individual, a Hindu undivided family, a Company, a firm, an association of persons, a body of individuals, whether incorporated or not, or every artificial juridical person, not falling within any one of the above persons any agency, office or branch owned or controlled by any of the above persons.
17. "Periodic Updation" means steps taken to ensure that documents, data, or information collected under the CDD process are kept up-to-date and relevant by undertaking reviews of existing records at the periodicity prescribed by the Reserve Bank or act or rules.
18. "Principal Officer" means an officer nominated by the Company, responsible for furnishing information as per Rule 8 of the Rules.
19. Politically Exposed Persons ("PEP") Politically Exposed Persons are Persons who are or have been entrusted with prominent public functions in India or foreign country, e.g., Heads of States or of Governments, senior politicians (eg. MPs, MLAs, MLC, Municipal Counsellors, Panchayat President, Members), senior government/judicial/military officers, senior executives of state-owned corporations, all political party officials, Political Parties, etc.
20. "Regulated Entities" (REs) means: all Scheduled Commercial Banks (SCBs)/ Regional Rural Banks(RRBs)/ Local Area Banks (LABs)/ All Primary (Urban) Co-operative Banks (UCBs)/State and Central Cooperative Banks (St CBs / CCBs) and any other entity which has been licensed under Section 22 of Banking Regulation Act, 1949, which as a group shall be referred as 'banks' All India Financial Institutions (AIFIs) All Non-Banking Finance Companies (NBFC)s, Miscellaneous Non-Banking Companies (MNBCs) and Residuary Non-Banking Companies (RNBCs). All Payment System Providers (PSPs)/ System Participants (SPs) and Prepaid Payment Instrument Issuers (PPI Issuers) All authorized persons (APs) including those who are agents of Money Transfer Service Scheme (MTSS), regulated by the Regulator.
21. "Suspicious Transaction" means a "transaction", including an attempted transaction, whether or not made in cash, which, to a person acting in good faith: gives rise to a reasonable ground of suspicion that it may involve proceeds of an offense specified in the Schedule to the Act, regardless of the value involved; or appears to be made in circumstances of unusual or unjustified complexity, or appears to not have an economic rationale or bonafide purpose, or gives rise to a reasonable ground of suspicion that it may involve financing of the activities relating to terrorism.
    Explanation: Transaction involving financing of the activities relating to terrorism includes transactions involving funds suspected to be linked or related to, or to be used for terrorism, terrorist acts or by a terrorist, terrorist organization or those who finance or are attempting to finance terrorism.
22. "Transaction" means a purchase, sale, loan, pledge, gift, transfer, delivery or the arrangement thereof and includes:
    1. Opening of an account, or
    2. Deposit, withdrawal, exchange, or transfer of funds in whatever currency, whether in cash or by cheque, payment order or other instruments or by electronic or other non-physical means, or
    3. The use of a safety deposit box or any other form of safe deposit, or
    4. Entering into any fiduciary relationship, or
    5. Any payment made or received, in whole or in part, for any contractual or other legal obligation, or
    6. Establishing or creating a legal person or legal arrangement.
23. "Video-based Customer Identification Process (V-CIP)" means a method of customer identification by an official of the company by undertaking seamless, secure, real-time, consent based audio-visual interaction with the customer to obtain identification information including the documents required for CDD purpose, and to ascertain the veracity of the information furnished by the customer.

