CUstomer onboarding Policy

COP1 : NO ANONYMOUS ACCOUNT

No account should be opened in anonymous or fictitious name or account on behalf of other persons whose identity has not been disclosed or cannot be verified.

 

COP2 : MUST COMPLETE CUSTOMER DUE DILIGENCE 

No account would be opened, if GRDA is unable to apply appropriate customer due diligence measures i.e. GRDA is unable to verify the identity and/or obtain documents required as per the risk categorisation due to non-cooperation of the customer or non-reliability of the data/information furnished to GRDA. While carrying out due diligence it would be ensured that there is no harassment to the customer. The existing account where GRDA is not able to apply appropriate customer due diligence measures may be considered to be closed. The decision to close an account would be taken by the Compliance Officer after giving due notice to the customer, explaining the reasons for such a decision.


COP3 : CUSTOMER DUE DILIGENCE SHOULD NOT BE RESTRICTIVE

While carrying out due diligence, it shall be ensured that the procedure adopted shall not become too restrictive and must not result in denial of GRDA services to general public, specially to those, who are at financial or social disadvantage.


COP4 : CUSTOMER BACKGROUND CHECK BEFORE OPENING A NEW ACCOUNT

Before opening a new account, necessary checks shall be conducted so as to ensure that the identity of the customers/entities/persons associated with the entities does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organisations etc. Lists circulated by relevant regulatory authorities of persons with known criminal background or banned entities as well as a list of persons involved in frauds and deliberate default as per information available with GRDA shall be used for this purpose. 


COP5 : CUSTOMER INFORMATION MUST BE OBTAINED AT THE TIME OF ACCOUNT OPENING

For the purpose of risk categorisation of customer, the relevant information shall be obtained from the customer at the time of account opening. While doing so, it shall be ensured that information sought from the customer is relevant to the perceived risk and is not intrusive.


COP6 : INDICATIVE RISK CATEGORISATION OF CUSTOMER 

Risk perception of different types of customers taking into account the background of the customer, nature of business activity, location of customer/ activity and profile of his/her customers, country of origin, sources of funds, mode of payments, volume of turnover, social and financial status etc. shall be decided based on the relevant information provided by the customer at the time of account opening. The intensive due diligence would be required for higher risk customers, especially those for whom the sources of funds are not clear. An indicative risk categorization of customers based on customer types is provided at the end of this COP, which would be reviewed periodically by the KYC Committe of GRDA.


COP7 : ASSESSMENT OF ML/TF RISK OF CUSTOMER

GRDA shall take steps to identify and assess the Money Laundering/ Terrorist Financing risk for customers, countries and geographical areas as also for products, services, transactions, delivery channels. The risk assessment carried out shall consider all the relevant risk factors before determining the level of overall risk and the appropriate level and type of mitigation to be applied. The assessment shall be documented, updated regularly and made available to competent authorities and self-regulating bodies, as and when required.


COP8 : CUSTOMER PROFILING BASED ON RISK CATEGORISATION

A profile for each new customer shall be prepared based on risk categorisation. The customer profile shall contain information relating to customer’s identity, social/financial status, nature of business activity, information about customers’ business and their location etc. The nature and extent of due diligence shall depend on the risk categorization of the customer. While preparing customer profile, care shall be taken to seek only such information from the customer, which is relevant to the risk category and is not intrusive. The customer profile is a confidential document and details contained therein should not be divulged for cross selling or any other purposes.


COP9 : REQUIRE FURTHER INFORMATION FROM CUSTOMER IF NEEDED 

Indicative information to be obtained from the customer at the time of opening of account for the purpose of creating customer profile is given in Identification section. The information to be sought from the customer would be reviewed by KYC Committee from time to time based on the guidelines issued by Company Registry and also depending upon business requirement and composition of the customers.


COP10 : CUSTOMER INFORMATION MUST BE VERIFIED 

The documentation requirements for completing the KYC are reviewed by KYC Committe from time to time, based on emerging business needs of GRDA and shall comply with the overall guidelines issued by Company Registry from time to time. Documents for verification of identity is also given in Identification section.


COP11 : CUSTOMER ACCEPTED AFTER IDENTITY VERIFICATION

Customer shall be accepted after verifying their identity as laid down in customer identification procedures. Documentation requirements and other information shall be collected in respect of different categories of customers depending on perceived risk and keeping in view the requirements of AMLO and guidelines issued by Company Registry.


COP12 : MANDATE HOLDER IDENTITY MUST  BE VERIFIED

There could be occasions when an account is to be operated by a mandate holder, power of attorney or where an account is to be operated by an intermediary in fiduciary capacity, such information needs to be obtained while accepting the customer and capture the same in GRDA Customer Profile System.


COP13 : BENEFICIAL OWNER IDENTITY MUST BE VERIFIED

Customer on whose behalf (i.e., Beneficial Owner), the accounts are maintained and operated, such information needs to be obtained while accepting the customer and capture the same in GRDA's Customer Profile System.


COP14 : RELIANCE OF THIRD PARTY INTERMEDIARY CDD WITH CONDITIONS  

For the purpose of customer due diligence,  GRDA may rely on a third party intermediary subject to the following conditions:

  1. GRDA immediately obtains necessary information of such customer due diligence carried out by the third party;
  2. GRDA takes adequate steps to satisfy itself that copies of identification data and other relevant documentation relating to the customer due diligence requirements will be made available from the third party upon request without delay;
  3. GRDA is satisfied that such 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 Act;
  4. the third party is not based in a country or jurisdiction assessed as high risk; and
  5. GRDA shall be ultimately responsible for customer due diligence and undertaking enhanced due diligence measures, as applicab

Indicative Risk Categorization (pdf)

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