AML

Gigico Innovations Pvt Ltd

Version 2025  | Effective From: 19 February 2025 |  Last Reviewed: 2026

1. Introduction

At Gigico Innovations Pvt Ltd, we are committed to preventing Anti-Money laundering (AML) across our digital platform. This Policy is governed by the Prevention of Money Laundering Act (PMLA), 2002, the principal legislation, as amended by the PMLA Amendment Act, 2012, and updated via the Finance Acts of 2015, 2019, 2023 and 2025. It also aligns with the PMLA Rules, 2005 (amended through 2023), RBI KYC Master Directions 2016 (updated 2024), FIU-IND Master Guidelines, and FATF Recommendations 2012 (revised October 2024). Our risk-based approach (RBA) formalises internal controls for detecting, preventing, and reporting financial crime.

2. Scope

This AML and other inclusive Policy applies to:

•        All registered customers, vendors, and merchants on the website and organisation related and built under the website and its organisation: “gigicocart.com”/Gigico Innovations Pvt Ltd.

•        Employees, representatives, contractors, and authorised agents of Gigico Innovations Pvt Ltd.

•        Payment aggregators, acquiring banks, escrow providers, and payment gateway partners

•        Third-party logistics (3PL) and fulfilment partners engaged in order processing

The Policy governs all transactions, including digital wallet operations, BBPS bill payments, prepaid card issuances, and marketplace transactions conducted via Gigico Innovations Pvt Ltd.

3. Definitions

•        Money Laundering (ML): Concealing, layering, or integrating proceeds of crime (predicate offences per PMLA Schedule) into the legitimate financial system with this criminalised under Section 3 of the PMLA, 2002

•        Terrorist Financing (TF) CFT: Providing or collecting funds to support terrorist acts or organisations, criminalised under the UAPA, 1967

•        Politically Exposed Persons (PEPs): Individuals entrusted with prominent public functions domestically or abroad, including their close associates and family members, per RBI KYC Master Directions (2024).

•        Beneficial Owner (BO): The natural person(s) who ultimately owns or controls a customer, per Rule 9(3) of the PML Rules and Section 12A of the PMLA.

•        Suspicious Transaction (ST): Any transaction giving reasonable grounds for suspicion of AML involvement, per Rule 2(1)(g) of the PML Rules, 2005.

•        Virtual Digital Assets (VDAs): As defined under Section 2(47A) of the Income Tax Act, 1961 (Finance Act, 2022), subject to PMLA reporting obligations (MoF notification, March 2023).

4. AML Objectives

The Company aims to:

•        Prevent the platform from being used for AML or proliferation financing

•        Comply fully with the PMLA, PML Rules, RBI KYC Master Directions, FIU-IND guidelines, and FATF Recommendations

•        Implement CDD, Enhanced Due Diligence (EDD), and Simplified Due Diligence (SDD) protocols proportionate to assessed risk

•        File all mandatory regulatory reports -STRs, CTRs, CBWTRs, and NTRs, via the FINnet 2.0 portal within prescribed timelines

•        Foster an organisation-wide culture of AML compliance through training and accountability

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

In compliance with RBI KYC Master Directions (2016, updated 2024) and the PML Rules, the Company applies a risk-proportionate CDD framework:

•        Identity Verification (IDV): Collection and verification of Officially Valid Documents (OVDs) with the Aadhaar (UIDAI-compliant masked Aadhaar), PAN, Passport, Driving Licence, or Voter ID - at onboarding and for high-value transactions. Video-based KYC (V-CIP) is deployed per RBI Circular RBI/2019-20/170.

•        Risk-Based Segmentation: Customers are classified as Low, Medium, or High risk based on transaction behaviour, geographic risk (FATF-listed jurisdictions, UNSC-designated countries), PEP status, and adverse media screening.

•        Enhanced Due Diligence (EDD): Mandatory for High-risk customers, PEPs, non-residents, and transactions from FATF grey/black-listed jurisdictions, requiring Source Of Wealth (SOW) and Source Of Funds (SOF) declarations with senior management approval.

•        Ongoing CDD (OCDD): Periodic re-KYC is crucial annually for High-risk, every two years for Medium, every five years for Low-risk customers - with continuous real-time screening against UNSC, OFAC SDN, and MHA/MEA Designated Persons lists.

