1. Purpose and Scope
InvestHaat is committed to preventing the platform from being used for money laundering, terrorist financing, or any other financial crime. This AML Policy applies to all users of the platform — founders, investors, mentors, and service providers.
This policy is established in compliance with the Prevention of Money Laundering Act, 2002 (PMLA), the PMLA Rules 2005, and guidelines issued by the Financial Intelligence Unit — India (FIU-IND).
2. Definition of Money Laundering
Money laundering is the process of making illegally obtained money appear legitimate. It typically involves three stages:
Placement: Introducing illegal funds into the financial system
Layering: Disguising the trail of illegal funds through complex transactions
Integration: Making the funds appear as legitimate business proceeds
InvestHaat's platform, if misused, could potentially be used as a vehicle for any of these stages. This policy is designed to prevent all three.
3. Customer Due Diligence (CDD)
InvestHaat performs the following due diligence on all users:
Basic CDD (all users): Identity verification via Aadhaar and PAN. Name, address, and date of birth verification against government databases.
Enhanced CDD (investors above ₹10L threshold): Source of funds declaration. Income verification. Beneficial ownership declaration for corporate investors. PEP (Politically Exposed Person) screening.
Ongoing Monitoring: Transactions are monitored for unusual patterns. Risk scores are updated as new activity data is collected.
4. Suspicious Transaction Reporting
InvestHaat is required by law to report Suspicious Transaction Reports (STRs) to the FIU-IND within 7 days of detecting suspicious activity.
Indicators of suspicious activity include:
• Investments that appear inconsistent with the user's stated income or net worth
• Multiple accounts using the same KYC documents
• Unusual transaction structuring (e.g., many small investments just below reporting thresholds)
• Investments funded from countries with weak AML controls
• Immediate withdrawal of funds after receiving a refund
• Startups with implausibly rapid fundraising from new, unverified accounts
InvestHaat is legally prohibited from informing the user that an STR has been filed ("tipping off" prohibition).
5. Record Keeping
InvestHaat maintains KYC records and transaction records for a minimum of 5 years from the date of each transaction, as required by the PMLA. Records include:
• Identity documents submitted during KYC
• Transaction history (amount, date, parties, method)
• IP addresses and device fingerprints at time of investment
• Correspondence related to any suspicious activity investigation
6. PEP Policy
Politically Exposed Persons (PEPs) — individuals who hold or have held prominent public functions — are subject to enhanced due diligence. InvestHaat screens all users against PEP databases.
PEPs are not automatically prohibited from using the platform but are subject to senior management approval for investments above ₹1 lakh and ongoing enhanced monitoring.
7. Sanctions Screening
InvestHaat screens all users against OFAC (Office of Foreign Assets Control), UN Security Council sanctions lists, and any Indian government sanctions lists. Any user identified as a sanctioned individual or entity will be immediately blocked and reported to the relevant authorities.
8. AML Compliance Officer
InvestHaat's designated AML Compliance Officer is responsible for:
• Implementing and updating this policy
• Filing STRs with FIU-IND
• Conducting AML training for internal staff
• Ensuring regulatory compliance
AML Compliance Contact: compliance@investhaat.in
9. User Obligations
By using InvestHaat, you agree to:
• Provide accurate and truthful KYC information
• Not use the platform to launder money or finance illegal activity
• Immediately inform InvestHaat if you become aware of any suspicious activity involving your account
• Cooperate fully with any regulatory investigation
Violation of this policy may result in immediate account suspension, fund freezing, and reporting to law enforcement.