1. Customer Acceptance Policy
2. Customer identification Procedures
3. Monitoring of Transactions
4. Risk Management

1. No loan account is opened in anonymous or fictitious / benami name(s). The Company shall insist on sufficient proof about the identity of the customer to ensure his physical and legal existence at the time of accepting the application form from any customer.
2. Documentation requirements and other information to be collected in respect of different categories of customers depending on perceived risk and keeping in mind the requirements of PML Act, 2002 and guidelines issued by Reserve Bank from time to time.
3. Parameters of risk perception are clearly defined in terms of the nature of business activity, location of customer and his clients, mode of payments, volume of turnover, social and financial status etc., to enable categorization of customers into low, medium, and high risk. Customers requiring very high level of monitoring, e.g. Politically Exposed Persons may, if considered necessary, be categorized even higher.
4. CDD procedure is applied at the unique customer identification number level. This way, if an existing KYC compliant customer wishes to avail another loan from the Company, there will be no need for a fresh CDD exercise.
5. Customers would be categorized as low, medium and high risk.
6. No transaction or account-based relationship is undertaken without following the CDD procedure.
7. CDD procedure is applied at the UCIC level. This way, if an existing KYC compliant customer wishes to avail another loan from the Company, there will be no need for a fresh CDD exercise.
8. The mandatory information to be sought for KYC purposes while opening an account and during the periodic updation, is specified.
9. The Company will not open an account or close an existing account where it is unable to apply appropriate customer due diligence measures i.e. it is unable to verify the identity and /or obtain documents required as per the risk categorization due to non-cooperation of the customer or non reliability of the data / information furnished to the Company. It may, however, be necessary to have suitable built-in safeguards to avoid harassment of the customer. For example, the decision to close an account will be taken at a reasonably high level after giving due notice to the customer explaining the reasons for such a decision.
10. CDD Procedure is followed for all the joint accountholders, co-applicants and guarantor(s) while opening a joint account.
11. Circumstances in which a customer is permitted to act on behalf of another person/entity will be clearly spelt out in conformity with the established law and practices, as there could be occasions when an Loan account is operated by a mandate holder or where an account may be opened by an intermediary in a fiduciary capacity.
12. A system is required to be put in place for periodical review of risk categorization of accounts and the need for applying enhanced due diligence measures in case of higher risk perception on a customer. Such review of risk categorization of customers should be carried out at regular intervals as prescribed by Risk Department of the company.
13. Where an equivalent e-document is obtained from the customer, the company will verify the digital signature as per the provisions of the Information Technology Act, 2000.

1. The first requirement of customer identification procedures to be satisfied is that a prospective customer is the person who he / she claims to be.
2. The second requirement of customer identification procedures is to ensure that sufficient information is obtained on the nature of the business that the customer expects to undertake, and any expected or predictable pattern of transactions.
3. Identity shall be verified for:
   1. The named account holder.
   2. Beneficial owners.
   3. Signatories to an account.
   4. Intermediate parties.

1. CDDin case of new customer on-boarding for individual customers, proprietor incase of proprietorship firm, authorised signatories and Beneficial Owners (BOs) in case of Legal Entity (LE) customers. Provided that in case of CDD of a proprietorship firm, the Company shall also obtain the equivalent e-document of the activity proofs with respect to the proprietorship firm, as mentioned inSection 28 of the Master Directions on KYC, apart from undertaking CDD of the proprietor.
2. Conversion of existing accounts opened in non-face to face mode using Aadhaar OTP based e-KYC authentication as per Section 17 of the Master Directions on KYC.
3. Updation / Periodic updation of KYC for eligible customers.

