Customer Onboarding (Prepaid Program)
Last Updated On: 25th August 2025
1. Customer onboarding for EnKash
The purpose of EnKash’s customer onboarding guidelines is to outline the KYC procedures that help EnKash understand its customers and their financial activities more effectively, enabling better risk management at Nehat Tech Solutions Private Limited.
2. Objectives
The objective of the policy is to ensure that:
- Issuer
‘EnKash’ is defined as an issuer, issuing pre-paid payment instruments to individuals/organizations. The money collected is used by customers to make payments. - Customer
Individuals/Organizations who acquire pre-paid payment instruments for purchase of goods and services, including financial services and engaged in a financial transaction or activity with EnKash. - Merchant
A 'Merchant' is defined as the establishments who accept the PPIs issued by PPI issuer against the sale of goods and services. - Officially Valid Document (OVD)
Means the passport, the driving license, proof of possession of Aadhaar number, the Voter's Identity Card issued by the Election Commission of India, job card issued by NREGA duly signed by an officer of the State Government and letter issued by the National Population Register containing details of name and address. - Politically Exposed Persons (PEPs)
Means individuals who are or have been entrusted with prominent public functions in a foreign country e.g., Heads of States / Governments, senior politicians, senior government / judicial / military officers, senior executives of state-owned corporations, important political party officials, etc. - Equivalent e-document
Means an electronic equivalent of a document, issued by the issuing authority of such document with its valid digital signature including documents issued to the digital locker account of the customer as per rule 9 of the Information Technology (Preservation and Retention of Information by Intermediaries Providing Digital Locker Facilities) Rules, 2016. - Video based Customer Identification Process (V-CIP)
A method of customer identification with facial recognition and customer due diligence by an authorised official of the Company by undertaking seamless, secure, live, informed-consent based audio-visual interaction with the customer to obtain identification information required for customer due diligence purpose, and to ascertain the veracity of the information furnished by the customer through independent verification and maintaining audit trail of the process. - Pre-paid Payment Instruments
Pre-paid payment instruments are payment instruments that facilitate purchase of goods and services, including funds transfer, against the value stored on such instruments. The value stored on such instruments represents the value paid for by the holders by cash, by debit to a bank account, or by credit card. The pre-paid instruments can be issued as smart cards, magnetic stripe cards, internet accounts, internet wallets, mobile accounts, mobile wallets, paper vouchers and any such instrument which can be used to access the pre-paid amount (collectively called Prepaid Payment Instruments hereafter). The pre-paid payment instruments that can be issued in the country are classified under three categories viz. (i) Closed system payment instruments (ii) Semi-closed system payment instruments and (iii) Open system payment instruments. - Closed System Payment Instruments
These are payment instruments issued by a person for facilitating the purchase of goods and services from him/it. These instruments do not permit cash withdrawal or redemption. As these instruments do not facilitate payments and settlement for third party services, issue and operation of such instruments are not classified as payment systems. - Semi-Closed System Payment Instruments
These are payment instruments which can be used for purchase of goods and services, including financial services at a group of clearly identified merchant locations/ establishments which have a specific contract with the issuer to accept the payment instruments. These instruments do not permit cash withdrawal or redemption by the holder. - Open System Payment Instruments
These are payment instruments which can be used for purchase of goods and services, including financial services like funds transfer at any card accepting merchant locations (point of sale terminals) and also permit cash withdrawal at ATMs / BCs. - Limits
All ‘limits’ in the value of instruments stated in the guidelines, indicate the maximum value of such instruments that can be issued to any holder.
3. KEY ELEMENTS OF KYC POLICY:
The KYC Policy includes the following four key elements:
- Customer Acceptance Policy
- Customer Identification Procedures
- Customer Due Diligence Process
- Monitoring of Transactions
- Risk Management (Risk Categorization)
- Periodic KYC review
- Maintenance of records
- Employee Hiring and Training
- Review of Policy
- Customer Acceptance Policy (CAP)
Customers availing services from EnKash are required to enter into a contract with EnKash as part of the onboarding process. These agreements are digitally signed, and the Terms and Conditions are accepted by the customer during this process.
- Customer Identification Procedures (CIP)
Customer identification means undertaking Client Due Diligence (CDD) measures while commencing an account-based relationship including identifying and verifying the customer...
- Customer Due Diligence Process
- Customer Registration:Obtaining the requisite organization/individual details as listed in Annexure I...
- Verification and scrutinization of the information received and documents by the onboarding team...
- Undertaking of various checks such as background, negative business list, PEP, UN sanctions list, etc.
- Customer Exit/Termination
- Termination requested by the customer:In case the customer wishes to culminate his contract...
- EnKash chooses to terminate:Customer has indulged in fraudulent or illegal activity...
- Monitoring of Transactions
A registered customer will be continuously monitored and supervised by EnKash in order to prevent any unlawful or malicious activity...
- Periodic KYC Review
EnKash shall put in place a system of periodical review of risk categorization of accounts and enhanced due diligence...
- Maintenance of Records
PML Act and Rules cast certain obligations... EnKash shall maintain proper record of transactions prescribed under Rule 3...
- Series of all transactions integrally connected to each other...
- All suspicious transactions whether or not made in cash...
- Deposits and credits...
- Credits or debits into or from non-monetary accounts...
- Money transfer or remittances...
- Loans and advances including credit or loan substitutes...
- All cross border wire transfers of value...
- Employee Hiring and Training
EnKash has adequate screening procedures in place to ensure high standards when hiring employees...
- Review of Policy
The Customer Onboarding policy would be reviewed as and when required by the statute...
4. Annexure I
General Information for registration
- Personal details: Name, email id, phone number;
- Business details: Business Identifier having details of Legal business name, registered address, business address, website address, constitution, etc.;
- Banking details: Bank Name and address, Type of account and account no. etc.
- Tech related information;
- Financial information;
- Declarations; if any.
5 Annexure II
List of Restricted businesses:
- Adult Goods & Services - Pornography, other sexually suggestive materials; Escort/Prostitution services. Personal Massagers/sex toys.
- Alcohol or Alcoholic beverages.
- Body Parts, including organs - Live, cultured, preserved or from cadaver. This Prohibited Products And Activities List Is Not Exhaustive And Finite And Enkash May At Any Time Include Other Products Into This List Or Change The List Without Your Consent.
- Bulk marketing tools - email lists, software or other products enabling unsolicited emails/sms.
- Cable TV descramblers & black boxes intended to obtain cable & satellite signals for free.
- Child Pornography in any form.
- Copyright unlocking devices - Mod chips or other products designed to circumvent copyright protection.
- Copyrighted Media - unauthorized copies of books, music, movies and other licensed or protected materials.
- Copyrighted Software which includes unauthorized copies of software, videogames and other licensed or protected materials including OEM or bundled software.
- Counterfeit and unauthorized goods - replica or imitation of designer goods; fake autographs; counterfeit stamps.
- Drugs & Drug paraphernalia which includes illegal drugs and drug accessories including herbal drugs.
- Drug test circumvention aids, includes drug cleansing shakes, urine test additives and related items.
- Endangered species - includes plants, animals or other organisms.
- Gambling/Betting - lottery tickets, sports bets, enrolments in online gambling sites.
- Government ID or documents which includes fake IDs, passports.
- Hacking & Cracking materials which includes manual, how-to-guides, equipment enabling illegal access to software servers or protected property.
- Illegal goods and goods/services promoting/enabling illegal acts.
- Miracle cures, which are marketed as quick health fixes.
- Offensive goods, which includes literature, products and other materials that defame or slander any person or group of person, encourage violent acts, promote intolerance or hatred.
- Offensive goods, crime which includes crime scene photos or items, such as personal belongings associated with criminals.
- Prescription drugs or herbal drugs of any kind of online pharmacies which includes drugs / other products requiring a prescription by a recognised & licensed medical practitioner in India or anywhere else.
- Pyrothenic devices & hazardous materials which includes firework & other toxic/radioactive goods.
- Regulated goods, regulated by government agency.
- Securities, which includes stocks, bonds, mutual funds or related financial products or investments.
- Tobacco & cigarettes, chewing tobacco and related products.
- Traffic devices which includes radar detectors / jammers, license plate cover, traffic signal changers and related products.
- Weapons which include knives, brass knuckles, gun parts and other armaments.
- Wholesale currency which includes discounted currencies or currency.
- Live animals or animal parts / products.
- Multi-level Marketing schemes / Pyramid / matrix scheme sites.
- Any intangible goods and services or aggregation business.
- Drop-Shipped Merchant.
- Web based telephony/e-mail/sms/fax/calling cards/bandwidth/data transfer or allied services.
- Crypto or Crypto based services.
- Any act/services/product/people/entity/place/country defined illegal or sanctioned or in negative list by RBI or other regulators.
- DMT
- Money Transfer Services / Card To Cash
- Any other service product activity described as illegal as per RBI or other regulators.
- Violation of any of the Enkash terms of use.
- WMD (Weapon of mass destruction)
- Drop Shipping
- Illegal arms trading
- Smuggling
- Child abuse
- Human trafficking
- Pornography
- Hawala
- Organs trading
- Extortion
- Illegal trading of animals
- Illegal drugs supply and handling
- Mystery Boxes / Get Risk Schemes / Betting
- Gaming LOB where company type is Individual or Sole proprietor.
***** END OF POLICY *****
