Devvrat Capital Private Limited - Know Your Customer (KYC) Policy & FAQ
This Know Your Customer (KYC) Policy (“Policy”) is adopted by Devvrat Capital Private Limited (“the Company”) in accordance with and pursuant to the Reserve Bank of India’s Master Direction DBR.AML.BC.No.81/14.01.001/2015-16, dated February 25, 2016, as amended from time to time (“Master Direction - Know Your Customer (KYC) Direction, 2016”).
The Company undertakes to comply with all statutory and regulatory requirements as prescribed under applicable laws for the prevention of money laundering (ML), prevention of Terrorism Funding (TF), prevention of fraud (PF) and to ensure the integrity and stability of the financial system, both internationally and nationally.
Ans. KYC is a process by which a Regulated Entity (RE), including a bank, obtains information on:
This process helps to ensure that an RE is aware of the customer it is dealing with, and the services provided by the RE are not misused for Money Laundering/ Terrorist Financing/ Proliferation Financing (ML/TF/PF) purposes.
Ans. Yes, KYC is mandatorily required to be carried out:
Ans. A “Walk-in Customer” means a person who does not have an account-based relationship with the RE, but undertakes transactions with the RE.
Ans. No, if an existing KYC compliant customer of an RE desires to open another account or avail any other product/ service from the same RE, he is not required to submit any KYC document unless there is a change in the information with respect to his identity and/ or address.
Ans. Following documents are required for opening of an account by an individual:
(a) any one of the following Officially Valid Documents (OVDs) or the equivalent e-document thereof, containing details of his name and address, viz.,
(b) the Permanent Account Number (PAN) or the equivalent e-document, thereof, or Form No. 60 as defined in Income-tax Rules, 1962; and
(c) other documents in respect of the nature of business and financial status of the customer, or the equivalent e-documents thereof, as may be required by the RE.
Ans. In case a customer does not possess an OVD, he can still open a ‘Small Account’. For the purpose, the RE shall obtain a self-attested photograph from the customer and the designated officer of the RE certifies under his signature that the person opening the account has affixed his signature or thumb impression in his presence.
The Small Account shall remain operational initially for a period of twelve months and is subject to conditions as given under paragraph 23 of the Master Direction on KYC.
Ans. The customer can furnish one of the following documents or the equivalent e-documents thereof, if the OVD submitted by him to the RE does not contain current address.
These documents are deemed to be OVDs for the limited purpose of proof of address:
However, the customer shall submit OVD with current address within a period of three months of submitting the document specified above.
Ans. Yes. The customer can open an account with a RE by submitting a deemed to be OVD for the purpose of proof of address.
However, as mentioned in reply to Q 7 above, he is required to submit OVD with current address within a period of three months.
Ans. In such case, an OVD containing the earlier name along with a copy of the Gazette notification, or marriage certificate issued by the State Government, as applicable, indicating the change in name, can be submitted for opening the account.
Ans. No. However, in case the customer is desirous of receiving any benefit or subsidy under any scheme notified under section 7 of the Aadhaar (Targeted Delivery of Financial and Other subsidies, Benefits and Services) Act, 2016 (18 of 2016), the customer shall provide the Aadhaar number.
In other cases, the Aadhaar number may be provided voluntarily by the customers.
Ans. KYC verification once done by one branch/ office of the RE shall be valid for transfer of the account to any other branch/ office of the same RE, provided full KYC verification has already been done for the concerned account and the same is not due for periodic updation.
Ans. Yes, documents as mentioned in reply to Q 5 above shall be submitted by all account holders of a joint account to the RE.
Ans. An RE has the following options to onboard a customer:
(a) Face-to-face onboarding:
(b) Non-face-to-face onboarding:
Ans. KYC Identifier means the unique number or code assigned to a customer of an RE by the Central KYC Records Registry (CKYCR).
If the customer approaches an RE for opening an account, he can provide his KYC Identifier and give consent to the RE to download the valid KYC data from CKYCR.
This can obviate the need for the customer to submit KYC documents again while opening an account with another RE.
Ans. In addition to the purpose of establishing an account-based relationship, KYC Identifier can be used for updation/ periodic updation of KYC, or for verification of identity of a customer.
Further details in this regard are given in paragraph 56(j) of the Master Direction on KYC.
Ans. Yes, the RE is required to obtain customer’s explicit consent to use his/ her KYC Identifier for downloading KYC records from CKYCR for the purposes mentioned in reply to Q. 14 and 15.
