Financial & RBI Policy

This Financial & RBI Compliance Policy is published by HRHKILLO Enterprise (OPC) Private Limited ("HRHKILLO", "we", "us") to outline our adherence to the guidelines issued by the Reserve Bank of India (RBI), including the Prevention of Money Laundering Act (PMLA), KYC Master Directions, and Guidelines on Regulation of Payment Aggregators and Payment Gateways.

1. Nature of Business & Financial Activities

HRHKILLO is strictly an IT and software services development firm. We are not a bank, Non-Banking Financial Company (NBFC), Payment Aggregator (PA), Payment Gateway (PG), or money transmitter. All financial activities conducted by our company are strictly limited to the collection of professional fees for digital services rendered and the disbursement of legitimate business expenses (such as salaries, vendor payments, and software licenses).

As part of our Fintech & Financial Solutions practice (see Services), HRHKILLO additionally designs, develops, and integrates technology for payment aggregation, cross-border payment rails, and Virtual Digital Asset (VDA) / cryptocurrency platforms — strictly as a software development and integration partner to our clients. HRHKILLO does not itself act as a Payment Aggregator, Authorised Dealer, or Virtual Digital Asset Service Provider; the regulated financial activity in each such engagement is carried out by our duly licensed or registered clients and their designated financial partners.

2. Authorized Payment Channels

In compliance with RBI digital payment directives:

• All customer pay-ins (booking advances, milestone payments, final invoices) are routed exclusively through RBI-authorised Payment Aggregators / Payment Gateways or regulated banking channels (UPI, IMPS, NEFT, RTGS, and SWIFT for international/cross-border clients).
• We do not accept or process cash transactions for any of our services through the website.
• All payouts and refunds are executed via the respective Payment Aggregator's payout APIs or direct bank transfers to verified accounts.

3. KYC (Know Your Customer) & AML (Anti-Money Laundering)

To prevent fraudulent activities and adhere to India's anti-money laundering frameworks, we enforce strict KYC norms during client onboarding:

• B2B Clients: Verification of GSTIN, PAN, and corporate identity prior to the commencement of large-scale financial or enterprise projects.
• B2C Clients: Collection of verified contact information matching the payment source to prevent unauthorized third-party transactions.
• We strictly monitor transactions for suspicious activity and are committed to reporting any anomalies to the appropriate authorities as mandated by law.

4. Prohibited Financial Activities

We do not provide services for or process transactions related to any business listed in the "Negative, Risky and Restricted Categories" of RBI or our PA partners, including but not limited to:

• Unregulated gambling, betting, or lotteries.
• Unregistered/unlicensed cryptocurrency exchanges, unregulated trading, or Ponzi/MLM schemes.
• Unlicensed lending apps or illegal financial advisory services.

4A. Virtual Digital Assets (VDA) / Cryptocurrency Technology Services

HRHKILLO provides software development, integration, and technology consulting for Virtual Digital Asset (VDA) and cryptocurrency platforms as described in our Services. In connection with this practice, HRHKILLO has applied for registration with the Financial Intelligence Unit – India (FIU-IND) as a Reporting Entity under the Prevention of Money-Laundering Act, 2002; this application was submitted on or around 9 August 2026 and is currently under processing.

Pending confirmation of this registration, HRHKILLO does not itself operate a crypto exchange, custody Virtual Digital Assets, or act as a counterparty to any VDA transaction. All crypto/VDA engagements are limited to technology development, integration, and advisory services provided to appropriately licensed or registered third parties, subject to full KYC/KYB and AML due diligence.

4B. AML/CFT, Sanctions Screening & Restricted Jurisdictions

HRHKILLO maintains an internal Anti-Money Laundering / Counter-Financing of Terrorism (AML/CFT) programme aligned with the Prevention of Money-Laundering Act, 2002, the RBI Master Direction on KYC, and — in connection with our VDA/crypto technology practice — the Financial Action Task Force (FATF) Recommendations on virtual assets, pending confirmation of our FIU-IND registration.

• Customer Due Diligence (CDD): identity and business verification (PAN, GSTIN, CIN, registered address, and director/UBO details) is completed for every B2B client before commencement of any fintech, payment-aggregation, cross-border, or crypto/VDA engagement.
• Sanctions & watch-list screening: clients and counterparties are screened, on a risk basis, against the UN Security Council Consolidated List, the OFAC Specially Designated Nationals (SDN) List, and other applicable sanctions lists prior to onboarding.
• Politically Exposed Persons (PEPs): enhanced due diligence is applied where a client, director, or beneficial owner is identified as a PEP or a close associate of a PEP.
• Restricted jurisdictions: HRHKILLO does not knowingly onboard, or provide technology services to, individuals or entities located in, incorporated in, or ordinarily resident in countries or territories subject to comprehensive UN, OFAC, or EU sanctions, or identified by FATF as high-risk / non-cooperative jurisdictions.
• Travel Rule readiness: for crypto/VDA technology engagements, integrations are designed to support originator/beneficiary information transfer consistent with FATF Travel Rule expectations, to be operated by our licensed or registered clients.
• Suspicious activity & reporting: HRHKILLO reserves the right to decline, suspend, or terminate any engagement, and to report to FIU-IND or other competent authorities, where a transaction or relationship raises money-laundering, terrorist-financing, proliferation-financing, or sanctions-evasion concerns.
• Record-keeping: KYC/KYB records and transaction data relevant to an engagement are retained for a minimum of 5 (five) years from the end of the business relationship, in line with PMLA record-keeping requirements.

5. Data Security for Financial Transactions

We do not collect, store, or process sensitive Card Data (Credit/Debit Card numbers, CVV, Expiry dates) or banking passwords on our servers. All transaction processing is securely handled off-site by our PCI-DSS compliant Payment Aggregators.

For more details on data handling, please refer to our Privacy Policy and Terms & Conditions.

6. Grievance Officer

7. Changes to this Policy

We may update this policy from time to time. The "Last updated" date reflects the latest revision. Material changes will be highlighted on the homepage or via email where appropriate.

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