Anti-Money Laundering Policy

1. Policy Statement

Ghar Se Technologies ("Ghar Se," "we," "us," or "our") is committed to fully complying with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations in Pakistan. We have a zero-tolerance policy towards money laundering, terrorist financing, and any other financial crimes. This Anti-Money Laundering Policy (the "Policy") outlines our approach to preventing, detecting, and reporting money laundering activities on our platform.

2. Scope and Applicability

This Policy applies to all operations, employees, contractors, agents, and business partners of Ghar Se. It covers all products and services offered through the Ghar Se platform, including but not limited to ride-hailing, food delivery, marketplace transactions, wallet services, and payment processing. All users of the platform, including passengers, drivers, riders, vendors, and merchants, are subject to the AML measures outlined in this Policy.

3. Regulatory Framework

Ghar Se's AML/CTF compliance program is designed to comply with the following laws and regulations:

• The Anti-Money Laundering Act, 2010 (as amended)
• The Anti-Money Laundering and Counter-Terrorism Financing Regulations issued by the State Bank of Pakistan
• The Financial Monitoring Unit (FMU) guidelines and directives
• The Pakistan Penal Code, 1860 (relevant provisions on financial crimes)
• The Prevention of Electronic Crimes Act (PECA), 2016
• Any other applicable AML/CTF laws, regulations, and guidelines issued by relevant Pakistani authorities
• Financial Action Task Force (FATF) recommendations as adopted by Pakistan

4. Customer Due Diligence (CDD)

Ghar Se implements robust customer due diligence measures to verify the identity of our users and assess potential risks:

4.1 Standard CDD

• All users must provide accurate and complete personal information during registration, including full name, phone number, CNIC, and address.
• Identity verification is conducted through our KYC process, which includes document verification and, where required, biometric verification.
• Users are screened against sanctioned persons lists, politically exposed persons (PEP) databases, and other relevant watchlists.

4.2 Enhanced Due Diligence (EDD)

• EDD is applied to users who present a higher risk, including those from high-risk jurisdictions, PEPs, and users conducting high-value or unusual transactions.
• EDD measures include additional document verification, source of funds inquiry, and enhanced transaction monitoring.
• Senior management approval is required for onboarding high-risk users.

4.3 Ongoing Due Diligence

• Customer information is kept up to date, and users are required to update their information when it changes.
• Periodic reviews of existing customers are conducted to identify any changes in risk profile.
• Account activity is continuously monitored for unusual or suspicious patterns.

5. Transaction Monitoring

Ghar Se maintains a transaction monitoring system to detect suspicious activity:

• All transactions on the platform are monitored in real-time using automated systems that flag unusual patterns, including:
  • Transactions exceeding predefined thresholds.
  • Rapid series of transactions within a short timeframe.
  • Transactions involving high-risk jurisdictions.
  • Unusual transaction patterns inconsistent with normal user behavior.
  • Transactions involving virtual currencies or anonymizing technologies.
  • Multiple accounts associated with the same person or device.
• Flagged transactions are reviewed by our compliance team for further investigation.
• Transaction monitoring parameters are reviewed and updated regularly based on emerging risks and regulatory guidance.

6. Suspicious Activity Reporting

Ghar Se has established procedures for reporting suspicious activity:

• Any employee, contractor, or agent who suspects money laundering, terrorist financing, or any financial crime must report it immediately to the Compliance Officer.
• The Compliance Officer investigates the matter and determines whether a Suspicious Transaction Report (STR) should be filed with the Financial Monitoring Unit (FMU) of Pakistan.
• STRs are filed promptly and in accordance with FMU requirements and timelines.
• Ghar Se maintains strict confidentiality regarding STR filings. No tipping-off is permitted — users who are the subject of an STR will not be informed of the filing.
• Records of all STRs and related investigations are maintained for at least 10 years.

7. Record Keeping

Ghar Se maintains comprehensive records in compliance with AML/CTF requirements:

• Customer Identification Records: All KYC documents and identification records are retained for at least 5 years after the business relationship ends.
• Transaction Records: All transaction records, including the nature, value, and parties involved, are retained for at least 10 years from the date of the transaction.
• Communication Records: Records of all communications related to AML/CTF matters, including STRs, internal reports, and compliance decisions, are retained for at least 10 years.
• Training Records: Records of AML/CTF training provided to employees are maintained for at least 5 years.

8. Training and Awareness

Ghar Se is committed to ensuring that all employees and relevant personnel are adequately trained on AML/CTF matters:

• Initial Training: All new employees receive AML/CTF awareness training as part of their onboarding process.
• Ongoing Training: Regular training sessions are conducted to keep employees informed about emerging risks, regulatory changes, and internal policies.
• Specialized Training: Compliance team members and relevant personnel receive specialized training on AML/CTF investigation techniques, regulatory reporting, and risk assessment.
• Training Records: Attendance and completion of training are documented and retained.
• Testing: Periodic testing is conducted to assess employee understanding of AML/CTF obligations.

9. Compliance with Pakistan AML Laws

Ghar Se's AML compliance program is specifically designed to meet the requirements of Pakistan's AML/CTF legal framework:

• We have registered with the relevant regulatory authorities as required.
• We have appointed a designated Compliance Officer responsible for AML/CTF compliance.
• We conduct risk assessments to identify and mitigate money laundering and terrorist financing risks specific to our business model and the markets we operate in.
• We comply with all AML/CTF reporting obligations, including STR filings, currency transaction reports, and any other required disclosures.
• We cooperate fully with law enforcement agencies, the FMU, and other regulatory authorities in their investigations.

10. Compliance Officer

Ghar Se has appointed a Compliance Officer who is responsible for implementing and overseeing the AML/CTF compliance program. The Compliance Officer's responsibilities include:

• Developing, implementing, and maintaining AML/CTF policies and procedures.
• Receiving and investigating internal reports of suspicious activity.
• Filing STRs and other reports with the FMU and other regulatory authorities.
• Conducting AML/CTF risk assessments.
• Providing AML/CTF training to employees.
• Serving as the primary point of contact for regulatory authorities on AML/CTF matters.
• Reporting to senior management and the Board of Directors on AML/CTF compliance.

11. Penalties for Non-Compliance

Ghar Se takes AML/CTF compliance seriously. Violations of this Policy by employees, contractors, or agents will result in disciplinary action, up to and including termination of employment or engagement. Additionally, violations may result in:

• Account suspension or termination for users who engage in or are suspected of engaging in money laundering or terrorist financing.
• Freezing of funds and assets associated with suspicious accounts.
• Reporting to law enforcement and regulatory authorities.
• Legal action and prosecution as provided by law.

12. Policy Review and Updates

This AML Policy is reviewed at least annually and updated as necessary to reflect changes in laws, regulations, and business operations. All updates are communicated to relevant personnel and stakeholders.

13. Contact Us

For questions or concerns regarding this Anti-Money Laundering Policy, or to report suspicious activity, please contact our Compliance Officer:

• Email: [email protected]
• Phone: +92-300-1234567
• Address: Ghar Se Technologies, Attn: Compliance Officer, Islamabad, Pakistan