Ans. A customer can obtain his KYC Identifier through the following ways:
Ans. For the purpose of opening an account, RE is required to seek the KYC Identifier from the customer or retrieve the same, if available, from the CKYCR and obtain KYC records by using such KYC Identifier.
In such cases, the customer is not required to submit the same KYC records/ information/ any other additional identification documents, unless–
Ans. V-CIP is an alternate method of customer identification with facial recognition and customer due diligence that allows REs to obtain and verify a customer’s identity information through a digital, secure, live, informed and consent-based and live audio-visual interaction between an authorised RE official and the customer to obtain identification information required for Customer Due Diligence - CDD purpose.
V-CIP eliminates the need for physical visit to a branch of the RE but is treated on par with face-to-face CIP.
Assisted V-CIP is also permitted when banks take help of Business Correspondents (BCs) facilitating the process only at the customer end.
Ans: No, making specific facial gesture like blinking of eyes, smiling, frowning, etc. are not mandatory for liveness check.
The RE is required to take due cognizance of special need, if any, of the customer during liveness check.
Ans. V-CIP may be used for carrying out the following processes:
Ans. RE is required to update the customers’ KYC records as part of ongoing due diligence process to ensure that the information or data collected under CDD is kept up to date and relevant.
The periodicity of such updation depends on the risk categorisation of the customer by the RE and such periodic updation of KYC records (at times referred to as re-KYC) shall be carried out at least once in every two years for high-risk, eight years for medium risk and ten years for low-risk customers.
However, RE may adopt any additional and exceptional measures as per its internal KYC policy which inter alia may require physical presence of the customer, periodic updation of KYC only in the branch of the RE where account is maintained, a more frequent periodicity of KYC updation than the minimum specified periodicity, etc.
Ans. The broad indicative parameters prescribed for customer’s risk categorisation are customer’s identity, social/ financial status, nature of business activity, information about the customer’s business and his/ her location, geographical risk covering customer as well as transactions, type of products/ services offered, delivery channel used for delivery of products/ services, types of transaction undertaken – cash, cheque/monetary instruments, wire transfers, forex transactions, etc.
While considering customer’s identity, the ability to confirm identity documents through online or other services offered by issuing authorities may also be factored in.
The risk category and reasons thereof are not required to be divulged to the customers by the RE.
Ans. The modes for periodic updation of KYC for individuals are as under:
Ans. The requirement of KYC documents depends on the modes used for periodic updation of KYC as detailed in the reply to Q 24, above.
Ans. Yes, once a customer submits updated KYC information or self-declaration to the RE, it shall provide an acknowledgement to this effect to the customer.
Upon updating KYC information, the RE shall also intimate customers about such updation.
Ans. Yes, the RE shall intimate its customer, in advance, to comply with the requirement of periodic updation of KYC.
Subsequent to the due date, RE shall also give reminders to such customer who has still not complied with the requirements, despite advance intimations.
Ans. Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 enable the REs to obtain the identity records (including updated records of identity) from the customers, failing which the RE shall close the account of the customers after giving due notice.
Ans. The customer shall exercise utmost caution before clicking links embedded in such SMS/ email as these may be suspicious/ fraudulent.
The public is advised not to fall prey to frauds being perpetrated in the name of KYC updation.
Please refer to the Press Release dated September 13, 2021 on RBI cautions against frauds in the name of KYC updation.
Ans. Payment of cheque/ draft/ pay order/ banker’s cheque, if presented beyond the period of three months from the date of issuance of such instrument, shall not be made by RE.
Ans. In case of any change in the OVDs such as change in demographic information or address or other documents submitted by a customer at the time of establishing account-based relationship, the customer shall submit the updated OVD/ other documents to the RE within 30 days of the update/ change/ modification in the documents for the purpose of updating the records at RE’s end.
In such case, the RE shall acknowledge the receipt of the KYC documents to the customer.
Ans: Yes, all modes of account opening as mentioned in the reply to Q 13 above, viz. onboarding customer in face-to-face mode; non-face-to-face mode and V-CIP are available to the person with disabilities.
Ans. REs’ Customer Acceptance Policy shall not result in denial of financial facility to members of the general public, especially those, who are financially or socially disadvantaged, including the persons with disabilities (PWDs).
The decision to reject the application of KYC/ periodic updation of KYC shall not be automated and such decisions on rejection shall be reviewed by an official of RE authorised for the purpose.
Ans: The provision to accept thumb impression in place of signatures has already been prescribed for onboarding customer in face-to-face-mode under paragraph 16 and 23 of the MD on KYC.