The Reserve Bank of India (RBI) has issued comprehensive ‘Know Your Customer' (KYC) Guidelines to all Non-Banking Financial Companies (NBFCs) in the context of the recommendations made by the Financial Action Task Force (FATF) and Anti Money Laundering (AML) standards and Combating Financing of Terrorism (CFT) policies. In view of the same, FHFSL has adopted the said KYC guidelines with suitable modifications depending on the business activity undertaken by it. The Company has ensured that a proper policy framework on KYC and AML measures be formulated in line with the prescribed RBI guidelines and put in place duly approved by its Board of Directors.


Money laundering refers to concealing or disguising the origin and ownership of the proceeds from criminal activity, including drug trafficking, public corruption, terrorism, fraud, human trafficking, and organized crime activities. Terrorist financing is the use of legally or illegally obtained funds to facilitate terrorist activities. Money laundering and terrorist financing may involve a wide variety of financial products, services, and transactions including lending and investment products, and the financing of equipment and other property that could be used to facilitate terrorism and other criminal activity.

Generally, the money laundering process involves three (3) stages: placement, layering and integration. As illegal funds move from the placement stage through the integration stage, they become increasingly harder to detect and trace back to the illegal source.

  1. Placement is the point where illegal funds first enter the financial system.

  2. Layering After illegal funds have entered the financial system, layers are created by closing and opening accounts, purchasing and selling various financial products, transferring funds among financial institutions and across national borders. The criminal’s goal is to create layers of transactions to make it difficult to trace the illegal origin of the funds.

  3. Integration occurs when the criminal believes that there are sufficient number of layers hiding the origin of the illegal funds to safely invest the funds or apply them towards purchasing valuable property in the legitimate economy.

    To prevent money-laundering in India and to provide for confiscation of property derived from, or involved in, money-laundering and related matters, the Parliament of India enacted the Prevention of Money Laundering Act, 2002 (PMLA), as amended from time to time. Further, necessary Notifications / Rules under the said Act have been published and amended by the Ministry of Finance, the Government of India.

    As per the Prevention of Money Laundering Act 2002, the offence of Money Laundering is defined as:

    “Whosoever directly or indirectly attempts to indulge or knowingly assists or knowingly is a party or is actually involved in any process or activity connected with the proceeds of crime and projecting it as untainted property shall be guilty of offence of money-laundering. "Proceeds of crime" means any property derived or obtained, directly or indirectly, by any person as a result of criminal activity relating to scheduled offence or the value of any such property.”

    The PMLA defines money laundering offence and provides for the freezing, seizure and confiscation of the proceeds of crime. The Reserve Bank of India (RBI) vide Master Direction DBR.AML.BC.No.81/14.01.001/2015-16 dated February 25 2016 and subsequent modifications thereof,

    have prescribed guidelines “Anti Money Laundering” guidelines/ standards. In view of the above, AML - KYC policy of FHFSL has been framed to broadly achieve the following purposes:

    1. To prevent criminal elements from using FHFSL for money laundering activities

    2. To enable FHFSL to know/ understand its customers and their financial dealings better which, in turn, would help the Company to manage risks prudently.

    3. To put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws/laid down procedures.

    4. To comply with applicable laws and regulatory guidelines.

    5. To ensure that the concerned staff are adequately trained in KYC/AML/CFT procedures.

      This Policy will be applicable to all branches/offices of Flyhi Finance and is to be read in conjunction with related operational guidelines issued from time to time.


        1. Customer

          1. A person or entity that maintains an account and/or has a business relationship with FHFSL;

          2. A person who is engaged in a financial transaction or activity with FHFSL and includes a person on whose behalf the person who is engaged in the transaction or activity.

          3. One on whose behalf the account is maintained (i.e. the beneficial owner)

          4. Beneficiaries of transactions conducted by professional intermediaries such as Stock Brokers, Chartered Accountants, Solicitors etc. as permitted under the law, and

          5. Any other person or entity connected with a financial transaction which can pose significant reputation or other risks to FHFSL, say a wire transfer or issue of high value demand draft as a single transaction.

        2. Beneficial Owner:

          1. Where the customer is a Company, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has/have a controlling ownership interest or who exercise control through other means.

            Explanation -

            1. “Controlling ownership interest” means ownership of/entitlement to more than 25 per cent of the sharesor capital or profits of the company.

