PAUL MERCHANTS LIMITED ADII Partner and its Responsibilities

Head Office
Palm Court, Opposite New Passport Office,
Sector 18, Chandigarh – 160018, India

RBI Authorisation
Authorized Dealer Category-II Licence No.: CHE-ADII-0021-2023
Licence: As authorised by the Reserve Bank of India under the Foreign Exchange Management Act (FEMA), 1999.

1. Paul Merchants Limited & Its Responsibilities

Paul Merchants Limited ("PML") is an Authorized Dealer Category-II (AD Category-II) authorised by the Reserve Bank of India (RBI) under the Foreign Exchange Management Act, 1999 (FEMA) to undertake permitted foreign exchange transactions and outward remittances in accordance with the applicable FEMA provisions, RBI Master Directions, circulars, notifications, and guidelines issued from time to time.

PML collaborates with authorised Online Referral Partners, digital platforms, educational service providers, travel platforms, and other approved business partners to facilitate customer acquisition and provide digital access to outward remittance services.

While Online Referral Partners assist customers with onboarding, document collection, and transaction facilitation, PML remains solely responsible for all regulated activities relating to foreign exchange transactions, including regulatory compliance, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Know Your Customer (KYC) verification, Anti-Money Laundering (AML) compliance, sanctions screening, foreign exchange conversion, transaction approval, remittance execution, and statutory reporting under FEMA and RBI regulations.

Customers must transfer funds only to the designated bank account communicated by Paul Merchants Limited for the respective transaction. Under no circumstances should payments be made to the bank account of the Online Referral Partner or any third party unless expressly instructed by PML.

PML undertakes all regulatory and compliance checks before approving any outward remittance transaction and reserves the right to seek additional information or supporting documents wherever required under applicable laws, banking regulations, or internal compliance policies.

Processing timelines may vary depending upon banking hours, intermediary bank processing, compliance reviews, sanctions screening, overseas banking procedures, regulatory requirements, and other operational factors beyond the reasonable control of PML.

1.1 Responsibilities of Paul Merchants Limited

Paul Merchants Limited shall be responsible for:

• Reviewing all customer applications received through Online Referral Partners.
• Conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD), wherever applicable.
• Verifying customer identity, source of funds, purpose of remittance, and regulatory eligibility.
• Reviewing and approving KYC documents submitted through the Online Referral Partner.
• Requesting additional documentation or clarification whenever required.
• Performing Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), and sanctions screening.
• Approving or rejecting remittance requests in accordance with applicable regulations and internal compliance policies.
• Executing outward remittance transactions through authorised banking channels.
• Coordinating with AD Category-I banks, correspondent banks, and overseas banking partners.
• Ensuring compliance with FEMA, RBI regulations, and applicable reporting requirements.
• Issuing remittance confirmations, transaction advice, and SWIFT copies (where applicable).
• Maintaining statutory records as required under applicable laws.
• Resolving transaction-related grievances in accordance with its Customer Grievance Redressal Policy.

2. Responsibilities of PayFX as the Online Referral Partner

PayFX Fintech Solutions Private Limited ("PayFX") acts as an Online Referral Partner of Paul Merchants Limited for sourcing customers and facilitating outward remittance requests through its digital platform.

PayFX performs its responsibilities strictly in accordance with the operational procedures, compliance framework, Standard Operating Procedures (SOPs), policies, and instructions prescribed by Paul Merchants Limited.

PayFX shall be responsible for:

• Providing a secure online platform for customers to register and initiate outward remittance requests.
• Assisting customers in selecting the appropriate RBI purpose code applicable to the transaction.
• Collecting Know Your Customer (KYC) documents and supporting documents as prescribed by Paul Merchants Limited.
• Conducting preliminary checks to ensure submitted documents are complete, legible, and consistent with transaction requirements.
• Collecting additional documents or information whenever requested by Paul Merchants Limited.
• Securely transmitting customer applications, KYC records, and supporting documents to Paul Merchants Limited.
• Facilitating communication between customers and Paul Merchants Limited throughout the transaction lifecycle.
• Providing customers with transaction status updates received from Paul Merchants Limited.
• Assisting customers in responding to compliance or documentation queries.
• Providing customer support relating to registration, onboarding, documentation, payment guidance, transaction status, and operational enquiries.
• Receiving customer complaints and coordinating with Paul Merchants Limited where matters relate to transaction execution, regulatory compliance, or banking processes.

PayFX does not:

• Receive customer remittance funds.
• Hold, manage, or pool customer funds.
• Undertake foreign exchange conversion.
• Independently approve customer KYC.
• Perform AML/CFT or sanctions screening.
• Approve or reject remittance applications.
• Execute outward remittance transactions.
• Undertake any regulated activity reserved exclusively for RBI-authorised AD Category-I or AD Category-II entities.

3. Customer Payment Instructions

Customers are advised to:

• Transfer funds only to the bank account designated by Paul Merchants Limited for the respective transaction.
• Never transfer funds to PayFX or to any employee, representative, agent, consultant, or third party unless specifically authorised by Paul Merchants Limited.
• Verify payment instructions before initiating any transfer.
• Promptly provide any additional information or documentation requested during the compliance review process.

Failure to comply with these requirements may result in delays, cancellation, rejection, or refund of the transaction.

4. Customer Grievance Redressal Mechanism

Customers are encouraged to first contact PayFX for assistance regarding onboarding, documentation, payment guidance, or transaction status.

Where the matter relates to transaction execution, regulatory compliance, banking operations, or remittance processing, PayFX will coordinate with Paul Merchants Limited for timely resolution.

PayFX Global Customer Support

Email: care@payfxglobal.com

Paul Merchants Limited Customer Support

Customer Care: info@paulmerchants.net

5. Regulatory Disclosure

PayFX acts solely as an Online Referral Partner of Paul Merchants Limited.

The customer onboarding, collection of KYC documents, preliminary document review, transaction facilitation, and customer support activities undertaken by PayFX are performed strictly in accordance with the compliance framework, Standard Operating Procedures (SOPs), operational guidelines, and instructions prescribed by Paul Merchants Limited.

Final KYC verification, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Anti-Money Laundering (AML) compliance, Counter Financing of Terrorism (CFT) checks, sanctions screening, source of funds verification, approval or rejection of remittance requests, foreign exchange conversion, remittance execution, settlement, statutory reporting, and all regulated activities under FEMA and RBI regulations remain the sole responsibility of Paul Merchants Limited as an RBI-authorised Authorized Dealer Category-II.