Anti-fraud and AML/KYC Policy

Module: CrowdFunding (UTSAV DAAN™)
Document Type: Hybrid — Plain English + Legal Reinforcement
Trademark: UTSAV DAAN™ is a registered trademark of MyMahotsav Futuretech Ltd
Jurisdictions: Global (compliant with India PMLA, UK MLR, US BSA, EU AMLD)
Version: 1.0
Effective Date: 25th February, 2026

PART A: PLAIN ENGLISH SUMMARY #

Keeping UTSAV DAAN™ Safe from Fraud and Financial Crime #

UTSAV DAAN™ takes financial crime seriously. We have systems to detect, prevent, and report fraud, money laundering, and terrorist financing.

What You Need to Know #

• We verify who you are: Before you start a Campaign or donate significant amounts, we need to confirm your identity (KYC).

• We monitor transactions: Our systems look for suspicious patterns—unusual activity gets flagged.

• We cooperate with authorities: If we detect potential money laundering or fraud, we report it to financial intelligence units as required by law.

• We block bad actors: Individuals or entities involved in fraud are permanently banned.

• We protect legitimate users: These measures protect genuine fundraisers and donors from being exploited by criminals.

PART B: LEGAL TERMS AND CONDITIONS #

1. POLICY STATEMENT #

1.1 UTSAV DAAN™ is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CFT) compliance. We implement risk-based procedures to detect, prevent, and report suspicious activities.

1.2 This Policy applies to all Users, Fundraisers, Beneficiaries, Contributors, and Support Group members.

2. KYC (KNOW YOUR CUSTOMER) REQUIREMENTS #

2.1 When KYC is Required #

2.2 KYC Documentation #

For Individuals:

• Government-issued photo ID (Passport, Driver’s License, National ID, Voter ID, Aadhaar*)

• Proof of address (utility bill, bank statement – <3 months old)

• PAN Card (India) / Tax Identification Number (other jurisdictions)

• Photograph (for verification)

• *Aadhaar used only with consent and VID where applicable

For Entities:

• Certificate of Incorporation/Registration

• Memorandum & Articles / Trust Deed

• PAN/Tax ID

• List of authorised signatories with ID proof

• Board resolution authorizing Campaign

• Proof of registered address

• Beneficial ownership declaration (>25% holders)

2.3 Verification Methods #

• Digital KYC: Video-based verification with live photo matching

• Document Verification: Automated checks for tampering/forgery

• Database Cross-check: Sanctions lists, politically exposed persons (PEP) lists

• Biometric: Where legally permitted and technically feasible

2.4 Ongoing Due Diligence #

• Periodic re-verification (every 2 years for low risk, annually for high risk)

• Transaction monitoring for unusual patterns

• Trigger-based review (material changes, suspicious activity)

3. ANTI-MONEY LAUNDERING CONTROLS #

3.1 Risk Assessment #

UTSAV DAAN™ maintains a risk-based approach considering:

3.2 Transaction Monitoring #

3.2.1 Automated monitoring flags:

• Multiple contributions from the same source to related campaigns

• Contributions just below reporting thresholds

• Rapid withdrawal requests after funding

• Inconsistent geographic patterns

• Round-dollar amounts from multiple sources

3.2.2 Manual review triggered for flagged transactions.

3.3 Suspicious Transaction Reporting #

3.3.1 When suspicious activity is identified:

• Internal investigation conducted within [48 hours]

• If confirmed, Suspicious Transaction Report (STR) filed with:

  • India: Financial Intelligence Unit (FIU-IND)

  • UK: National Crime Agency (NCA)

  • US: FinCEN

  • EU: Respective FIUs

3.3.2 Tipping off prohibition: Users must not be informed that a report has been filed.

3.4 Sanctions Screening #

All Users and Beneficiaries screened against:

• UN Security Council Sanctions List

• OFAC (US) Specially Designated Nationals List

• EU Consolidated Sanctions List

• UK Sanctions List

•  Individual country watchlists

Matches result in immediate account freezing and reporting.

