1. Introduction

Biz by Aroon Fintech ("Biz", "Platform", "we", "our", or "us") is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in the provision of its services.

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This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy ("Policy") establishes the principles and procedures adopted by Biz by Aroon Fintech to prevent the Platform from being used for:

• money laundering;

• terrorist financing;

• proliferation financing;

• fraud;

• bribery and corruption;

• sanctions evasion;

• tax evasion;

• identity theft;

• financial crime; and

• other unlawful activities.

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Biz by Aroon Fintech is operated by Aroon Fintech Private Limited, together with the applicable Aroon Fintech entity providing the Services in the relevant jurisdiction.

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This Policy should be read together with our Terms & Conditions, Privacy Policy, Data Processing Policy, Risk Disclosure, Partner Disclosure, and all other legal notices published on the Platform.

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2. Purpose

The objectives of this Policy are to:

• establish a risk-based AML/KYC framework;

• identify and verify the identity of Users;

• assess customer risk;

• comply with Applicable Laws and regulatory obligations;

• detect and prevent financial crime;

• support lawful financing transactions;

• protect the integrity of the Platform; and

• safeguard our Users, Partners, and business operations.

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3. Scope

This Policy applies to:

• all Users of the Platform;

• businesses applying for finance;

• company directors;

• shareholders;

• beneficial owners;

• authorised signatories;

• guarantors;

• partners;

• consultants;

• vendors;

• service providers;

• employees;

• contractors; and

• any other person or organisation interacting with Biz by Aroon Fintech where customer due diligence is required.

 

4. Regulatory Commitment

Biz by Aroon Fintech seeks to comply with Applicable Laws relating to:

• anti-money laundering;

• counter-terrorist financing (CTF);

• sanctions compliance;

• anti-bribery and anti-corruption;

• customer due diligence;

• financial crime prevention;

• fraud prevention;

• beneficial ownership transparency;

• record keeping; and

• reporting obligations.

Where Services are provided in multiple jurisdictions, the applicable Aroon Fintech entity will comply with the local legal and regulatory requirements governing those Services.

 

5. Risk-Based Approach

Biz by Aroon Fintech applies a risk-based approach when assessing Users and transactions.

Risk assessments may consider factors including:

• customer type;

• legal structure;

• jurisdiction of incorporation;

• country of residence;

• business sector;

• ownership structure;

• source of funds;

• source of wealth;

• transaction value;

• transaction frequency;

• financing product;

• delivery channel;

• politically exposed person (PEP) status;

• sanctions exposure; and

• any other relevant risk indicators.

Higher-risk relationships may be subject to Enhanced Due Diligence.

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6. Customer Identification (KYC)

Before providing certain Services or facilitating introductions to Funding Providers, Biz by Aroon Fintech may require Users to complete identity verification.

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Depending on the User and the Services requested, information may include:

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Individuals

• full legal name;

• date of birth;

• nationality;

• residential address;

• government-issued identification;

• contact details;

• photograph or biometric verification where permitted;

• tax identification number; and

• other information reasonably required for verification.

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Businesses

• legal entity name;

• registration number;

• incorporation documents;

• registered office address;

• principal place of business;

• tax registrations;

• business licences;

• constitutional documents;

• ownership structure;

• organisational chart;

• financial information;

• authorised signatories; and

• any other documentation reasonably required.

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7. Beneficial Ownership

Biz by Aroon Fintech may require information regarding Ultimate Beneficial Owners (UBOs), including:

• ownership percentages;

• control structure;

• voting rights;

• significant influence;

• identification documents; and

• residential addresses.

Where ownership structures are complex, additional documentation may be requested.

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8. Customer Due Diligence (CDD)

Customer Due Diligence may include:

• identity verification;

• business verification;

• address verification;

• beneficial ownership verification;

• sanctions screening;

• politically exposed person screening;

• adverse media screening;

• fraud prevention checks;

• regulatory status verification;

• source of funds review;

• source of wealth review where appropriate; and

• ongoing monitoring.

Biz by Aroon Fintech reserves the right to determine the level of due diligence appropriate to the risk presented.

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9. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be conducted where higher-risk circumstances are identified, including:

• politically exposed persons (PEPs);

• high-risk jurisdictions;

• complex ownership structures;

• unusually large transactions;

• cross-border financing;

• higher-risk industries;

• unusual transaction patterns;

• adverse media findings; or

• any circumstance presenting elevated financial crime risk.

EDD may include additional documentation, management approval, enhanced monitoring, or independent verification.

 

10. Sanctions Compliance

Biz by Aroon Fintech may screen Users, beneficial owners, counterparties, and transactions against applicable sanctions lists issued by relevant governmental and international authorities.

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Where legally required or otherwise considered appropriate, Services may be declined, suspended, or terminated if a User or transaction appears to involve sanctioned individuals, entities, jurisdictions, vessels, or activities.

 

11. Politically Exposed Persons (PEPs)

Users may be required to disclose whether they, their beneficial owners, or key controllers are Politically Exposed Persons, family members of PEPs, or close associates of PEPs.

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PEP status does not automatically prevent the provision of Services but may result in Enhanced Due Diligence and ongoing monitoring.

 

12. Source of Funds and Source of Wealth

Where appropriate, Biz by Aroon Fintech may request evidence demonstrating the legitimate origin of:

• business funds;

• investment capital;

• collateral;

• assets;

• income;

• shareholder contributions; or

• other financial resources.

Supporting documentation may include financial statements, bank statements, contracts, invoices, tax records, or other evidence reasonably requested.

 

13. Ongoing Monitoring

Customer relationships may be monitored throughout the duration of the business relationship.

Monitoring may include:

• periodic KYC refreshes;

• transaction monitoring;

• sanctions re-screening;

• adverse media monitoring;

• documentation updates;

• changes in ownership;

• changes in business activities;

• changes in jurisdiction; and

• review of unusual activity.

Users are responsible for notifying Biz by Aroon Fintech of any material changes affecting previously submitted information.

 

14. Suspicious Activity

Biz by Aroon Fintech reserves the right to investigate activity that appears unusual, suspicious, inconsistent, or potentially unlawful.

 

Where required by Applicable Law, Biz by Aroon Fintech may report suspicious activities to competent authorities without prior notice to the User.

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Where prohibited by law, Biz by Aroon Fintech may be unable to disclose that such a report has been made.

 

15. Refusal or Termination of Services

Biz by Aroon Fintech may decline, suspend, restrict, or terminate Services where:

• identity cannot be verified;

• required documentation is not provided;

• information is inconsistent or misleading;

• fraud is suspected;

• sanctions concerns arise;

• AML risks cannot be adequately mitigated;

• legal or regulatory obligations require refusal; or

• continuing the relationship would expose Biz by Aroon Fintech or its Partners to unacceptable legal, regulatory, financial, or reputational risk.

Biz by Aroon Fintech is not obliged to explain every decision where disclosure would breach Applicable Law or prejudice financial crime prevention measures.

 

16. Record Retention

AML and KYC records may be retained for the period required by Applicable Law, regulatory obligations, contractual commitments, or legitimate business purposes.

Records may include:

• identification documents;

• verification records;

• transaction information;

• communications;

• risk assessments;

• screening results;

• due diligence documentation; and

• audit records.

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After the applicable retention period, records will be securely deleted, anonymised, or otherwise disposed of in accordance with our internal policies and Applicable Law.

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17. User Responsibilities

Users agree to:

• provide accurate and complete information;

• promptly update changes to submitted information;

• cooperate with verification requests;

• provide additional documentation where reasonably requested;

• refrain from using the Platform for unlawful purposes; and

• comply with all Applicable Laws.

Providing false, misleading, forged, or fraudulent information may result in rejection of applications, suspension of Services, termination of accounts, reporting to authorities, and legal action.

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18. Employee Training and Compliance

Biz by Aroon Fintech maintains internal policies, procedures, and training programmes designed to promote awareness of:

• AML obligations;

• KYC requirements;

• sanctions compliance;

• fraud prevention;

• customer due diligence;

• data protection;

• financial crime reporting; and

• ethical business conduct.

Relevant personnel receive training appropriate to their responsibilities.

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19. Policy Updates

Biz by Aroon Fintech may amend this Policy from time to time to reflect:

• changes in Applicable Law;

• regulatory guidance;

• industry best practices;

• business operations;

• technology developments; or

• enhancements to our compliance framework.

The latest version will be published on the Platform and will become effective on the stated Effective Date.

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20. Contact Information

For questions regarding this AML/KYC Policy or our financial crime compliance programme, please contact:

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Compliance Department

Biz by Aroon Fintech

Operated by Aroon Fintech Private Limited, together with the applicable Aroon Fintech entity providing the Services.

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Email: support@aroonfintech.com

Website: https://biz.aroonfintech.com

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Where required by Applicable Law, additional jurisdiction-specific compliance contact details, regulatory disclosures, or reporting information may be published by the relevant Aroon Fintech entity.

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By using the Platform, you acknowledge that you may be required to complete identity verification, provide supporting documentation, undergo screening, and comply with applicable AML, KYC, sanctions, and financial crime prevention requirements before certain Services can be provided.