Anti-Money Laundering (AML) & Transaction Monitoring Policy

1.1 This Policy establishes the framework adopted by Bani Global Industries LLP (“Company”) for the prevention, detection, and reporting of activities that may constitute money laundering, financing of unlawful activities, fraud, or other financial crimes through the Stamp Mitra platform (“Platform”).

1.2 This Policy applies to all Users, transactions, and interactions conducted on or through the Platform and shall be read in conjunction with applicable laws, payment network rules, and internal risk controls.

1.3 The Company operates as a technology-enabled facilitation platform and not as a financial institution; however, it adopts reasonable safeguards to prevent misuse of its services.

2.1 This Policy is aligned with applicable Indian laws and regulatory expectations, including principles derived from anti-money laundering frameworks, payment system guidelines, and risk management standards.

2.2 The Company shall cooperate with:

• Banks and payment aggregators
• Payment networks
• Law enforcement agencies
• Competent regulatory authorities

to the extent required under applicable law.

3.1 The Company adopts a risk-based monitoring framework, whereby transactions are assessed based on indicators such as:

• Transaction value and frequency
• Velocity and repetition patterns
• Geographic inconsistencies
• Device and behavioral anomalies
• Payment failures or reversals

3.2 Transactions may be categorized as Low Risk, Medium Risk, or High Risk based on internal scoring mechanisms.

4.1 The Platform may deploy automated and manual monitoring systems to identify unusual or suspicious patterns.

4.2 Monitoring may include, without limitation:

• Rapid repeat transactions
• Multiple transactions from same identifiers
• Unusual order patterns inconsistent with normal usage
• Attempts to bypass controls

4.3 The Company reserves the right to continuously refine monitoring criteria without prior notice.

5.1 The Company may implement verification measures including:

• Mobile number authentication (OTP)
• Identity verification (where applicable)
• Additional documentation requests for high-risk cases

5.2 Enhanced Due Diligence (EDD) may be applied where risk indicators are elevated.

5.3 Failure to comply with verification requests may result in suspension or termination of services.

6.1 The Company may, at its sole discretion:

1. Place temporary or permanent holds on transactions
2. Delay or suspend order processing
3. Decline or cancel transactions
4. Restrict user access or block accounts
5. Limit transaction volume or frequency

6.2 The Company may reverse transactions where permitted by payment gateway rules and applicable law.

7.1 Where required, the Company may report suspicious transactions or activities to payment gateway partners, banking institutions, law enforcement agencies, or competent authorities.

7.2 Such reporting may be undertaken without prior notice to the User, where permitted or required by law.

8.1 The Company may maintain transaction logs, audit trails, and monitoring records for compliance purposes, investigation and dispute resolution, and legal and regulatory requirements.

8.2 Records may include transaction details, device and session information, and verification logs.

Without limitation, the following activities are prohibited:

• Use of stolen or unauthorized payment instruments
• Structuring transactions to evade monitoring thresholds
• Identity misrepresentation or impersonation
• Use of Platform for illegal or fraudulent documentation

11.1 In case of suspected or confirmed violations, the Company may suspend or terminate access, cancel orders without refund (where applicable), initiate legal proceedings, or report the matter to authorities.

11.2 The Company reserves the right to recover losses arising from misuse.

12.1 The Company shall not be liable for delays caused due to verification or investigation, transaction rejection or suspension, or loss arising from enforcement actions taken in good faith.

12.2 The Company acts in compliance with legal and risk obligations and retains discretion in enforcement decisions.

13.1 Information collected for AML purposes shall be handled in accordance with the Platform’s Privacy Policy.

13.2 Data may be shared with authorized entities where required for compliance or investigation.