            2. “Control” shall include the right to appoint majority of the directors or to control the management or policy decisions including by virtue of their shareholding or management rights or shareholders agreements or voting agreements.

          2. Where the customer is a Partnership firm, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has/have ownership of/entitlement to morethan 15 per cent of capital or profits of the partnership.

          3. Where the customer is an unincorporated association or body of individuals, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has/have ownership of/entitlement to more than 15 per cent of the property or capital or profits of the unincorporated association or body of individuals.

            Explanation: Term ‘body of individuals’ includes societies. Where no natural person is identified under (a), (b) or (c)

            above, the beneficial owner is the relevant natural person who holds the position of senior managing official.

          4. Where the customer is a trust, the identification of beneficial owner(s) shall include identification of the author of the trust, the trustee, the beneficiaries with 15% or more interest in the trust and any other natural person exercising ultimate effective control over the trust through a chain of control or ownership.


    FHFSL’s Customer Acceptance Policy, which lays down explicit criteria for acceptance of customers,

    ensures the following aspects of the customer relationship:

    1. No account is opened in anonymous or fictitious/benami name.

    2. No account is opened where the Company is unable to apply appropriate CDD measures, either due to non-cooperation of the customer or non-reliability of the documents/information furnished by the customer.

    3. No transaction or account-based relationship is undertaken without following the CDD procedure.

    4. The mandatory information to be sought for KYC purpose while opening an account and during the periodic updation, is specified.

    5. ‘Optional’/additional information, is obtained with the explicit consent of the customer after the

      account is opened.

    6. CDD Procedure is followed for all the joint account holders, while opening a joint account.

    7. Necessary checks before opening a new account are to be ensured so that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations, etc. For this purpose, the Company shall maintain lists of individuals or entities issued by RBI, United Nations Security Council, other regulatory & enforcement agencies, internal lists as the Company may decide from time to time. Fulldetails of accounts/ customers bearing resemblance with any of the individuals/ entities in the listshall be treated as suspicious and reported.

    8. Where Permanent Account Number (PAN) is obtained, the same shall be verified from the verification facility of the issuing authority.

    9. Where an equivalent e-document is obtained from the customer, FLFSL shall verify the digital signature as per the provisions of the Information Technology Act, 2000 (21 of 2000).

    10. Classify customers into various risk categories and based on risk perception, apply the acceptance criteria for each category of customers. Also, a profile of each customer will be prepared based on risk categorization.

    11. Implementation of CAP should not become too restrictive and result in denial of FHFSL services to general public, especially to those who are financially or socially disadvantaged.

    12. Circumstances, in which a customer is permitted to act on behalf of another person/ entity shall be clearly spelt out in conformity with the established law and practice and shall be strictly followed so as to avoid occasions when an account is operated by a mandate holder or where an account may be opened by an intermediary in the fiduciary capacity or beneficial owner. (Refer Annexure IIB)

      FHFSL will try and ensure KYC procedure is done in all accounts as per the guidelines above and try and check the latest address and not rely on existing records only in case of an existing customer.


        1. The Company shall undertake identification of customers in the following cases:

          1. Commencement of an account-based relationship with the customer;

          2. When there is a doubt about the authenticity or adequacy of the customer identification data it has obtained;

          3. Carrying out transactions for a non-account based customer (walk-in customer);

        2. The Company shall obtain satisfactory evidence of the identity of the customer depending upon the perceived risks at the time of commencement of relationship/ opening of account. Such evidence shall be substantiated by reliable independent documents, data or information or other means like physical verification etc.

        3. The Company will obtain Permanent account number (PAN) of customers as per the applicable provisions of Income Tax Rule 114B.

        4. For the customers that are legal person or entities:

          1. the Company will verify the legal status for the legal person/ entity through proper and relevant documents;

          2. the Company will understand the beneficial ownership and control structure of the customer and determine who the natural persons are and who ultimately controls the legal person.

        5. Additional documentation may be obtained from the customers with higher risk perception as may be deemed fit. This shall be done having regard but not limited to location (registered office address, correspondence address and other addresses as may be applicable), nature of business activity, repayment mode & repayment track record.

