VIPS Finstock Anti Money Laundering Policy


The Company's commitment to preventing money laundering, financing of terrorism, and other illicit actions is reflected in this Anti-Money Laundering Policy (the "AML Policy"). It outlines the policies and practises put in place by the Company to make sure that Users are not using the services provided by the Company to facilitate the working of any crimes.
This AML Policy was created by the company to ensure trading transparency and to stop money laundering and other illicit actions.
The terms "We", "Our", "Company", "VIPS Finstock" and "Us" relate to the Company, and the terms "User", "You" and "Your" refer to a User of our Online Platform.
Each and every User who wants to use the Services or otherwise access or utilise them is subject to this AML Policy.
Utilising the Online Platforms to their advantage and may be viewed as a part of the User Terms and Conditions. You must read this AML Policy in its entirety before using the Online Platforms or providing any personal data. You expressly agree to be governed by the User Terms and Conditions and, as a result, this AML Policy by using the Online Platforms.


A. In accordance with this AML Policy, a "Beneficial Owner" is defined as:
  • In the case of corporations, a natural person who owns more than 25% (twenty five percent) of the company's shares, is entitled to more than 25% (twenty five percent) of the profits, or has the authority to directly or indirectly appoint or elect more than half of the board of directors of such corporation, as the case may be;
  • The natural person who, in the case of partnership firms or Limited Liability Partnerships, owns more than 15% (fifteen percent) of the capital or is entitled to more than 15% (fifteen percent) of the earnings of such a firm;
B. The following items are referred to as "Identification Document(s)":
  • a passport or official identification document (such as a birth certificate, national identification card, or driver's licence) with a photo, full name, a unique identification number, the date of birth, nationality, and, if applicable, a name change document;
  • A document proving your address, such as a recent utility or phone bill, bank statement, or letter from the government that includes your full name; and
  • any other document that the Company may from time to time notify; "Periodic Updates" refers to re-verifying the User's identity in accordance with Clause 8.1 (Customer Verification Procedure) of this AML Policy at regular intervals as the Company sees fit or as instructed by relevant authorities.
C. "Sanction Lists" are lists of both natural and legal entities that are part of any list circulated by any nation, administration, or international body, including the Office of Foreign Assets Control ("OFAC"), the US Department of the Treasury, the US Department of State, the United Nations Security Council, the European Union, Her Majesty's Treasury, the Hong Kong Monetary Authority, the Monetary Authority of Singapore, Combating Financing of Terrorism (CFT) under Unlawful Activities (Prevention) Act, 1967 –Directions to stock exchanges, depositories and all registered intermediaries, Combating Financing of Terrorism (CFT) under Unlawful Activities (Prevention) Act, 1967 –Directions to stock exchanges, depositories and all registered intermediaries, Financial Intelligence Unit - India (FIU-IND), Reserve Bank of India (RBI), Prevention of Money Laundering Act in 2002, Financial Action Task Force (FATF), and applicable laws.
D. The following actions, whether they are attempted or carried out, are referred to as "Suspicious Transactions":
  • Transactions that, to a reasonable person acting in good faith, appear to be money being raised for any terrorist organisation or a group affiliated with one shall be deemed to be terrorist financing; or to carry out any "Terrorism Financing Offence".
  • Unusually Complex transactions that, to a person acting in good faith, appear to have been structured in a way of unusual or unjustified complexity; or
  • Transactions with a malafide purpose are those that, to a person acting in good faith, appear to have neither a bona fide goal nor a strong economic justification.
Terms that are capitalised but are not specified elsewhere in this document shall have the meanings ascribed to them in the Terms (described below).

Policy Changes

This AML Policy may occasionally be modified and updated by the Company. These modifications may be made without prior notice, but they will only be applicable to activities and information moving ahead, not backward. Every time you enter the Online Platforms, we strongly advise you to read over this AML Policy.

Your Obligations

You acknowledge that it is your duty to ensure compliance with the terms and conditions described in this AML Policy and accord your consent to not using the Services and the Online Platforms in any manner which results in committing/attempting to commit any criminal offences. You also agree and consent to any changes made to this Privacy Policy in due course and without notice.
You must ensure that any personal information and/or Identification Documents submitted by you belong to you.
You must file a fresh proof of address within six months of making any changes to the address mentioned as per the ‘proof of address’ submitted by you.
If you are acting on behalf of a juridical person, you are required to identify the Beneficial Owner and help with the identification of anyone else who claims to be acting on that person's behalf.

