PayFX Global – Online Referral Partner Responsibilities

Our Role

PayFX Fintech Solutions Private Limited ("PayFX") acts as an Online Referral Partner of one or more Reserve Bank of India (RBI) authorised Authorized Dealer Category-I (AD-I) and/or Authorized Dealer Category-II (AD-II) entities for facilitating permissible outward remittance transactions under the Foreign Exchange Management Act, 1999 (FEMA) and the directions, master directions, and circulars issued by the Reserve Bank of India from time to time.

PayFX provides customers with a secure digital platform to initiate outward remittance requests, complete Know Your Customer (KYC) formalities, upload supporting documents, track transactions, and receive customer assistance throughout the remittance lifecycle.

All regulated foreign exchange activities are undertaken by the respective RBI-authorised AD Category-I or AD Category-II entity.

1. Customer Onboarding

PayFX serves as the primary point of contact for customers throughout the remittance journey.

Our responsibilities include:

• Providing a secure digital platform for customers to register and initiate outward remittance requests.
• Assisting customers in selecting the appropriate purpose of remittance in accordance with RBI guidelines.
• Guiding customers through the remittance process and applicable documentation requirements.
• Providing continuous assistance from transaction initiation until completion.

2. KYC Collection & Customer Due Diligence Support

PayFX undertakes customer onboarding and KYC document collection strictly in accordance with the policies, Standard Operating Procedures (SOPs), compliance framework, and operational instructions prescribed by the respective RBI-authorised AD Category-I or AD Category-II partner.

Our responsibilities include:

• Collecting customer identification and KYC documents.
• Collecting PAN, Passport, Address Proof and other mandatory documents as applicable.
• Collecting transaction-specific supporting documents based on the purpose of remittance.
• Performing preliminary checks to ensure documents are complete, valid, legible, and consistent with the transaction requirements.
• Obtaining additional information or supporting documents whenever required by the Authorised Dealer.
• Securely transmitting customer information and documents to the respective Authorised Dealer for regulatory review and processing.
• Assisting customers in responding to compliance or documentation queries raised during transaction processing.

The collection and preliminary review of documents by PayFX is undertaken solely to facilitate processing by the respective Authorised Dealer and does not constitute final KYC verification, regulatory approval, or transaction authorisation.

3. Transaction Facilitation

PayFX facilitates communication and coordination between customers and the respective Authorised Dealer throughout the transaction lifecycle.

This includes:

• Submission of customer applications and supporting documents.
• Coordination for additional documentation or clarification.
• Providing customers with regular transaction status updates.
• Facilitating communication between customers and the Authorised Dealer whenever required.

4. Customer Support

PayFX provides customer assistance relating to:

• Registration and account creation.
• KYC documentation.
• Documentation requirements.
• Purpose code guidance.
• Transaction status updates.
• Payment guidance.
• General remittance enquiries.
• Refund and cancellation requests, where applicable.
• Escalation of compliance-related queries to the respective Authorised Dealer.

5. Payment Guidance

PayFX ensures customers receive accurate payment instructions issued by the respective Authorised Dealer.

Customers must transfer funds only to the designated bank account communicated by the respective RBI-authorised AD Category-I or AD Category-II entity.

PayFX:

• Does not receive customer funds.
• Does not hold or pool customer money.
• Does not operate escrow accounts for outward remittance transactions.
• Does not undertake foreign exchange conversion.
• Does not execute outward remittance transactions.

6. Transaction Monitoring Support

PayFX supports the transaction process by:

• Coordinating additional documentation requests.
• Facilitating responses to compliance queries.
• Assisting customers during enhanced due diligence, where required.
• Sharing transaction confirmations, acknowledgements, and SWIFT copies (where applicable) received from the Authorised Dealer.

7. Customer Grievance Support

PayFX acts as the first point of contact for customer enquiries and service-related issues.

Where a complaint relates to remittance execution, regulatory compliance, sanctions screening, banking operations, or any matter requiring the intervention of the Authorised Dealer, PayFX will coordinate with the respective Authorised Dealer to facilitate timely resolution.

Regulatory Responsibilities of the Authorised Dealer

In accordance with the Foreign Exchange Management Act (FEMA) and the directions issued by the Reserve Bank of India, the following responsibilities are performed exclusively by the respective RBI-authorised AD Category-I or AD Category-II entity:

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD).
• Final KYC verification and approval.
• Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), and sanctions screening.
• Verification of source of funds and purpose of remittance.
• Approval or rejection of remittance requests.
• Foreign exchange conversion.
• Execution and settlement of outward remittance transactions.
• Coordination with AD Category-I banks, correspondent banks, and overseas banking partners.
• Issuance of remittance confirmations and regulatory reporting.
• Maintenance of statutory records in accordance with applicable laws and regulations.

Regulatory Disclosure

PayFX acts solely as an Online Referral Partner for RBI-authorised AD Category-I and AD Category-II entities.

The customer onboarding, KYC collection, preliminary document review, transaction facilitation, and customer support activities performed by PayFX are carried out strictly in accordance with the compliance policies, Standard Operating Procedures (SOPs), and operational instructions prescribed by the respective Authorised Dealer.

Final KYC approval, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), AML/CFT compliance, sanctions screening, foreign exchange conversion, remittance execution, settlement, and regulatory reporting remain the sole responsibility of the respective RBI-authorised AD Category-I or AD Category-II entity in accordance with FEMA and the applicable RBI regulations.