        6. For the purpose of verifying the identity of customers at the time of commencement of an account-based relationship, the Company, at its discretion may at its option, rely on customer due diligence done by a third party, subject to the following conditions:

          1. Necessary information of such customers’ due diligence carried out by the third party is immediately obtained by the Company;

          2. Adequate steps are taken by the Company to satisfy that copies of identification data and other relevant documentation relating to customer due diligence shall be made available from the third party upon request without delay

          3. The third party is regulated, supervised or monitored for, and has measures in place for, compliance with customer due diligence and record-keeping requirements in line with the requirements and obligations under the PML Act;

          4. The third party shall be based in India only;

          5. The ultimate responsibility for customer due diligence and undertaking enhanced due diligence measures as applicable, will be with the Company.

        7. While undertaking customer identification, the Company will ensure that:

          1. Decision-making functions of determining compliance with KYC norms shall not be outsourced.

          2. The customers shall not be required to furnish an additional OVD, if the OVD submitted for KYC contains proof of identity as well as proof of address e.g., Passport.

          3. The customers shall be required to furnish separate proof of address if the current address is different form the OVD given as proof of address. This address proof would be those which are listed on the “simplified measures.” The company may physically verify this address for positive confirmation. However, the address so provided should be updated in the OVD within six months.

        8. Periodic Updating of KYC data: Flyhi Finance shall periodically update Customer’s KYC information / documents after the transaction is entered. The periodicity of updating of Customer’s KYC data shall be once in 10 years for low risk customers, once in every 8 years for medium risk customers, and once in 2 years for high risk categories, subject to following conditions:

          1. Fresh proofs of identity and address shall not be sought at the time of periodic updation from customers who are categorized as ‘low risk’, when there is no change in status with respect to their identities and addresses and a self-certification to that effect is obtained.

          2. A certified copy of the proof of address forwarded by ‘low risk’ customers through mail/ post, etc., in case of change of address shall be acceptable.

          3. Physical presence of low risk customer at the time of periodic updation shall not be insisted upon.

          4. The time limits prescribed above would apply from the date of opening of the account/ last verification of KYC.

          5. Fresh photographs shall be obtained from customer for whom account was opened when they were minor, on their becoming a major.

          6. E-KYC process using OTP based authentication for periodic updation is allowed provided while on boarding, the customer was subjected to proper KYC process.

  2. Customer Due Diligence (CDD) - Identifying and verifying the customer and the beneficial owner using ‘Officially Valid Documents (OVD)’ as a ‘proof of identity’ and a ‘proof of address’. The documents and the process to be followed for due diligence for various entities is listed in Annexure I.

The company intends to lend only to individuals; however, KYC procedures have been designed for all categories as it intends to disburse loan money to educational institutes who may be any legal entity.

The e-KYC service of Unique Identification Authority of India (UIDAI) shall be accepted as a valid process for KYC verification and the information containing demographic details and photographs made available from UIDAI as a result of e-KYC process will be treated as an ‘Officially Valid Document’ (‘OVD’).

There shall be explicit consent and authorization from the customer before commencing the e-KYC process, authorizing UIDAI to release his/ her identity/address through OTP Authentication to the Company or it’s Business Correspondents (BCs).

Accounts opened using OTP based e-KYC shall not be allowed for more than one year within which Customer Due Diligence (CDD) procedure as provided in preceding paragraph is to be completed. If the CDD procedure is not completed within a year, no further debits shall be allowed in the loan account except for various fees and charges. Further, while uploading KYC information to CKYCR, the Company will clearly indicate that such accounts are opened using OTP based e-KYC and other regulated entities shall not open accounts based on the KYC information of accounts opened with OTP based e-KYC procedure.

Any deviation in the policy needs to be approved by senior management of the company

Senior management for the purpose of KYC compliance shall include Designated Director, Head of Credit, Head of Risk, Key Managerial Persons, Compliance Officer, Principal Officer (PO) and his/her supervisor.


For Risk Management, the Company will have a risk-based approach which includes the following:

  1. Customers shall be categorized as low, medium and high-risk category, based on the assessment and risk perception of the Company;

  2. Risk categorization shall be undertaken based on parameters such as customer’s identity, social/financial status, nature of business activity, and information about the clients’ business and their location etc. While considering customer’s identity, the ability to confirm identity documents through online or other services offered by issuing authorities may also be factored in.

  3. The customers will be monitored on regular basis with built in mechanism for tracking irregular behavior for risk management and suitable timely corrective action.

