KYC & AML Policy

FRONTPAY DIGITAL PRIVATE LIMITED is committed to preventing misuse of FrontPay for money laundering, terrorist financing, fraud or other crimes. This policy follows the spirit of the Prevention of Money-Laundering Act, 2002 ("PMLA") and the PML (Maintenance of Records) Rules, 2005, as they apply to our business.

1. Know Your Customer (KYC)

• Every Member registers with a mobile number verified by OTP.
• Before using full limits, settlements or downline features, a Member must provide: PAN, Aadhaar (stored encrypted, and masked when shown), shop/business address, and, for withdrawals, a bank account in the Member's own name.
• Distributors and Master Distributors may be asked for more documents (GST registration if applicable, business proof).
• KYC status is shown as Pending, Verified or Rejected. We may limit or suspend accounts with incomplete or doubtful KYC.
• Members must update their KYC details when they change.

2. Transaction monitoring

• We set limits on top-ups, transfers, withdrawals and transactions, and monitor for unusual patterns: rapid load-and-withdraw, structuring below limits, many accounts on one device, mismatched names, or reused UTRs.
• Wallet balance cannot be paid out to third parties. Settlements go only to the Member's verified own bank account.
• Cash deposits into the Company's accounts are discouraged. Top-ups should come from the Member's own bank or UPI account.

3. Suspicious activity

Where we suspect money laundering, fraud or other illegal activity, we may, without notice:

• freeze the account and Wallet
• ask for more information
• refuse or reverse transactions
• report to the Financial Intelligence Unit – India (FIU-IND), cyber-crime cells (1930 / cybercrime.gov.in) or other authorities as required or permitted by law

We will not tell the Member about such a report where the law prohibits it.

4. Record keeping

KYC records and transaction records are kept for at least 5 years after the business relationship ends or the transaction date, whichever is later, and produced to authorities when lawfully required.

5. Member responsibility

Members must not process transactions for known or suspected fraudsters, or let anyone else use their account. Distributors and Master Distributors must take reasonable care when onboarding Retailers and must report suspicious behaviour in their network.

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