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Aml Policy

Anti-Money Laundering (AML) Policy

Quintus Technologies Private Limited ("QTPL")

1. Introduction

Quintus Technologies Private Limited ("QTPL") operates a technology-enabled API-based payment facilitation platform available through https://quintustech.in/, enabling businesses to process bulk payouts and payment transactions through integrations powered by one of India's leading and trusted banking institutions specializing in transaction banking and digital payments.

QTPL acts strictly as a technology service provider and payment facilitation platform for approved business use cases and does not participate in, control, own, or assume responsibility for the underlying commercial transactions between clients and their end customers/users.

This AML Policy is established to prevent misuse of QTPL's platform for money laundering, terrorist financing, fraud, unlawful fund movement, unauthorized financial activities, or any illegal business operations.

2. Purpose of Policy

The purpose of this Policy is to:

  • Ensure compliance with applicable Indian laws and regulatory requirements;
  • Prevent misuse of QTPL's infrastructure for unlawful or suspicious transactions;
  • Define responsibilities of clients using QTPL's platform;
  • Protect QTPL, its banking partners, and payment ecosystem from financial crime risks.

3. Nature of QTPL Services

QTPL provides:

  • API-based payout infrastructure,
  • Bulk payment processing solutions,
  • Utility and voucher redemption payment facilitation,
  • BBPS-enabled payment services,
  • Settlement support services,
  • Technology integration services.

QTPL does not:

  • Accept public deposits,
  • Operate as a bank,
  • Control customer funds independently,
  • Own or originate the underlying transactions,
  • Act as principal merchant for client businesses.

All transactions processed through QTPL are initiated, authorized, and controlled solely by the respective Client using the platform.

4. Client Responsibility & Undertaking

Every Client using QTPL's platform expressly agrees and undertakes that:

  1. All transactions initiated through the platform are lawful, genuine, and backed by valid business activity.
  2. The Client shall solely remain responsible for:
    • Nature of business,
    • Source of funds,
    • Legitimacy of customers,
    • End-use of transactions,
    • Regulatory compliance,
    • Customer KYC obligations,
    • Applicable licenses/permissions.
  3. The Client shall ensure that the platform is not used directly or indirectly for:
    • Money laundering,
    • Fraudulent activities,
    • Terror financing,
    • Gambling/betting,
    • Adult or prohibited services,
    • Crypto-related unauthorized activities,
    • Ponzi/multi-level marketing schemes,
    • Unauthorized lending,
    • Illegal gaming,
    • High-risk or restricted businesses,
    • Any activity prohibited under Indian law.
  4. Any change in business model, transaction flow, nature of services, customer segment, use case, or website/application functionality must be informed to QTPL in writing and approved prior to implementation.

5. KYC & Due Diligence

QTPL may conduct onboarding and periodic due diligence including collection of:

  • Company incorporation documents,
  • PAN/GST details,
  • Bank account proof,
  • Director/authorized signatory details,
  • Website/application review,
  • Business model verification,
  • Transaction pattern analysis,
  • Additional compliance documents as deemed necessary.

QTPL reserves the right to:

  • Reject onboarding,
  • Seek additional information,
  • Suspend accounts,
  • Hold transactions,
  • Report suspicious activity,
  • Terminate services,

without prior notice if risk or non-compliance is identified.

6. Transaction Monitoring

QTPL and/or its banking/payment partners may monitor transactions for suspicious patterns including but not limited to:

  • Unusual transaction spikes,
  • Layering or fund routing activities,
  • Circular transactions,
  • High refund ratios,
  • Mismatch in business activity,
  • Transactions inconsistent with declared use case,
  • Regulatory red flags,
  • Transactions involving prohibited categories.

QTPL may request supporting documents or explanations for any transaction at its sole discretion.

7. Reporting of Suspicious Activities

QTPL reserves the right to:

  • Suspend processing,
  • Hold settlements,
  • Block access,
  • Escalate suspicious cases to banking partners,
  • Report transactions to competent authorities/regulators/law enforcement agencies,

wherever required under applicable laws or upon reasonable suspicion.

The Client shall fully cooperate in such investigations and provide all requested documents/information promptly.

8. Indemnity & Limitation of Liability

The Client expressly agrees that QTPL acts only as a technology and payment facilitation intermediary.

QTPL shall not be liable or responsible for:

  • Nature of client transactions,
  • End-customer disputes,
  • Source or destination of funds,
  • Unauthorized or illegal business activities,
  • Regulatory violations by the Client,
  • Fraudulent transactions initiated by the Client,
  • Misrepresentation by the Client,
  • Customer KYC failures,
  • Tax violations,
  • Chargebacks, penalties, investigations, or legal proceedings arising due to Client conduct.

The Client shall fully indemnify, defend, and hold harmless QTPL, its directors, employees, banking partners, payment partners, and affiliates against any claims, losses, penalties, damages, investigations, regulatory actions, legal proceedings, costs or liabilities arising out of misuse of the platform, unlawful activities, or breach of applicable laws by the Client or its users/customers.

9. Restricted & Prohibited Categories

QTPL strictly prohibits usage of its platform for:

  • Illegal products/services,
  • Gambling or betting,
  • Adult content/services,
  • Drugs/narcotics,
  • Shell company transactions,
  • Crypto exchanges without approvals,
  • Unauthorized forex/remittance,
  • Fake invoicing,
  • Terror financing,
  • Multi-level marketing/Ponzi schemes,
  • High-risk financial activities,
  • Any business restricted under Indian law or banking regulations.

QTPL reserves absolute discretion to classify any business/use case as high-risk or prohibited.

10. Record Retention

QTPL may retain transaction and compliance records for such duration as required under applicable laws, banking guidelines, internal policies, or regulatory obligations.

11. Policy Updates

QTPL reserves the right to modify, update, or amend this AML Policy at any time without prior notice. Continued use of the platform shall constitute acceptance of the revised policy.

12. Governing Law & Jurisdiction

This Policy shall be governed by the laws of India.

Any disputes arising in relation to this Policy shall be subject to the exclusive jurisdiction of the courts where QTPL's registered office is situated.