MD & CEO, Audit & Compliance Committee, Board

The MD & CEO working under the broad directions of the Board of Nivara will ensure that an effective KYC programme is in place by establishing appropriate procedures and ensuring their effective implementation.

Nivara will establish suitable internal audit and compliance functions that will be tasked (amongst other things) with evaluating and ensuring adherence to the KYC policies and procedures.

Internal Audit

Nivara will in consultation with its statutory auditors establish a system of internal audits to check and verify the application of KYC procedures at the branches and comment on the lapses observed in this regard. The compliance in this regard will be put up before the Audit Committee of the Board at quarterly intervals.

Employee Training and Customer Education

Nivara will have an ongoing employee training programme so that the members of the staff are adequately trained in KYC procedures. Such training will have different focus for frontline staff, compliance staff and staff dealing with new customers.

Nivara frontline staff will be adequately equipped to educate customers on the needs and requirements with respect to KYC documentation.

Introduction of New Technologies

Nivara will evaluate potential money laundering threats and ensure its mitigation while developing and operating its systems.

Appointment of Principal Officer

Nivara has appointed Balaji Thavamani – Manager – Operations as the “Principal Officer” who will be responsible for reporting all transactions and sharing of information. He will be responsible for monitoring and reporting of all transactions and sharing of information with various relevant regulatory authorities in normal course and as required under the law.

Maintenance, Preservation and Reporting of Specified transactions

Nivara will ensure compliance with respect to maintaining, preservation and reporting of transactions as required under section 12 of the PMLA read with Rule 3 of the PML Rules.

Reporting to Financial Intelligence Unit-India

As required under Section 12 of PMLA, Nivara will report information of transaction referred to in clause (a) of sub-section (1) of section 12 read with Rule 3 of the PML Rules relating to cash and suspicious transactions etc. to the Director, Financial Intelligence Unit-India (FIU-IND).

It is understood that Nivara need not submit ‘NIL’ reports in case there are no Cash/Suspicious Transactions, during a particular period.

An illustrative (but not exhaustive) list of suspicious transactions are given in subsequent sections viz. Suspicious Transactions - Builder and Suspicious Transactions - Housing Loans

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