Anti-Money Laundering Policy

AML / CFT Compliance Framework

1. Introduction & Legal Basis

DropMandi is committed to preventing its platform from being used for money laundering, terrorist financing, or any other financial crime. This Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) Policy establishes our framework for detecting, preventing, and reporting suspicious activities.

1.1 Legal Framework

1.2 Scope

This policy applies to all users of the DropMandi platform including buyers, sellers, dropshippers and any person accessing our services. It also applies to all DropMandi employees, contractors and agents.

2. Definitions

3. Customer Due Diligence (KYC)

3.1 Identity Verification

DropMandi collects and verifies the following information for all sellers and dropshippers:

3.2 Enhanced Due Diligence

DropMandi applies enhanced due diligence for:

• High-volume sellers (monthly transactions above Rs 500,000)
• Sellers dealing in high-risk product categories
• Accounts with unusual transaction patterns
• Politically Exposed Persons (PEPs) or their associates
• Users from high-risk jurisdictions (if international operations added)

3.3 Ongoing Monitoring

• All transactions are logged with timestamps and IP addresses
• Automated alerts for unusual transaction volumes
• Periodic re-verification of high-risk accounts
• KYC documents reviewed annually or on significant account changes

4. Suspicious Transaction Indicators

The following activities may indicate money laundering or financial crime:

4.1 Transaction Red Flags

• Sudden unexplained spike in transaction volume
• Multiple transactions just below reporting thresholds
• Payments from unusual or inconsistent sources
• Requests to split payments across multiple accounts
• Transactions inconsistent with seller's stated business type
• Buyer pays large amounts and immediately requests refund to different account
• Same product ordered and returned repeatedly without clear reason

4.2 Account Red Flags

• Multiple accounts with same CNIC
• Account registered with false identity documents
• User refuses to provide KYC documentation
• Inconsistency between stated business and actual transactions
• Requests to process transactions outside platform (off-platform payments)
• Use of multiple bank accounts without clear business reason

4.3 Product/Listing Red Flags

• Listings for non-existent or undeliverable products
• Significantly overpriced or underpriced products
• Products that appear to be used for value transfer
• Counterfeit or fake branded goods
• Products on prohibited items list

5. Reporting Obligations

5.1 Internal Reporting

• Any suspicious activity must be reported to DropMandi compliance team immediately
• Report via email: customercare@dropmandi.com with subject "COMPLIANCE: Suspicious Activity"
• Do NOT alert the suspected user that a report has been filed
• Preserve all relevant transaction records and communications

5.2 FMU Reporting (STR)

DropMandi will file a Suspicious Transaction Report (STR) with the Financial Monitoring Unit (FMU) when:

• There are reasonable grounds to suspect money laundering or terrorist financing
• A transaction involves proceeds of any criminal activity
• Required by any law enforcement or regulatory authority

5.3 Law Enforcement Cooperation

DropMandi will fully cooperate with:

• FIA (Federal Investigation Agency) investigations
• NAB investigations related to our platform
• FBR audits and inquiries
• Court orders for data disclosure
• SBP inspections related to payment activities

6. Record Keeping

DropMandi maintains the following records in compliance with AML Act 2010:

7. Prohibited Activities

The following are strictly prohibited on DropMandi platform:

• Using DropMandi to launder proceeds of any criminal activity
• Structuring transactions to avoid detection or reporting thresholds
• Providing false identity information or fake KYC documents
• Facilitating payments for terrorist organizations or individuals
• Processing payments for prohibited goods or services
• Using DropMandi for Hawala or informal money transfer
• Using DropMandi to evade taxes or customs duties
• Creating fictitious transactions to generate false payment records
• Operating multiple accounts to circumvent transaction limits
• Bribery or corruption involving DropMandi staff or agents

8. Platform Controls

8.1 Technical Controls

• All transactions logged with timestamp, IP address and device information
• Automated alerts for unusual transaction patterns
• CNIC uniqueness check prevents duplicate identity registration
• KYC verification required before payouts are enabled
• Bank account verification required for seller payouts
• Transaction limits for new accounts (graduated trust system)
• Encrypted storage of all sensitive user data

8.2 Operational Controls

• Manual review of high-value or unusual transactions
• KYC document review by trained staff
• Periodic audit of seller transaction patterns
• Regular review of banned/suspended accounts
• Separation of duties between operations and compliance

8.3 Payout Controls

• Payouts only to verified bank accounts in seller's name
• No payout to third-party accounts
• Payout withheld during active investigations
• Minimum payout threshold: Rs 500
• Large payouts subject to additional verification

9. Training & Awareness

• All DropMandi staff receive AML/CFT training on joining
• Annual refresher training on AML regulations and red flags
• Staff briefed on new AML typologies and regulatory changes
• Clear escalation procedures for suspicious activity reports
• Staff aware of legal protections for reporting in good faith

10. Enforcement

10.1 Consequences for Users

10.2 Policy Review

This AML policy is reviewed annually or whenever significant regulatory changes occur. The latest version is always available at dropmandi.com/aml_policy.php

11. Report Suspicious Activity

If you suspect any user of money laundering, fraud or financial crime on DropMandi, please report immediately:

AML Compliance Contact

For AML/compliance queries contact our team

DropMandi AML Policy v1.0 | Effective May 25, 2026 | Reviewed Annually