  4. The Company shall prepare a profile for each new customer during the credit appraisal based on risk categorization as mentioned in this policy. The customer profile shall contain the information relating to the customer’s identity, social/financial status, nature of business activity, information about his clients’ business and their location, etc. The nature and extent of due diligence will depend on the risk perceived by FHFSL. These requirements may be moderated according to the risk perception.

  5. FHFSL has designed a scoring methodology based on information gathered from the customers known as Flyhi Score. In certain circumstances the data requirement is very minimal and the loan decisioning is purely based on KYC and credit bureau information. The risk categorization is based on these scoring methodology as mentioned below, and the internal scoring mechanism (Flyhi Score) is provided as a link in the annexure IIA.

  6. FHFSL reserves the right to change the internal scoring mechanism and the classification grid based on the emerging risk in the market and its risk perception.

Full Process

Minimal Process

Flyhi Score

Credit Bureau Score

Low Risk



Medium Risk

>=550 and <650

>=625 and <675 and -1 and 1 to 6

High risk


< 625

The Company will have monitoring procedures including systems to generate alerts in case of anynon-compliance/violation, to ensure compliance with the above-mentionedconditions.

Note: The Company will capture the KYC information for sharing with the CKYCR in the manner as prescribed in the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, under the prescribed KYC templates for ‘individuals’ and ‘Legal Entities’ as applicable. Further, the Company will upload the KYC data pertaining to all types of prescribed accounts with CKYCR, as and when required, in terms of the provisions of the Prevention of Money Laundering (Maintenance of Records) Rules, 2005.

  1. Monitoring of Transactions:

    As per Income Tax Act, 1961, Cash cannot be accepted by any person (Branch / collection staff) over and above Rs. 2,00,000/- (Two Lacs only) for a particular transaction or series of integrally connected transactions. TheCompany does not accept cash deposits in foreign currency.

    As per Income Tax Act, 1961, for any Cash or its equivalent payment over and above Rs. 10,000/-, a ‘source of funds’

    declaration for such cash should be obtained from the Customer / person depositing / repaying the loan.

    Note: Source of funds in cash is through ‘sale of immovable property’, then Cash or its equivalent for more than Rs. 20,000/-should not be accepted.

    Ongoing monitoring is an essential element of effective KYC procedures. Monitoring of transactions and its extent will be conducted taking into consideration the risk profile and risk sensitivity of the account. FHFSL shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified, Special attention will be paid to all complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose. FHFSL may prescribe threshold limits for a particular category of accounts and pay particular attention to the transactions which exceed these limits. Transactions that involve cash over and above Rs. 1 lac should particularly attract the attention of FHFSL. Higher risk accounts shall be subjected to intense monitoring.

    FHFSL shall set key indicators for such accounts basis the background of the customer, country of origin, sources of funds, the type of transactions involved and other risk factors which shall determine the extent of monitoring. FHFSL shall carry out the periodic review of risk categorization of transactions/customer’s accounts and the need for applying enhanced due diligence measures at a periodicity of not less than once in twelve (12) months.

    FHFSL shall explore the possibility of validating the new account opening applications with various watch lists available in public domain, including RBI watch list.

  2. Training Programme

    FHFSL shall have an ongoing employee training programs so that the members of the staff are adequately trained in KYC/ AML/ CFT procedures. Training requirements shall have different focuses for frontline staff, compliance staff and officer/ staff dealing with new customers so that all those concerned fully understand the rationale behind the KYC policies and implement them consistently.

    FHFSL will also provide inputs to the third-party vendors involved in the process so that they are aware of the new policies and regulations on KYC and emerging risks around KYC documentation.

  3. Internal Control System

    The Company’s Internal Audit and Compliance functions will evaluate and ensure adherence to the KYC policies and procedures. As a rule, the compliance function will provide an independent evaluation of the Company’s own policies and procedures, including legal and regulatory requirements. The Management under the supervision of Board shall ensure that the audit function is staffed adequately with skilled individuals. Internal Auditors will specifically check and verify the application of KYC procedures at the branches and comment on the lapses observed in this regard. The audit findings and compliance thereof will be put up before the Audit Committee of the Board on quarterly intervals till closure of audit findings.