1. The official of the “MoneyGear” performing the V-CIP shall record video as well as capture a photograph of the customer present for identification and obtain the identification through Offline Verification of Aadhaar.
2. “MoneyGear” shall capture a clear image of the PAN card to be displayed by the customer during the process, except in cases where e-PAN is provided by the customer. The PAN details shall be verified from the database of the issuing authority.
3. Live location of the customer (Geotagging) shall be captured to ensure physical presence in India.
4. The official of the “MoneyGear” shall ensure that the photograph of the customer in the Aadhaar / PAN details matches with the customer undertaking the V-CIP and the identification details in Aadhaar / PAN shall match with the details provided by the customer.
5. The official oft he “MoneyGear” shall ensure that the sequence and/or type of questions during video interactions are varied in order to establish that the interactions are real-time and not pre-recorded.
6. All accounts opened through V-CIP shall be made operational only after being subject to concurrent audit, to ensure the integrity of process. RE shall ensure that the process is a seamless, real-time, secured, end-to-end encrypted audiovisual interaction with the customer and the quality of the communication is adequate to allow identification of the customer beyond doubt. RE shall carry out the liveliness check in order to guard against spoofing and such other fraudulent manipulations.
7. To ensure security, robustness and end to end encryption, the REs shall carry out software and security audit and validation of the V-CIP application before rolling it out.
8. The audio visual interaction shall be triggered from the domain of the RE itself, and not from third party service provider, if any. The V-CIP process shall be operated by officials specifically trained for this purpose. The activity log along with the credentials of the official performing the V-CIP shall be preserved.
9. "MoneyGear” shall ensure that the video recording is stored in a safe and secure manner and bears the date and time stamp.
10. "MoneyGear” are encouraged to take assistance of the latest available technology, including Artificial Intelligence (AI) and face matching technologies, to ensure the integrity of the process as well as the information furnished by the customer. However, the responsibility of customer identification shall rest with the “MoneyGear”.
11. "MoneyGear” shall ensure to redact or blackout the Aadhaar number in terms of Section 16.

1. Originals of the KYC documents shall be verified by officials of the Company and copies thereof shall be obtained and retained with the Company. Such copies shall be attested by theCompany officials certifying that they have been verified with the originals.
2. KYC documents so obtained shall be properly arranged and filed in order so that they shall be available for verification any time.
3. Company’s Internal Auditors/Management shall ensure an independent evaluation of compliance of KYC/AML policy including legal and regulatory requirements. They shall reportLapses observed in this regard as Irregularities in their Audit Reports.
4. Adverse features noted by the Internal Auditors/ Management shall be brought to the attention of the Principal Officer.
5. Summary of serious Irregularities/deviations shall be placed before the Audit Committee of the Board by the Internal Audit Department at quarterly intervals.
6. Review of implementation of KYC/AML guidelines shall also be placed before the AuditCommittee of the Board by the Principal Officer at quarterly intervals.
7. The Company shall have an on-going employee training programme so that members of the staff are adequately trained in KYC/AML procedures.
8. The Principal Officer designated by the Company in this regard shall have responsibility in managing oversight and coordinating with various functionaries in the implementation ofKYC/AML Policy.
9. Designated Director shall be responsible for the overall compliance with the obligations under the Act and Rules.

1. “MoneyGear” to devise a procedure for creating Risk Profiles of their new customers based on risk categorization. The Company shall categorize the customers according to the risk perceived to facilitate undertaking due diligence for the purpose of risk categorization. The customer profile shall contain amongst others information relating to the customer’s identity, social/ financial status, nature of the business activity, information about the customer’ clients’ business and their location, etc.
2. Further, the Company shall seek information from its customers which is relevant for the loan and is in conformity with the guidelines. The customer’s profile with the Company shall remain a confidential document and the information shall not be divulged for cross-selling or any other purpose.
3. MoneyGear shall categorize the risk profile of individual customers into 2 (two)basic categories in order of the profile. The categories are as below:

1. The extent of due diligence requirement will vary from case to case as the same will depend upon risk perceived by the Company while granting credit facilities to customers.
2. For the purpose of preparing customer profile only such relevant information from the customers will be sought based on which the Company can easily decide about the risk category in which the customers are to be placed.
3. “MoneyGear” has formulated an indicative list of customers and their respective risk categories. The same is attached as Annexure - C to this Policy.

