Fincrypt LLP (Operating under brand name: Stable Pay)

1. Objective

The objective of this Enhanced Due Diligence (EDD) Policy is to establish a structured, risk-based, and heightened scrutiny framework for customers, transactions, or business relationships that present an elevated risk of money laundering, terrorist financing, proliferation financing, or other financial crimes.

This Policy ensures compliance with the Prevention of Money Laundering Act, 2002 (PMLA), FIU-IND guidelines, applicable RBI advisories, and FATF recommendations, while maintaining transparency, traceability, and regulatory readiness.

2. Scope & Applicability

This Policy applies to:

• All individual, merchant, corporate, and institutional customers
• Existing and prospective customers
• Domestic and cross-border transactions
• Compliance, risk, and senior management teams

EDD is applied in addition to Standard CDD, not as a replacement.

3. EDD Trigger Events

EDD is initiated when one or more of the following conditions are identified:

3.1 High-Risk Customer Categorization

• Customers classified as High Risk under the Risk Categorization SOP
• Customers exhibiting mule account indicators or abnormal behavior