    Further, the Company shall have an adequate screening mechanism in place as an integral part of their recruitment/ hiring process of personnel to ensure that person of criminal nature/ background do not get an access, to misuse the financial channel.

  4. Record keeping

    1. Maintenance of records of transactions

      The Company shall maintain proper record of the transactions as required under Section 12 of the Prevention of Money Laundering Act, 2002 (PMLA) read with Rules 3 of the PML Rules as mentioned below:

      1. All cash transactions of the value of more than Rs. 2 lacs, though by policy the Company does not accept cash deposits in foreign currency.

      2. All series of cash transactions integrally connected to each other which have been valued below Rs. 2 lacs where such series of transactions have taken place within a month.

      3. All transactions involving receipts by non-profit organizations of rupees ten lakhs or its equivalent in foreign currency.

      4. All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security has taken place;

      5. records pertaining to identification of the customer and his/her address; and

      6. All suspicious transactions whether or not made in cash and in manner as mentioned in the Rule framed by the Government of India under PMLA.

      An Illustrative List of suspicious transaction pertaining to financial services is given in Annexure III.

    2. Records to contain the specified information

      The Records referred to above in Rule 3 of PMLA Rules to contain the following information:

      1. the nature of the transactions;

      2. the amount of the transaction and the currency in which it was denominated;

      3. the date on which the transaction was conducted; and

      4. the parties to the transaction.

    3. Maintenance and preservation of records

      Section 12 of PMLA requires the Company to maintain records as under:

      1. records of all transactions referred to in clause (a) of Sub-section (1) of section 12 read with Rule 3 of the PML Rules is required to be maintained for a period of five (5) years from the date of transactions between the clients and FHFSL.

      2. records of the identity of all clients of FHFSL is required to be maintained for a period of five years from the date of cessation of transactions between the clients and FHFSL.

      FHFSL shall take appropriate steps to evolve a system for proper maintenance and preservation of information in a manner (in hard and soft copies) that allows data to be retrieved easily and quickly whenever required or as/ when requested by the competent authorities.

  5. Appointment of Principal Officer

    FHFSL shall designate a senior employee as ‘Principal Officer’ (PO) who shall be located at the

    Head/Corporate office and shall be responsible for monitoring and reporting of all transactions and sharing

    of information as required under the law. The name, designation and address of the Principal Officer shall be communicated to the FIU-IND.

  6. Reporting to Financial Intelligence Unit - India

    In accordance with the requirements under PMLA, the Principal Officer of FHFSL will furnish the following reports, as and when required, to the Director, Financial Intelligence Unit-India (FIU-IND):

    1. Cash Transaction Report (CTR) - If any such transactions detected, Cash Transaction Report (CTR) for each month by 15th of the succeeding month.

    2. Counterfeit Currency Report (CCR) - All such cash transactions where forged or counterfeit Indian currency notes have been used as genuine as Counterfeit Currency Report (CCR) for each month by 15th of the succeeding month.

    3. Suspicious Transactions Reporting (STR) - The Company will endeavor to put in place automated systems for monitoring transactions to identify potentially suspicious activity. Such triggers will be investigated, and any suspicious activity will be reported to FIU-IND.

    The Company will file the Suspicious Transaction Report (STR) to FIU-IND within 7 days of arriving at a conclusion that any transaction, whether cash or non-cash, or a series of transactions integrally connected are of suspicious nature. However, in accordance with the regulatory requirements, the Company will not put any restriction on operations in the accounts where an STR has been filed. An indicative list of suspicious transactions is enclosed as Annexure III.

    The employees of FHFSL shall maintain strict confidentiality of the fact of furnishing/ reporting details of suspicious transactions.

  7. Appointment of Designated Director

    The Board of Directors shall nominate a “Designated Director” to ensure compliance with the obligations prescribed by the PMLA and the Rules there under. The “Designated Director” can be a person who holds the position of senior management or equivalent. However, it shall be ensured that the Principal Officer is not nominated as the “Designated Director”. The name, designation and address of the Designated Director shall be communicated to the FIU-IND.

  8. General

    1. Closure of Accounts/Termination of Financing/Business Relationship

      Where FHFSL is unable to apply appropriate KYC measures due to non-furnishing of information and/or non-cooperation by the customer, FHFSL shall terminate Financing/Business Relationship after issuing due notice to the customer explaining the reasons for taking such a decision. Such decision shallbe taken with the approval of Chairman & Managing Director or key managerial persons authorized for thepurpose.

