International Fund Transfer Policy

Module: CrowdFunding (Utsavdaan™)
Document Type: Hybrid — Plain English + Legal Reinforcement
Trademark: UTSAVDAAN™ is a registered trademark of MyMahotsav Futuretech Ltd
Jurisdictions: Global (with multi-currency addendums)
Version: 1.0
Effective Date: [INSERT DATE]

📋 PART A: PLAIN ENGLISH SUMMARY #

Sending Money Across Borders #

UTSAVDAAN™ connects donors and beneficiaries around the world. This policy explains how international transfers work, what fees apply, and how currency conversion is handled.

The Simple Truth #

• Donors can give in their currency: You see prices and donate in your local currency.

• Beneficiaries receive in theirs: Funds arrive in the beneficiary’s local currency (unless they hold foreign currency accounts).

• Currency conversion happens: Your donation is converted from your currency to the beneficiary’s currency.

• Exchange rates matter: We use wholesale rates plus a small transparent margin.

• Transfer fees apply: Banks charge for international wires—we pass these through at cost.

• Timelines vary: International transfers take 3-10 business days depending on countries and banks.

• Tracking available: You can track your donation’s journey.

⚖️ PART B: LEGAL TERMS AND CONDITIONS #

1. DEFINITIONS #

2. CURRENCY CONVERSION FRAMEWORK #

2.1 Donation Currency Options #

2.1.1 Contributors may donate in:

2.1.2 Contributors see Campaign amounts in Campaign Base Currency with approximate conversion to Donor Currency at current rates.

2.2 Exchange Rate Determination #

2.2.1 UTSAVDAAN™ determines exchange rates as follows:

• Base Rate: Interbank Rate from reputable financial data provider (updated real-time)

• Margin: [X]% added to Interbank Rate

• Displayed Rate: Interbank Rate + Margin, shown to donor before confirmation

2.2.2 Margin covers:

• Currency volatility risk during settlement

• Bank conversion charges

• Platform FX handling costs

• Reconciliation expenses

2.2.3 Margin is disclosed as:

• Separate line item in fee breakdown, OR

• Incorporated into displayed exchange rate with clear disclosure

2.3 Rate Lock #

2.3.1 Exchange rate is locked at the moment of donor confirmation.

2.3.2 Rate applies for that transaction only. Future donations subject to new rates.

2.3.3 If rate changes between confirmation and settlement (rare), UTSAVDAAN™ absorbs minor fluctuations (<1%). Major fluctuations may require donor notification.

3. INTERNATIONAL TRANSFER PROCESS #

3.1 Donation to Escrow #

3.2 Escrow to Beneficiary #

3.3 Transfer Methods by Corridor #

4. FEE STRUCTURE #

4.1 Fees Applicable to International Transfers #

4.2 Fee Estimates #

UTSAVDAAN™ provides fee estimates before Campaign launch and before disbursement:

4.3 Transparent Disclosure #

Before confirming donation, Contributors see:

• Amount in Donor Currency

• Amount in Campaign Currency

• Exchange rate used

• Conversion margin

• Total charge in Donor Currency

Before disbursement, Beneficiaries see:

• Gross proceeds in Campaign Currency

• All deductions itemized

• Net proceeds in Beneficiary Currency

• Expected arrival date

5. BENEFICIARY BANK ACCOUNT REQUIREMENTS #

5.1 Required Information by Country #

5.2 Verification #

All beneficiary bank details verified through:

• Document verification (bank statement/canceled cheque)

• Test transaction (where applicable)

• Beneficiary confirmation

5.3 Errors in Bank Details #

If beneficiary provides incorrect details:

• Transfer may fail (funds returned to UTSAVDAAN™)

• Return fees deducted from proceeds

• Corrected details required for re-transfer

• Delays may extend 2-4 weeks

6. REGULATORY COMPLIANCE #

6.1 India – FEMA Compliance #

Foreign Exchange Management Act, 1999 (FEMA) :

• Inward remittances to India: Allowed for bona fide purposes

• Reporting to RBI through authorized dealer banks

• FIRC (Foreign Inward Remittance Certificate) provided to Beneficiary

• FCRA compliance for foreign contributions to charitable organizations

FCRA (Foreign Contribution Regulation Act) :

• Indian NGOs receiving foreign contributions must have FCRA registration

• Funds credited only to FCRA-designated bank account

• UTSAVDAAN™ verifies FCRA status before disbursement

6.2 UK Compliance #

• HMRC reporting for cross-border payments

• Anti-money laundering checks on source of funds

• Sanctions screening

6.3 US Compliance #

• OFAC sanctions screening

• FinCEN reporting for transactions > $10,000

• State licensing requirements for money transmission (varies by state)

6.4 EU Compliance #

• SEPA Regulation for euro transfers

• AML Directives implementation

• Cross-border payment regulation

6.5 FATCA/CRS Reporting #

• UTSAVDAAN™ may report account information to tax authorities under:

  • FATCA (US)

  • Common Reporting Standard (CRS – global)

7. DELAYS AND ISSUES #

7.1 Common Delay Reasons #

7.2 Failed Transfers #

If transfer fails:

1. Funds returned to UTSAVDAAN™ Escrow (minus any fees)

2. Beneficiary notified

3. Corrected details obtained

4. Re-transfer attempted

5. Additional fees borne by Beneficiary

7.3 Force Majeure #

UTSAVDAAN™ not liable for delays caused by:

• Banking system failures

• Regulatory changes

• Sanctions implementation

• Natural disasters

• Political instability

• Pandemics

🌍 PART C: JURISDICTION-SPECIFIC ADDENDUMS #

INDIA ADDENDUM #

RBI Liberalised Remittance Scheme (LRS) :

• For outward remittances from India (if ever applicable)

• Current limit: $250,000 per financial year per individual

• Purpose codes required

FCRA Details:

• Beneficiaries must provide FCRA registration certificate

• Funds to be credited to designated FCRA account only

• UTSAVDAAN™ provides FIRC for each remittance

Tax Deduction at Source:

• TDS under Section 194C/194J applicable on payments to residents

• TDS certificates issued

UK ADDENDUM #

Payment Services Regulations 2017:

• UTSAVDAAN™ acts as payment initiator, not payment institution

• Pass-through of funds without holding license (reliance on authorized payment partners)

Currency and Amounts:

• Reporting to HMRC for payments over €10,000

US ADDENDUM #

Money Transmitter Licensing:

• UTSAVDAAN™ uses licensed partners for money transmission

• Beneficiaries advised on state licensing implications

IRS Form 1099-K:

• May be issued if payment volume exceeds thresholds

EU ADDENDUM #

Cross-Border Payments Regulation:

• Transparency on currency conversion charges

• Right to choose conversion provider

SEPA Transfers:

• EUR transfers within SEPA zone: 1-2 days

• IBAN required

📝 PART D: ENTERPRISE INTERNAL MANUAL #

For UTSAVDAAN™ Finance Team #

A. International Transfer Processing Schedule #

B. Correspondent Bank Routing Guide #

C. Fee Calculation Examples #

Example: £1,000 donation to India Campaign