4. FRAUD PREVENTION #

4.1 Types of Fraud Monitored #

4.2 Fraud Detection Measures #

• Device fingerprinting

• Behavioral analytics

• Document forensics

• Payment velocity checks

• Cross-Campaign analysis

• External database checks

• Community flagging system

4.3 Fraud Response Protocol #

Upon fraud detection:

1. Immediate freeze of Campaign/Account

2. Investigation within [72 hours]

3. Notification to affected parties (with restrictions if tipping off risk)

4. Law enforcement referral for criminal fraud

5. Permanent ban of fraudulent actors

6. Asset tracing for fund recovery, where possible

4.4 Chargeback and Dispute Management #

• Contributors must first attempt resolution through the Platform

• Evidence package prepared for payment processor disputes

• Fraudulent chargebacks (friendly fraud) contested

• Repeat abusers blocked from Platform

5. RECORD KEEPING #

5.1 UTSAV DAAN™ maintains records:

• KYC documents: Minimum 5 years after account closure

• Transaction records: Minimum 5 years (10 years for high-risk)

• STR copies: As required by law (typically 5 years)

• Investigation reports: 7 years

5.2 Records stored securely with access controls and audit trails.

6. COMPLIANCE GOVERNANCE #

6.1 Designated Compliance Officer:

• Name: [Insert Name]

• Title: [Insert Title]

• Contact: [Insert Email/Phone]

6.2 Compliance Responsibilities:

• Policy implementation and review

• STR filing oversight

• Employee training

• Regulatory liaison

• Annual independent audit

6.3 Employee Training:

• Annual AML/CFT training is mandatory

• New hire training within 30 days

• Specialised training for the compliance team

7. USER OBLIGATIONS #

7.1 Users must:

• Provide accurate, complete information

• Update information when changed

• Do not structure transactions to avoid reporting

• Report suspected fraud to the Platform

• Cooperate with investigations

7.2 Non-compliance results in:

• Account suspension

• Fund freezing

• Reporting to authorities

• Permanent ban

  PART C: JURISDICTION-SPECIFIC ADDENDUMS #

INDIA ADDENDUM #

Legal Framework:

• Prevention of Money Laundering Act, 2002 (PMLA)

• PMLA Rules, 2005

• RBI Master Direction on KYC

• FIU-IND Reporting Formats

Thresholds:

• Identity verification for all Fundraisers

• Suspicious transaction reporting mandatory

• Cash transaction limit: ₹2 lakh (where applicable)

• Cross-border wire transfer reporting

PEP Definition: Includes foreign political figures, their family members and close associates.

UK ADDENDUM #

Legal Framework:

• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017

• Proceeds of Crime Act 2002

• Terrorism Act 2000

• FCA Handbook

Thresholds: Occasional transaction > €2,000 requires CDD.

SAR Filing: Via NCA’s SAR Online system.

US ADDENDUM #

Legal Framework:

• Bank Secrecy Act (BSA)

• USA PATRIOT Act

• FinCEN Regulations

• OFAC Sanctions

Thresholds:

• Cash payments > $10,000: Currency Transaction Report

• Suspicious Activity Report (SAR) for transactions > $5,000 with suspicion

Patriot Act Section 326: Minimum verification standards.

EU ADDENDUM #

Legal Framework:

• 5th Anti-Money Laundering Directive (AMLD5)

• 6th Anti-Money Laundering Directive (AMLD6)

• Respective national implementations

Beneficial Ownership: Register of beneficial owners >25% required.

 PART D: ENTERPRISE INTERNAL MANUAL #

For UTSAV DAAN™ Compliance Team #

A. Alert Triage Matrix #

B. Investigation Workflow #

Step 1: Initial Review (4 hours)

• Gather all available information

• Review transaction history

• Check previous flags

Step 2: Enhanced Due Diligence (24-48 hours)

• Request additional documentation

• Conduct open-source research

• Verify with external databases

Step 3: Decision

• No further action (document)

• Enhanced monitoring

• File STR

• Law enforcement referral

Step 4: Documentation

• Complete investigation report

• Preserve evidence

• Update case management system

C. Regulatory Reporting Deadlines #