Purpose of this policy

The Company aims to implement this policy, which includes the following components, to reduce its risks related to money laundering and other unlawful activities:
  • Customer Acceptance Terms
  • Risk Management Protocol
  • Customer Verification Protocol
  • Transaction Monitoring Terms

Customer Acceptance Terms

The following may be checked off by the Company at the time the User Account is opened, during any transactions, during Periodic Updates, or for any other purpose.
  • Demand that you submit your identification documents and other information as required by AML Policy during the activation procedure of your user account.
  • If the Company has reason to believe that you are a person or entity listed on the Sanctions Lists, it may require you to provide additional information to prove your identity.
  • Compel you to provide any additional information and/or data that may be required by a qualified enforcement authority.
  • Demand that you attest that the only scheduled commercial bank with whom you have a linked bank account complies with all Know Your Customer (KYC) requirements established by the relevant laws.
If the Company is unable to ensure compliance with any of the aforementioned conditions, either due to non-cooperation by the User or due to the details provided by the User being found on any Sanctions Lists or unreliable or unverifiable to the Company's satisfaction, the Company may, in its sole discretion, refuse to open any new accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Online Platforms.

Risk Management Procedure

The following considerations (including without limitation) may be used by the Company to appropriately analyse each User's risk before the Company places them in low, medium, or high-risk categories, including you:
The completeness and accuracy of the identifying data provided;
The social and/or financial situation of the User;
The nature of the User's professional or business activity; or
Various governmental and multilateral organisations' guidance notes. You agree that the Company will keep your risk categorization and all data pertaining to it confidential in order to protect the integrity of the Risk Management Procedure. You won't have the right to request disclosure of your risk classification. However, if the Company determines that a specific User has executed or is likely to execute any Suspicious Transaction, it may disclose the User's risk categorization data to the appropriate enforcement authority.

Customer Verification Process

The following information may be requested by the Company for the purposes of confirming any User's identification during the activation of User Accounts, while carrying out any transactions, or for any other reason.
  • In the case of individuals, one copy of any identification document with their name, address, and phone number; one current photo; and any other documentation relevant like Pan card, Adhaar card & bank details to verify a customer identity.
  • Certificate of Incorporation, Memorandum and Articles of Association, Board resolution authorising to transact on the Online Platform, Identification Documents containing identification and address details of the individual authorised to transact, and a copy of such authorization document are all required in the case of companies.
  • In the case of a partnership firm or limited liability partnership, one copy of each of the following documents is required: registration or incorporation certificates, partnership deeds, identification documents containing the name and address of the person authorised to transact business, and a copy of each of these documents. All copies of the aforementioned identification documents must be properly certified, according to users.
The Company may rely on suitable and authorised third-party service providers to authenticate the Identification Documents and other incidental information provided by the User for the purposes of confirming any User's identity.
The Company may, in its sole discretion, refuse or terminate (as applicable) the registration of such User Account or require further verification of such User's Identification Documents if it determines that any User information obtained in accordance with the procedure described under this Clause is insufficient, inadequate, or listed on the Sanctions Lists.

Transaction Monitoring Terms

The Company routinely monitors all transactions carried out and/or attempted to be carried out on the Online Platforms, both manually and through the use of software-based algorithms, in order to quickly identify and highlight specific types of transactions, including but not limited to the following kinds of transactions:
  • A high value transaction
  • International transactions involving; and
  • Transactions deemed suspicious udner Singaporean Law
The Company may, from time to time, do the required research in order to spot and analyse transactions that don't fit any User's risk profile, complexity, and anticipated usage pattern.
The level of surveillance will be determined by a number of variables, including each User's risk profile.
The Company retains the right to cancel the User Account, restrict and/or block access to Online Platforms, or notify the proper law enforcement authorities of any User's actions in relation to transactions recognised under this Transaction Monitoring Terms.

Maintenance of Records

For a minimum of 10 (Ten) years from the date of each transaction, the Company shall keep track of and preserve the information and/or data listed below:
  • Records of all transactions made on the Online Platforms.
  • Records of all transactions listed under Clause 9 (Transaction Monitoring Terms) above for a minimum of 12 (Twelve) years, including but not limited to details regarding the kind, amount, parties involved, and the date of remittance of such transactions.
  • Identification records of Users, for a minimum of 10 (Ten) years after the date the User Account was terminated, including but not limited to the Identification Documents submitted in accordance with Clause 8 (Customer Verification Procedure) above.

Compliance, Disclosure, and Notice

The Company may, from time to time, provide the relevant law enforcement authorities with information regarding transactions detected under Clause 9 (Transaction Monitoring Terms), identification details of such Users, or any other information required by applicable law.
You are encouraged to contact our Compliance Officers at legal@vipsfinstock.com with any information you have about any suspicious transactions or transactions that you find or have reason to believe are questionable in nature in order to help improve the integrity and transparency of transactions on the online platforms.