1. The company shall obtain self-declaration from Individual customers and non-Individual customers in case of no change in their KYC details. However, in case of change in address of individual customer a self-declaration of such change and proof of new address to be obtained from customer’s registered email id and the declared address shall be verified through positive confirmation within two months, by means such as address verification letter, contact point verification, deliverables etc.
2. The Company may obtain a copy of OVD or deemed OVD or the equivalent e-documents thereof, as defined in Section 3(a)(xiii) of Master Direction on KYC, for the purpose of proof of address, declared by the customer at the time of periodic updation.
3. In case of change in KYC information of non-individual customer, the Company shall undertake a KYC process which shall be equivalent to on-boarding a new customer.

1. All cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency.
2. All series of cash transactions integrally connected to each other which have been valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the aggregate value of such transactions exceeds rupees ten lakh.
3. All transactions involving receipts by non-profit organizations of rupees ten lakhs or its equivalent in foreign currency.
4. All suspicious transactions, where forged or counterfeit currency notes or bank note shave been used as genuine and where any forgery of a valuable security has taken place.
5. All suspicious transactions whether or not made in cash and by way of as mentioned in the Rules.

1. The nature of transactions.
2. The amount of the transaction and the currency in which it was denominated.
3. All transactions involving receipts by non-profit organizations of rupees ten lakhs or its equivalent in foreign currency.
4. The date on which the transaction was conducted.
5. The parties to the transaction.

1. The Company shall carry out ‘Money Laundering (ML) and Terrorist Financing (TF)Risk Assessment’ exercise periodically to identify, assess and take effective measures to mitigate its money laundering and terrorist financing risk for clients, countries or geographic areas, products, services, transactions or delivery channels, etc. The assessment process will consider all the relevant risk factors before determining the level of overall risk and the appropriate level and type of mitigation to be applied. While preparing the internal risk assessment, the Company will take cognizance of the overall sector-specific vulnerabilities, if any, that the regulator/supervisor may share with theCompany from time to time.
2. The risk assessment exercise by the Company shall be properly documented and be proportionate to the nature, size, geographical presence, complexity of activities/structure, etc. of the Company. Further, the periodicity of risk assessment exercise shall be determined by the Board of the company, in alignment with the outcome of the risk assessment exercise. However, it will be reviewed at least annually.
3. The outcome of the exercise shall be put up to the Board or any committee of the Board to which power in this regard has been delegated and will be available to competent authorities and self-regulating bodies.

1. Verify Identity:
   1. Obtain and file legible copies of corporate formation and registration documents or public company prospectuses and government filings.
   2. PAN card of the Directors etc.
   3. Wherever possible (in the case of privately owned entities), arrange for a recommendation from legal counsel to the company.
   4. Wherever possible (in the case of privately owned entities), obtain from appropriate government entity confirmation of due incorporation and existence of the corporation.
   5. Wherever possible (in the case of privately owned entities), Verify the identity of All directors, Shareholders, UBO of body corporate through various online sources. The following due diligence must also be performed on prospective Business Partners.
2. Verify Source of Income:
   1. Research for the Company details in available news or business databases and obtain all corporate earnings information available.

1. Secondly, to curb and prevent any such practice by the customers which is aimed to achieve unlawful objectives or any other practice by which the financial institutions can be used to perpetuate any criminal or unlawful activities. However, at the same time, this policy does not aim or intend to deny the benefit of financial services to those who genuinely need such services / facilities due to real lack of their own sufficient financial resources.

1. There is a change in information of customer as existing in the records of CKYCR.
2. The current address of customer needs to be verified.
3. It is considered necessary to verify identity or address of customer, or to perform enhanced due diligence or to build an appropriate risk profile of the client.

1. Permanent Account Number (with photo and signature) or Form 60.
2. One certified copy of an Officially Valid Document (OVD”) containing details of the borrower’s identity for legal name, and any other names used and address:
   1. Proof of possession of Aadhaar number in such form as are issued by the Unique Identification Authority of India.
   2. Valid Indian Passport (with photo and signature)
   3. Valid Voter’s ID card issued by the Election Commission of India
   4. Valid Permanent Driving License (with photo and signature)
   5. Letter issued by the National Population Register containing details of name and address.

