ANTI-MONEY LAUNDERING (AML) & KYC POLICY

1. PURPOSE & SCOPE

Yutiqaa Lifestyle Private Limited (“Yutiqaa”) is committed to the highest standards of financial integrity. As a purveyor of high-value artisanal masterpieces, we operate in strict accordance with the Prevention of Money Laundering Act (PMLA), 2002, and international Financial Action Task Force (FATF) standards. This policy is designed to prevent Yutiqaa from being used as a vehicle for money laundering, terrorism financing, or other financial crimes.

2. CUSTOMER IDENTIFICATION PROCEDURE (KYC)

To ensure the legitimacy of high-value transactions, Yutiqaa employs a tiered Know Your Customer (KYC) protocol:

• The Verified Patron Threshold: In alignment with our Terms & Conditions and Indian regulatory requirements, any single transaction or series of connected transactions exceeding ₹2,00,000 (Two Lakh Indian Rupees) or its equivalent in foreign currency, triggers mandatory KYC verification. To minimize lead-time, the 24-hour verification window for high-value orders runs concurrently with the 24-hour cancellation window. This ensures that the ‘Artisanal Buffer’ (weaving time) begins immediately upon the successful closure of both periods.
• Required Documentation (Domestic): Patrons must provide a valid Permanent Account Number (PAN) card. For corporate entities, a GST Registration Certificate and the Authorized Signatory’s PAN are required.
• Required Documentation (International): Patrons must provide a high-resolution copy of a government-issued Passport or National Identity Card.
• Verification Process: Documents must be uploaded via the secure Patron Portal at the time of purchase. Verification is conducted via encrypted third-party automated systems before the “Artisanal Buffer” period begins.

3. ANTI-MONEY LAUNDERING (AML) STANDARDS

• Source of Funds: For ultra-high-value bespoke commissions (exceeding ₹5,00,000), Yutiqaa reserves the right to request a self-declaration regarding the source of funds to ensure compliance with global wealth transparency norms.
• Strict Gatekeeper Policy: Yutiqaa operates exclusively through secure, gated Payment Gateways (PGs). We do not accept cash-on-delivery for high-value items, nor do we accept direct international wire transfers outside of our integrated PG environment.
• Third-Party Payment Restriction: To prevent “Layering,” the name on the payment instrument (Credit Card/Bank Account) must match the name of the registered Patron or the verified KYC entity. Discrepancies will result in an immediate transaction hold.

4. GLOBAL JURISDICTIONAL COMPLIANCE (COUNTRY-SPECIFIC)

As a global brand, Yutiqaa adheres to regional financial “High-Value Dealer” (HVD) regulations:

• United States: We comply with the Bank Secrecy Act (BSA) and USA PATRIOT Act requirements. Transactions exceeding $10,000 are subject to intensified monitoring and, if necessary, the filing of a Currency Transaction Report (CTR).
• Canada: We adhere to the CBSA (Canada Border Services Agency) regulations. Our DDP model includes the calculation of GST/HST (and PST/QST where applicable) based on your specific province. Yutiqaa manages the brokerage fees and duties for items exceeding the CAD 20 de minimis, ensuring the Patron receives a single, final price at checkout with no secondary “COD” requests from the courier.
• European Union: We adhere to the 6th Anti-Money Laundering Directive (6AMLD). High-value transactions are screened for “Ultimate Beneficial Ownership” (UBO) to prevent the use of shell entities in luxury acquisitions. 
• UK: Following Brexit, Yutiqaa complies with the HMRC UK VAT requirements. We collect 20% VAT at the point of sale for all orders. For consignments exceeding the £135 threshold, we manage the formal customs entry and prepay all applicable import duties. This ensures that your masterpiece is cleared via the “Fast Track” system and delivered without any “Import VAT” or “Handling Fee” demands at your doorstep.
• United Arab Emirates (UAE): We comply with the GoAML reporting requirements as stipulated by the UAE Ministry of Economy for dealers in precious materials and high-value crafts.
• Australia: We follow AUSTRAC guidelines regarding the identification of politically exposed persons (PEPs) and the reporting of significant cash-equivalent digital transactions.
• South East Asia (Singapore, Malaysia, Thailand, Vietnam): Yutiqaa operates a full DDP model across SEA to mitigate regional tax complexities.

• Singapore: We collect and remit GST for all imports; for orders exceeding the SGD 400 de minimis, we manage the formal customs entry. For high-value purchases in Singapore exceeding SGD 20,000, Yutiqaa adheres to the Precious Stones and Precious Metals (Prevention of Money Laundering and Protection against Terrorism Financing) Act (PSPM Act).
• Malaysia & Thailand: Local Sales and Service Tax (SST) or VAT is pre-calculated and included in the checkout total.
• Vietnam & Indonesia: Due to stringent luxury import regulations, Yutiqaa handles the specialized “Luxury Goods Tax” filings to ensure your masterpiece is delivered without local administrative holds.

• Rest of World (Global Tier 2): For regions not explicitly listed, Yutiqaa utilizes a Global DDP Matrix. We pre-calculate local consumption taxes and estimated duties based on the HSN/Tariff codes for “Handmade Silk/Cotton Textiles.” While local laws in smaller jurisdictions can be volatile, our brand promise remains: Yutiqaa acts as the intermediary to ensure all foreseeable landing costs are settled before the item reaches your country.

5. TRANSACTION MONITORING & SUSPICIOUS ACTIVITY

Yutiqaa’s compliance team monitors for patterns that signal financial risk, including:

• Structuring: Multiple smaller transactions designed to stay just below the ₹2,00,000 KYC threshold.
• Rapid Cancellation: Frequent high-value orders followed by immediate cancellation requests to “clean” funds through refunds.
• Reporting Obligations: Under PMLA and FATF standards, Yutiqaa is legally bound to report suspicious activity to the Financial Intelligence Unit – India (FIU-IND) or relevant global authorities. Per “Anti-Tipping Off” laws, the Patron will not be notified if a Suspicious Transaction Report (STR) is filed.

6. DATA PRIVACY, ENCRYPTION & RETENTION

• Security: KYC documents are stored in a siloed, AES-256 encrypted environment, separate from marketing and browsing data. Access is restricted to the Compliance Head and the DPO.
• Retention: In accordance with statutory requirements, Yutiqaa retains KYC and transaction records for a period of ten (10) years from the date of the transaction or the end of the business relationship.
• Cross-Reference: KYC data is strictly ring-fenced. Our marketing teams and customer support staff have zero visibility into your sensitive identification documents. Access is restricted solely to the Compliance Officer for verification purposes. All personal data handling, including your rights to access or delete information, is governed by our comprehensive Data Privacy Policy.

7. SANCTIONS SCREENING

Every high-value transaction is automatically screened against global sanctions lists, including:

• OFAC (US Treasury)
• UNSC (United Nations Security Council)
• EU/UK Consolidated Sanctions Lists
  Yutiqaa will not process any transaction involving individuals or entities appearing on these lists.

8. REFUSAL OF SERVICE

Yutiqaa reserves the right to decline any transaction or terminate a Patron relationship if:

1. KYC documentation is found to be forged, expired, or incomplete.
2. The transaction is flagged as a “High-Risk” financial activity by our Payment Gateway partners.
3. The Patron refuses to provide the mandatory PAN or Identity details for transactions exceeding the threshold.