Anti-Money Laundering (AML) & KYC Policy

e-sahulat Pvt Ltd ("the Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). Our policy is designed to comply with the SBP AML/CFT/CPF Regulations and the Anti-Money Laundering Act, 2010 of Pakistan.

1. Customer Due Diligence (CDD)

We implement a robust "Know Your Customer" (KYC) program. No merchant or high-value customer account will be activated without:

• Verification of CNIC/Passport for individuals.
• Verification of NTN and Incorporation documents for businesses.
• Biometric verification where applicable under SBP guidelines.
• Physical address verification through utility bills.

2. Transaction Monitoring

We employ automated systems to monitor transactions for suspicious patterns, including:

• Unusually large transactions compared to the customer's profile.
• Rapid succession of transactions from the same source.
• Structuring of transactions to avoid reporting thresholds.

3. Reporting Obligations

The Company is legally obligated to report:

• Suspicious Transaction Reports (STRs): Reported to the Financial Monitoring Unit (FMU) of Pakistan within 7 days of detection.
• Currency Transaction Reports (CTRs): For transactions exceeding the threshold defined by SBP.

4. Record Retention

In compliance with SBP regulations, all KYC documents and transaction records are retained for a minimum period of 10 years following the termination of the business relationship or the date of the transaction.

5. Sanctions Screening

We screen all customers against the UN Security Council Sanctions List and the NACTA Proscribed Persons list. We maintain a zero-tolerance policy for transactions involving proscribed entities or individuals.