Introduction

Glomo Payments or Glomo is committed to providing seamless payment solutions while adhering to regulatory requirements. This Merchant Onboarding Policy outlines the criteria, procedures, and obligations necessary to onboard merchants. The policy ensures compliance with applicable laws and regulations, and out internal policy including Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Know Your Customer (KYC) or“AML-CFT and KYC Policy”, while promoting a secure and transparent environment for payment processing.

Applicability

This policy applies to all merchants wishing to avail payment services offered by Glomo. Additionally, it applies to certain third-parties such as the Customer of the Merchants engaging in cross-border transactions, ensuring that due diligence processes are followed.

Merchant Onboarding Process

1. Registration
   Merchants are required to provide essential information, including but not limited to:
   
   

   1. Business name and registration details.

   2. Permanent Account Number (PAN), Goods and Services Tax (GST) details.

   3. Ownership structure and information about Beneficial Owners (BOs).

   The aforementioned is an indicative list of documents. The requirements may differ based on the nature entity and jurisdiction of their registration/incorporation. The For more details, please refer to our AML-CFT and KYC Policy.

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3. Documentation Submission
   Merchants must submit all required documents for identity verification and business validation. The documents required may vary based on the legal status of the merchant (e.g., company, partnership, or sole proprietorship), but typically include:

   1. Certificate of Incorporation or registration documents.

   2. Memorandum and Articles of Association (for companies).

   3. Government-issued identity documents (PAN, GST registration).

   4. Proof of business and bank account information.

   The requirements may differ based on nature entity and jurisdiction of their registration/incorporation. The For more details, please refer to our AML-CFT and KYC Policy.

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5. Risk Assessment
   Glomo Payments employs a risk-based approach to assess the risk level of merchants. Merchants are categorized into low, medium, or high risk based on:

   1. The nature of the business.

   2. Geographic location.

   3. Transaction volume and patterns.

   For high-risk merchants (e.g., those in industries prone to money laundering or fraud), Enhanced Due Diligence (EDD) will be conducted.

Due Diligence Procedures

1. Customer Due Diligence (CDD)
   CDD is performed to verify the merchant’s identity, understand the nature of their business, and assess the legitimacy of their financial transactions. This includes verifying:
   
   

   1. The legal status of the business.

   2. The identity of Beneficial Owners (BOs) and Authorised Representatives.

   3. The legitimacy of the bank account used for settlements.

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3. Enhanced Due Diligence (EDD)
   For merchants categorized as high-risk, additional verification measures are implemented. This includes deeper scrutiny of financial documents, assessment of the source of funds, and approval from senior management before onboarding.

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Customer Due Diligence

For Customers - third parties involved in cross-border transactions—Glomo Payments conducts basic due diligence and name screening. This process ensures that payments made to or from such entities comply with regulations, safeguarding against fraudulent or illegal activities.

Ongoing Monitoring and Compliance

Glomo Payments conducts ongoing monitoring of merchant transactions to detect any unusual or suspicious activity. Merchants are subject to periodic re-verification of their KYC documents to ensure compliance over time. Depending on the risk category of the merchant, the following intervals apply:

1. High-risk merchants: Annual re-verification.

2. Medium-risk merchants: Re-verification every three years.

3. Low-risk merchants: Re-verification every five years.

Termination of Business Relationship

Glomo Payments reserves the right to suspend or terminate any merchant account if:

1. The merchant fails to comply with KYC/AML/CFT regulations.

2. Suspicious activities or transactions are identified.

3. The requisite due diligence procedures cannot be completed.

Data Privacy and Confidentiality

Glomo Payments adheres to strict data privacy standards. All merchant information and documentation collected during the onboarding process are treated as confidential. The data will only be shared with regulatory authorities or third parties as required by law.

Review and Updates

This policy is reviewed periodically to ensure that it remains compliant with regulatory changes and business practices. Any amendments to the policy will be communicated to the relevant stakeholders.

Contact Information

For any queries regarding this Merchant Onboarding Policy, please contact:

Glomo Payments Compliance Department

legal@glomopay.com