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AML Policy

Anti-Money Laundering (AML) Policy – BharatOne Services and Affiliates Pvt. Ltd.

Last Updated: May 2026

BharatOne Services and Affiliates Private Limited ("BharatOne", "Company", "we", "our", or "us") is committed to maintaining a secure, transparent, and responsible financial ecosystem by implementing reasonable measures to prevent the misuse of its platforms and services for unlawful, fraudulent, or prohibited activities, including money laundering, terrorist financing, identity theft, financial fraud, sanctions violations, and other illegal activities.

This Anti-Money Laundering ("AML") Policy outlines BharatOne's general approach towards customer onboarding, merchant verification, operational monitoring, risk assessment, fraud prevention, and cooperation with regulatory authorities and ecosystem participants across its platforms and services.

1. Scope

This Policy applies to all:

  • Customers;
  • Merchants;
  • Retailers;
  • Franchise Partners;
  • Agents;
  • Distributors;
  • API users;
  • Business partners;
  • Service providers; and
  • Any other individual or entity accessing or using BharatOne Services.

2. Responsible Platform Usage

Users shall not use BharatOne Services for:

  • Money laundering or terrorist financing;
  • Fraudulent or deceptive financial activities;
  • Identity theft or impersonation;
  • Unauthorized or illegal fund transfers;
  • Transactions involving proceeds of crime;
  • Sanctioned, prohibited, or unlawful commercial activities;
  • Misuse of payment instruments or banking infrastructure; or
  • Any activity prohibited under applicable Indian laws or regulatory requirements.

BharatOne reserves the right to review, restrict, suspend, terminate, or refuse access to any Service where suspicious, abusive, fraudulent, prohibited, or high-risk activity is identified or reasonably suspected.

3. Customer Verification & Operational Review

BharatOne may undertake appropriate onboarding, Know Your Customer (KYC), Know Your Business (KYB), merchant verification, transaction monitoring, and operational review procedures based on:

  • Nature of the Service;
  • Transaction volume;
  • Risk profile;
  • Merchant category;
  • Regulatory requirements;
  • Banking partner policies; and
  • Operational or fraud-related indicators.

Verification measures may include:

  • Identity verification;
  • Business verification;
  • PAN, GST, and bank account verification;
  • Document validation;
  • Merchant due diligence;
  • Transaction review;
  • Source of funds verification where applicable;
  • Additional information or supporting documents; and
  • Temporary account restrictions pending review.

BharatOne reserves the right to delay, suspend, restrict, or reject access to Services where necessary to maintain platform security, comply with regulatory obligations, or mitigate operational and financial risks.

4. Monitoring & Risk Management

BharatOne maintains operational monitoring practices intended to identify potentially suspicious, abusive, fraudulent, or prohibited activities across its ecosystem.

Monitoring activities may include review of:

  • Unusual transaction patterns;
  • High-value or high-frequency transactions;
  • Rapid movement of funds;
  • Multiple account usage;
  • Settlement anomalies;
  • Chargeback trends;
  • Suspicious onboarding activities;
  • Device or IP inconsistencies;
  • API misuse;
  • Fraud indicators; and
  • Other operational or behavioral risk signals.

Where necessary, BharatOne may initiate enhanced due diligence, temporarily suspend transactions, or conduct further investigations.

5. Cooperation with Banking Partners & Authorities

BharatOne may cooperate with:

  • Banks;
  • Payment Aggregators;
  • Payment Gateways;
  • NPCI ecosystem participants;
  • Financial institutions;
  • Regulatory authorities;
  • Law enforcement agencies;
  • Government departments;
  • Fraud prevention organizations; and
  • Other authorized ecosystem participants

where reasonably required for:

  • Fraud prevention;
  • AML investigations;
  • Dispute resolution;
  • Regulatory compliance;
  • Operational reviews;
  • Legal proceedings; or
  • Protection of the integrity of the financial ecosystem.

Information may be disclosed only where required or permitted under applicable laws or contractual obligations.

6. Operational Dependencies

BharatOne operates through integrations with:

  • Banking institutions;
  • Payment networks;
  • Government departments;
  • Licensed financial institutions;
  • Technology providers;
  • Identity verification agencies;
  • Payment gateways; and
  • Other third-party infrastructure providers.

Certain verification outcomes, transaction reviews, account restrictions, or settlement decisions may therefore depend upon external ecosystem participants and systems that are outside BharatOne's direct operational control.

7. Operational Records

BharatOne may retain:

  • Customer onboarding records;
  • KYC/KYB documents;
  • Merchant verification records;
  • Transaction logs;
  • Settlement reports;
  • Audit trails;
  • Support communications;
  • Security logs; and
  • Operational records

for such periods as may be reasonably necessary to:

  • Comply with applicable laws;
  • Support fraud investigations;
  • Resolve disputes;
  • Meet regulatory obligations;
  • Maintain audit records;
  • Protect platform security; and
  • Support operational continuity.

Information may be securely archived, anonymized, or deleted in accordance with BharatOne's Privacy Policy and applicable legal requirements.

8. User Responsibilities

All Users are expected to:

  • Provide accurate, complete, and up-to-date information;
  • Cooperate with KYC, KYB, and verification requests;
  • Maintain accurate merchant and banking information;
  • Promptly report suspicious or unauthorized activity;
  • Protect account credentials and authentication information;
  • Avoid misuse of BharatOne Services; and
  • Comply with applicable laws, regulations, and BharatOne policies.

Failure to comply may result in suspension, restriction, termination of Services, or reporting to competent authorities where required.

9. Policy Updates

BharatOne may revise or update this AML Policy periodically to reflect:

  • Regulatory developments;
  • RBI, FIU-IND, or other governmental guidance;
  • Banking and payment ecosystem requirements;
  • Operational improvements;
  • Technology enhancements;
  • Security developments; and
  • Fraud prevention measures.

The latest version of this Policy will be published on the official BharatOne website. Continued use of BharatOne Services after publication of revised terms constitutes acceptance of the updated Policy.

10. Contact Information

For AML-related concerns, compliance queries, fraud reporting, or merchant verification assistance, please contact: