Maintenance of Records of Transactions

As unlikely as it will be in PANDINADU  FINANCE  COMPANY  PVT LTD.’s case, due to its focus on lower income families, PANDINADU  FINANCE  COMPANY PVT LTD. has a system of maintaining proper record of transactions prescribed under Rule 3, of the Prevention of Money-Laundering and value of transactions, the procedure and manner of maintaining and verification and maintenance of records of the identity of the clients of the Banking Companies, Financial Institutions and Intermediaries) Rules, 2005, as mentioned below:

• all cash transactions of the value of more than rupees ten lakh or its equivalent in foreign currency
• all series of cash transactions integrally connected to each other which have been valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the aggregate value of such transactions exceeds rupees ten lakh 
• 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
• all suspicious transactions whether or not made in cash and by way of as mentioned in the Rules.

 Information to be preserved. As per the RBI guidelines, PANDINADU  FINANCE  COMPANY PVT LTD. maintains the following information in respect of transactions referred to in Rule 3

• the nature of the transactions
• the amount of the transaction and the currency in which it was denominated 
• the date on which the transaction was conducted;
• the parties to the transaction.

Maintenance and Preservation of records
Enhanced Due Diligence
Appointment of Principal Officer
Maintenance and Preservation of records

PANDINADU  FINANCE  COMPANY PVT LTD. has a system for proper maintenance and preservation of account information in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities. PANDINADU  FINANCE  COMPANY PVT LTD. will maintain for at least ten years from the date of cessation of transaction between PANDINADU  FINANCE  COMPANY PVT LTD. and the customer, all necessary records of transactions, both domestic or international, which will permit reconstruction of individual transactions (including the amounts and types of currency involved if any) so as to provide, if necessary, evidence for prosecution of persons involved in criminal activity.

PANDINADU  FINANCE  COMPANY  PVT LTD. also ensures that records pertaining to the identification of the customer and his / her address (e.g. copies of documents like passports, identity cards, driving licenses, PAN, utility bills etc.) obtained while opening the loan account and during the course of business relationship, are properly preserved for at least ten years. The identification records and transaction data will be made available to the competent authorities upon request.

Enhanced Due Diligence

PANDINADU  FINANCE  COMPANY PVT LTD. does not deal with such category of customers who could pose a potential high risk of money laundering, terrorist financing or political corruption and are determined to warrant enhanced scrutiny. The existing credit policies of PANDINADU  FINANCE  COMPANY PVT LTD. in respect of its various businesses ensure that PANDINADU  FINANCE  COMPANY  PVT LTD. is not transacting with such high risk customers.

PANDINADU  FINANCE  COMPANY  PVT LTD. shall conduct Enhanced Due Diligence in connection with all customers or accounts that are determined to pose a potential high risk and are determined to warrant enhanced scrutiny. PANDINADU  FINANCE  COMPANY  PVT LTD. has established appropriate standards, methodology and procedures for conducting Enhanced Due Diligence, which shall involve conducting appropriate additional due diligence or investigative actions beyond what is required by standard KYC due diligence. Enhanced Due Diligence shall be coordinated and performed by PANDINADU  FINANCE  COMPANY  PVT LTD.

The following are the indicative list where the risk perception of a customer which is considered higher:

• Customers requesting for frequent change of address/contact details
• Sudden change in the loan account activity of the customers
• Frequent closure and opening of loan accounts by the customers

Enhanced due diligence is in the nature of keeping the account monitored closely for a re-categorisation of risk, updation of fresh KYC documents, field investigation or visit of the customer, etc., which form part of the credit policies of the businesses.

Appointment of Principal Officer

Appointment of Principal Officer

Mr.C.Deivarajan, Managing Director will be the designated director who is responsible for ensuring overall compliance as required under PMLA Act and the Rules. Mr.G.M.Murugesan, Chief Manager is designated as Principal Officer who shall be responsible for furnishing of information to FIUIND.

As per the RBI guidelines, the Principal Officer is located at our corporate office and is responsible for monitoring and reporting of all transactions and sharing of information as required under the law. He maintains a close liaison with enforcement agencies, other NBFCs and any other institution which are involved in the fight against money laundering and combating financing of terrorism.