Anti-Money Laundering Policy

Surgery Care Foundation is committed to ensuring that donations received through the Site are not used to launder money, finance terrorism, or fund any other illegal activity. This Anti-Money Laundering (AML) Policy sets out the standards we follow in line with the Prevention of Money Laundering Act, 2002 (PMLA), the Unlawful Activities (Prevention) Act, 1967, the Foreign Contribution (Regulation) Act, 2010 (FCRA, where applicable), and the Reserve Bank of India’s KYC/AML directions applicable to payment aggregators.

This policy applies to every donation received through the Site, every donor, every campaigner, and every employee, volunteer or contractor of the Foundation who handles donor or patient information.

• All digital donations are processed through Razorpay, which performs KYC of the underlying payment instrument under RBI directions.
• For donations of Rs. 50,000 or more in a single transaction, the gateway may require additional KYC (PAN, address proof) before completing the transaction.
• We collect PAN at donation time when the donor wishes to claim 80G tax benefit; PAN is verified against the IT Department's portal where required.
• Cash donations are not accepted through the Site, in any amount.

• Patient identity is verified using a government-issued photo ID (Aadhaar, PAN, voter ID or passport).
• Hospital identity, accreditation status and bank account details (for disbursement) are independently verified before any disbursement.
• Medical documents (diagnosis report, hospital cost estimate, prescription) are reviewed by our team and, where needed, confirmed directly with the hospital.
• Repeat campaigns or unusually large estimates are escalated for senior review before listing.

Our team and our payment gateway monitor donation patterns for indicators of potential abuse, including:

• A single donor making structured donations just below KYC thresholds.
• Donations from sanctioned individuals or entities, or from politically exposed persons (PEPs) without supporting context.
• Donor and campaigner banking details that match in suspicious ways.
• Sudden, unexplained spikes in donation volume from a single source.
• Requests to refund a recent donation to a different account from the one that originated the donation.

Where we have reasonable grounds to suspect money laundering or terrorism financing, we will, in coordination with our payment gateway and after legal advice where required, file a Suspicious Transaction Report (STR) with the Financial Intelligence Unit – India (FIU-IND) under the PMLA framework. The Foundation will also cooperate with any lawful enquiry from Indian regulators, the Income Tax Department, the Enforcement Directorate or other competent authorities.

Donor names flagged by the payment gateway against Indian sanctions lists, the United Nations Security Council Consolidated Sanctions List, or politically-exposed-person (PEP) databases are escalated for review. Where required, the donation will be held, returned to source, or reported as set out in Section 6.

In line with Section 12 of the PMLA, records relating to donations, KYC, campaigner due diligence, disbursement to hospitals and any STR filings are retained for a minimum of five (5) years from the date of the transaction or the date of completion of the relevant client relationship, whichever is later. Records are stored in restricted-access systems with appropriate audit logging.

The Foundation accepts foreign-source donations only if and when it holds a valid FCRA registration. Until then, any foreign contribution received in error is returned to the source. Where the Foundation is FCRA-registered in the future, foreign contributions will be received only into the designated FCRA bank account at the State Bank of India, New Delhi Main Branch, in line with the FCRA, 2010.

All employees and volunteers handling donor information receive periodic training on this policy. The compliance owner for AML matters is the Foundation’s designated Compliance Officer, reachable at info@surgerycarefoundation.com.

If you have reason to believe that a donor or campaigner is misusing the Site, you may report your concern confidentially to the Compliance Officer at the address above. Reports made in good faith are protected and will be acted on promptly.