1. Bank Account Statement
2. Letter from any recognised public authority
3. Utility Bill not more than two months old (electricity, telephone, post-paid mobile phone, piped gas, water bill) of any service provider
4. Property or Municipal tax receipt

1. Property (including land) registration document containing photograph, name, signature and address.
2. Letter from employer (subject to satisfaction of the Company).

1. Valid Indian Passport
2. Valid PAN card
3. Valid Permanent Driving license
4. Banker's letter/ verification letter/ ECS verification in original on Bank’s letter head bearing the authorising officer’s name and signature along with the stamp of the bank. In case the Bank refuses to give the signature verification on the Bank’s letter head, then Signature/ECS verification shall be obtained in the format prescribed for the said purpose.
5. Property registration document containing photograph, name, signature and address

1. Proof of possession of Aadhaar number in such form as are issued by the UniqueIdentification Authority of India.
2. Valid Passport (with photo and signature)
3. Valid Voter’s ID card issued by the Election Commission of India
4. Valid Permanent Driving License (with photo and signature)
5. Letter issued by the National Population Register containing details of name and address.

1. Proof of the name, address and activity of the entity, like GST certificate or Shop &establishment license or any registration/licensing document issued in the name of the proprietary concern by the Central Government or State Government Authority / Department.
2. Utility bills such as electricity, water, and landline telephone bills in the name of the proprietary concern.

1. Pan card of all the partners
   1. Address proof as applicable for an individual account.
   2. The two latest passport size photographs.

1. Permanent Account Number of the partnership firm.
   
2. Proof of the name, address and activity of the entity, like GST certificate or Shop & establishment license or Any registration / licensing document issued in the name of the partnership firm by the Central Government or State Government Authority / Department.
3. Partnership deed
4. Authority Letter signed by all the partners.
5. The complete Income Tax return of last three years if it is applicable or such lesser period (not just the acknowledgement) in the where the firm's income is reflected duly authenticated / acknowledged by the Income Tax Authorities.
6. Utility bills such as electricity, water, and landline telephone bills in the name of the partnership firm.
7. Any other prescribed equivalent e-documents.

1. Basic documents of company i.e. Certificate of incorporation, Memorandum & Articles of Association, Permanent Account Number of the company & Any license or registration certificate by central government state government or any regulatory authority of India.
2. Resolution by the Board of Directors to obtain a loan from MoneyGear and authority to any director or employee to act on behalf of the company.
3. One Proof of identity (PAN CARD), Proof of address, and a Colored recent passport size photograph of the authorized person.
4. List of Directors as on date.
5. List of Shareholders.
6. Financials statement along with the statutory company’s auditor report of the latest preceding completed financial year.
7. Income tax return of last 3 years or such a lesser period as may be applicable along with the Tax audit report.
8. Any other prescribed equivalent e-documents.