6. Appointment of a Principal Officer

In compliance with Sections 12 and 12A of the PMLA and Rule 7 of the PML Rules, 2005, a designated Principal Officer (PO) is responsible for:

•        Formulating and implementing AML/CFT policies and internal controls in line with PMLA, FIU-IND directives, and FATF Recommendations

•        Overseeing the Transaction Monitoring System (TMS) and reviewing alerts for AML indicators

•        Filing STRs, CTRs, CBWTRs, and NTRs with FIU-IND via FINnet 2.0 within prescribed timeframes

•        Serving as the primary liaison with FIU-IND, the Enforcement Directorate (ED), and other regulatory bodies

•        Ensuring whistleblower protection for staff raising AML concerns in good faith

7. Record Keeping

Per Section 12 of the PMLA and Rules 3 and 10 of the PML Rules, 2005, the Company retains:

•        KYC and CDD/EDD Records: All OVDs, risk assessments, and account documentation for a minimum of five (5) years after the business relationship ends

•        Transaction Records: Full transaction details, amounts, counterparties, timestamps, payment channels, IP addresses, and device identifiers and retained for five (5) years from the transaction date

•        STR and Reporting Records: All STR investigations, FINnet 2.0 filings, and regulatory correspondence retained for five (5) years, with immutable audit trails available for regulatory inspection

8. Suspicious Transaction Monitoring and Reporting

The Company employs a multi-layered monitoring framework aligned with FATF Recommendation 20:

•        Transaction Monitoring System (TMS): An automated, rule-based and ML-enhanced TMS performs real-time monitoring, applying threshold alerts, peer-group anomaly detection, and network link analysis to identify AML patterns, including structuring, smurfing, and layering

•        Sanctions Screening: Real-time screening of all customers and transactions against UNSC Consolidated List, OFAC SDN List, and MHA/MEA Designated Persons lists, with automated blocking and escalation

•        STR Filing: Suspicious transactions are reported to FIU-IND within seven (7) working days of establishing suspicion, strictly observing the tipping-off prohibition under Section 13 of the PMLA

•        CTR and CBWTR Reporting: Cash Transaction Reports (INR 10 lakh and above) and Cross Border Wire Transfer Reports (INR 5 lakh and above) are filed monthly with FIU-IND

9. Employee Training & Awareness

Pursuant to FATF Recommendation 18 and Section 12 of the PMLA, the Company maintains:

•        Mandatory AML induction training for all new employees and agents covering PMLA obligations, KYC/CDD procedures, red-flag indicators, and STR filing protocols

•        Annual recertification incorporating updates from FATFMutual Evaluation Reports, FIU-IND guidance notes, and RBI circulars

•        Role-based specialist modules for compliance officers, onboarding teams, payment operations, and senior management

•        Whistleblower protection per the Companies Act, 2013, ensuring no employee faces retaliation for reporting AML concerns in good faith

10. Internal Controls and Audits

In line with FATF Recommendation 18, the Company maintains:

•        Segregation of duties between transaction processing, compliance monitoring, and regulatory reporting functions

•        Independent annual AML audits by internal or qualified external auditors, with findings reported to senior management and the Board

•        Quarterly Compliance Committee reviews of AML risk indicators, TMS effectiveness, STR filing rates, and emerging regulatory developments

•        Documented remediation plans for all identified control deficiencies, with assigned accountability and timelines

11. Non-Compliance and Disciplinary Actions

Violations of this Policy, the PMLA, or associated regulations shall result in:

•        Employees: Disciplinary proceedings up to summary dismissal and referral to law enforcement. Criminal violations under Sections 3 and 4 of the PMLA attract rigorous imprisonment of three to seven years (extendable to ten years for scheduled offences) and monetary fines

•        Vendors and Merchants: Immediate suspension or termination of platform access, freezing of pending settlements, blacklisting, and referral to FIU-IND or law enforcement as appropriate

•        Regulatory Penalties: The Company, as a Reporting Entity, may face fines, show-cause notices, and adjudication under Section 13 of the PMLA by the Adjudicating Authority, including attachment of property for wilful or repeated non-compliance

12. Policy Review and Updates

This AML/CFT Policy shall be reviewed annually by the Compliance Officer and Compliance Committee, incorporating changes in the PMLA, PML Rules, RBI KYC Master Directions, FIU-IND guidelines, and FATF Recommendations. Ad hoc reviews are triggered by material regulatory changes, significant business model updates, or adverse audit findings. All revisions require senior management and Board approval and are communicated to all relevant personnel. Version-controlled archives are retained for a minimum of five (5) years.

GIGICO INNOVATIONS Pvt. Ltd. - 216 Main Frame-1 BLDG (WING-A), Goregaon (E), Aarey milk Colony, Mumbai, Suburban, Maharashtra - 400065  |  contactus@gigicocart.com  |  +91-7304458919