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Section 5. AML / KYC / CFT POLICY

Effective Date: May 10, 2026

5.1 Policy Statement

While FutureFunding is currently not a "reporting entity" under Section 2(1)(wa) of the PMLA, 2002, given that it does not carry on a "financial business" as defined, it voluntarily aligns with the spirit of PMLA, FATF, and FIU-IND best practice. In the event that the activity is brought within the PMLA reporting ambit by notification or regulatory clarification, FutureFunding shall register with FIU-IND and operate as a reporting entity from such date.

5.2 KYC — Mandatory Onboarding Documents

PAN

  • Verification Method: NSDL/UTIITSL real-time validation
  • Storage: Encrypted vault

Aadhaar

  • Verification Method: Offline XML / OTP-based eKYC under UIDAI rules; masked storage
  • Storage: Reference + last-4 only

Bank account

  • Verification Method: Penny-drop verification
  • Storage: Account number + IFSC

Liveness

  • Verification Method: Selfie + face-match against KYC photo
  • Storage: Hash + reference

Address

  • Verification Method: As per Aadhaar / passport / DL
  • Storage: Document image

5.3 Customer Due Diligence

Standard CDD: Identity verification + sanctions screening + PEP screening (against UN, OFAC, EU, MEA, MHA lists).

Enhanced Due Diligence (EDD) is applied when:

  • (a) User triggers any sanction/PEP/adverse-media match;
  • (b) Aggregate annual Stipend exceeds INR 25 lakh;
  • (c) Anomalous behaviour: rapid pass-and-stipend cycles, multiple challenge attempts funded from third-party UPIs, mismatched IP geography vs declared residence;
  • (d) Account linkage indicators: shared device, shared bank, shared address with other Users.

5.4 Transaction Monitoring & Red Flags

Automated and manual monitoring captures:

  • Velocity of Challenge Fee payments from same instrument across distinct accounts;
  • Unusual stipend-versus-effort ratios;
  • Round-tripping patterns (deposit → pass → stipend → outflow to high-risk geographies);
  • Reuse of bank/UPI/device across putatively distinct identities;
  • Stipend disbursement to accounts inconsistent with declared geography;
  • Pattern matching against typologies published in FIU-IND's strategic-analysis reports.

5.5 Reporting

Internal Suspicious Transaction Report (STR) templates are maintained. Where reporting becomes statutorily required, STRs shall be filed within the prescribed timeline; tipping-off is prohibited under Section 10 of PMLA. Records of suspicions, whether reported or not, are preserved for 10 years.

5.6 Sanctions & PEP Screening

Daily re-screening against:

  • UN Security Council Consolidated List;
  • MHA Banned Organizations & Individuals lists (UAPA);
  • SEBI Debarred Persons list;
  • Adverse-media checks (commercial provider).

5.7 Training & Audit

  • Annual mandatory AML training for all staff;
  • Independent internal audit every 12 months;
  • Board-level reporting via the Compliance Committee.