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1. Offline verification of a customer may be carried out, if the customer desires to undergo Aadhaar offline verification for identification purpose. Offline Verification means the process of verifying the identity of the Aadhaar number holder without authentication, through such offline modes as may be specified by the Aadhaar regulations.
2. Accounts opened using OTP based e-KYC shall not be allowed for more than one year unless identification as per Annexure - B, V-CIP is carried out.
3. If Aadhaar details are used for V-CIP, the process shall be followed in its entirety including fresh Aadhaar OTP authentication.
4. The Company may undertake V-CIP to carry out:
   1. CDD in case of new customer on-boarding for individual customers, proprietor in case of proprietorship firm, authorised signatories and Beneficial Owners (BOs) in case of Legal Entity (LE) customers.
   2. Provided that in case of CDD of a proprietorship firm, the Company shall also obtain the equivalent e-document of the activity proofs with respect to the proprietorship firm, as mentioned in Annexure A, apart from undertaking CDD of the proprietor.
   3. Conversion of existing accounts opened in non-face to face mode using Aadhaar OTP based e-KYC authentication shall be subject to conditions laid down in Master Directions, updated from time to time. i. Updation / Periodic updation of KYC for eligible customers.
   4. Updation /Periodic updation of KYC for eligible customers.
5. In case the CDD is outsourced, then the records or the information of the customer due diligence carried out by the third party should be obtained within reasonable time from the third party or from the Central KYC Records Registry.
6. Incase the CDD is outsourced, the decision making functions of determining compliance with KYC norms should not be outsourced.
7. CDD procedure should be applied at the UCIC level and if an existing KYC complaint customer of the Company desires to open another account, there shall be no need for a fresh CDD exercise.
8. Incase the identity information relating to the Aadhaar number or PermanentAccount Number submitted by the customer does not have a current address, other current address proof defined under Annexure-A shall be obtained from the customer for this purpose.
9. CDD procedure shall be followed for all joint account holders, while opening a joint account.
10. The Company can establish relationship with Politically Exposed Persons (PEPs) provided that:
    1. Sufficient information including information about the sources of funds accounts of family members and close relatives is gathered on the PEP.
    2. The identity of the person shall have been verified before accepting the PEP as a customer.
    3. The decision to open an account for a PEP is taken at a senior level in accordance with the Company’s Customer Acceptance Policy; senior level for this purpose shall include HOD & above.
    4. All such accounts are subjected to enhanced monitoring on an on-going basis.
    5. In the event of an existing customer or the beneficial owner of an existing account subsequently becoming a PEP, senior management’s approval is obtained to continue the business relationship.

1. Individuals and entities in various United Nations' Security Council Resolutions(UNSCRs) such as UN 1267 etc.
2. Individuals or entities listed in the schedule to the order under section 51A of theUnlawful Activities (Prevention) Act, 1967 relating to the purposes of prevention of, and for coping with terrorist activities.
3. Individuals and entities in watch lists issued by Interpol and other similar international organizations; - Customers with dubious reputation as per public information available or commercially available watch lists; - Individuals and entities specifically identified by regulators, FIU and other competent authorities as high-risk.
4. Customers conducting their business relationship or transactions in unusual circumstances, such as significant and unexplained geographic distance between the institution and the location of the customer, frequent and unexplained movement of accounts to different institutions, etc.
5. Politically exposed persons (PEPs), customers who are close relatives of PEPs and accounts of which a PEP is the ultimate beneficial owner.
6. Non-face-to-face customers.
7. High net worth individuals.
8. Firms with 'sleeping partners'.
9. Companies having close family shareholding or beneficial ownership.
10. Complex business ownership structures, which can make it easier to conceal underlying beneficiaries, where there is no legitimate commercial rationale.
11. Shell companies which have no physical presence in branch locations. The existence simply of a local agent or low-level staff does not constitute physical presence.
12. Accounts for "gatekeepers" such as accountants, lawyers, or other professionals for their clients where the identity of the underlying client is not disclosed to the Company.
13. Client Accounts managed by professional service providers such as law firms, accountants, agents, brokers, fund managers, trustees, custodians etc.
14. Gambling/gaming including “Junket Operators” arranging gambling tours.
15. Jewelers and Bullion Dealers; - Dealers in high value or precious goods (e.g. gem and precious metals dealers, art and antique dealers and auction houses, estate agents and real estate brokers).
16. Customers engaged in a business which is associated with higher levels of corruption(e.g., arms manufacturers, dealers and intermediaries).
17. Customers engaged in industries that might relate to nuclear proliferation activities or explosives.
18. Customers that may appear to be Multi-level marketing companies etc.
19. Individual, who is a prisoner in jail.

1. Stock brokerage
2. Import / Export
3. Gas Station
4. Car / Boat / Plane Dealerships
5. Electronics (wholesale)
6. Travel Agency
7. Telemarketers
8. Providers of telecommunications service, internet café, International direct dialing (IDD) call service