    2. KYC for the Existing Accounts:

      While the KYC guidelines will apply to all new customers, the same would be applied to the existing customers on the basis of materiality and risk. However, transactions with existing customers would be continuously monitored for any unusual pattern in the operation of the accounts.

    3. Updation in KYC Policy of Company

Principal Officer after taking the due approval from the Board of Directors of FHFSL shall make thenecessary amendments/modifications in the KYC/ AML/ CFT Policy or such other related guidance notes of Company, to be in line with RBI or such other statutory authority’s requirements/updates/ amendments from time to time.

Annexure I

Features to be verified and documents that may

be obtained from customers Customers/Clients


(Certified copy of the following OVDs)

Accounts of individuals

- Proof of Identity and Address

Any one document from the Officially Valid Document is only allowed. They are:

(i) Passport (ii) PAN card (iii) Voter’s Identity Card issued by Election Commission (iv) Driving License (v) Job Card issued by NREGA duly signed by an officer of the State Govt (vi) The letter issued by the Unique Identification Authority of India (UIDAI) containing details of name, address and Aadhaar number.

Where ‘simplified measures’ are applied for verifying the identity of customers the following documents shall be deemed to be 'officially valid documents’:

  1. identity card with applicant's Photograph issued by Central/State Government Departments, Statutory/Regulatory Authorities, Public Sector Undertakings, Scheduled Commercial Banks, and Public Financial Institutions;

  2. letter issued by a gazetted officer, with a duly

    attested photograph of the person. Where ‘simplified measures’ are applied for verifying for the limited purpose of proof of address the following additional documents are deemed to be OVDs:.

    1. Utility bill which is not more than two months old of any service provider (electricity, telephone, post-paid mobile phone, piped gas, water bill);

    2. Property or Municipal Tax receipt;

    3. Bank account or Post Office savings bank account statement;

    4. Pension or family pension payment orders (PPOs) issued to retired employees by Government Departments or Public Sector Undertakings, if they contain the address;

    5. Letter of allotment of accommodation from employer issued by State or Central Government departments, statutory or regulatory bodies, public sector undertakings, scheduled commercial banks, financial institutions, and listed companies. Similarly, leave and license agreements with such employers allotting official accommodation; and Documents issued by Government departments of foreign jurisdictions and letter issued by Foreign Embassy or

Mission in India


  1. Certificate of incorporation;

  2. Memorandum and Articles of Association;

  3. A resolution from the Board of Directors and power of attorney granted to managers, officers or employees to transact on its behalf; and

  4. An officially valid document in respect of managers, officers or employees holding an attorney to transact on its behalf.

Partnership Firm

  1. Registration certificate;

  2. Partnership deed; and

  3. An officially valid document in respect of the person holding an attorney to transact on its behalf (Please refer the documents list under customer

category of Individuals.

Unincorporated association or a body of individuals

including societies

  1. Resolution of the managing body of such association or body of individuals;

  2. Power of attorney granted to him to transact on its behalf;

  3. An officially valid document in respect of the person holding an attorney to transact on its behalf; and

Such information as may be required by FHFSL to collectively establish the legal existence of such an

association or body of individuals.


  1. Certified copy of an OVD containing details of identity and address of the individual (proprietor) shall be obtained.

  2. In addition to the above, any two of the following documents as a proof of business/ activity in the name of the proprietary firm shall also be obtained:

    1. Registration certificate

    2. Certificate/license issued by the municipal authorities under Shop and Establishment Act.

    3. Sales and income tax returns.

    4. GST certificate.

    5. Certificate/registration document issued by GST/Professional Tax authorities.

    6. IEC (Importer Exporter Code) issued to the proprietary concern by the office of DGFT/License/certificate of practice issued in the name of the proprietary concern by any professional body incorporated under a statute.

    7. Complete Income Tax Return (not just the acknowledgement) in the name of the sole proprietor where the firm's income is reflected, duly authenticated/acknowledged by the Income Tax authorities.

    8. Utility bills such as electricity, water, and landline telephone bills which is not more than two months old, of any service provider

Annexure II

Broad categories of reason for suspicion and examples of suspicious transactions for Non Banking Financial Companies are indicated as under:

Identity of client

B. Illustrative list of Suspicious Transactions