Foreign Exchange Management Act, 1999 (FEMA): This Act aims to consolidate and amend the law relating to foreign exchange to facilitate external trade and payments and promote the orderly development of the foreign exchange market in India. Compliance with FEMA and RBI directions is mandatory.  

Anti-Money Laundering (AML) Act & Sanctions Regimes: Compliance with AML laws and sanctions regimes, including export controls, is mandatory. This requires scrutiny of users and transactions originating from or destined to certain jurisdictions or entities.  

Nature of Coins: The Coins are internal, pre-paid, and non-refundable digital credits/units of account that entitle Users to access specified internal Platform features and are purchased exclusively to access them. These features include verification fees and communication fees (verification, chat initiation, call initiation, per-project interactions, and profile features). Coins do not constitute currency, securities, stored-value instruments regulated as deposit liabilities, or electronic money beyond their utility on the Platform.  

Value: The Coin system represents a pre-funded value, pegged internally to a base currency (e.g., INR equivalent) for ease of global pricing and management.  

Coin Issuance and Purchase Mechanics: Users purchase Coins through the authorised payment gateway, i.e Razorpay. The Platform will list the purchase price, currency options, and applicable taxes/fees at the time of purchase. Purchase confirmation, transaction identifiers, and coin crediting events are logged and made available on a user’s account statement. Coins are not transferable off-Platform except where the Platform provides a specific contractual mechanism (e.g., partner integrations) and then only subject to prior written approval and compliance checks.  

Non-Refundable Access Fees & FX Risk Allocation: Coins bought on Quickenlancer (the Platform) are explicitly non-refundable except as required by applicable law (e.g., consumer protection or payment regulations). Users acknowledge and accept that:  

Parties to Coin Transaction: The transaction is between the User (Service Provider or Project Admin) and Quickenlancer (Quickensol IT Solutions LLP).  

Payment Processing: Third-Party Payment Gateways/Processors/Banks determine and apply the executed exchange rate, payments, and correspondent charges during payment processing.  

Payment Channel Policy: All Platform Fee receipts shall be received only via payment gateways and banks that are authorised persons under Indian law or operate through or with an authorised person. The Platform shall maintain a register of approved payment service providers and their respective compliance credentials.  

Due Diligence on Payment Processors: Before onboarding any payment processor or aggregator (collectively “Payment Partners”), the Compliance team will perform documented due diligence covering licensing, AML controls, sanctions screening, transaction monitoring capability, dispute handling procedures, data hosting, and audit trail capabilities.  

Razorpay and Other Gateways: Where the Platform uses named gateways (e.g., Razorpay), it shall ensure written representations from such providers that the provider operates in compliance with applicable foreign exchange rules, and that all FX settlements are executed via authorised persons where necessary.  

Inward Remittance: When an International User purchases Coins using foreign currency, this constitutes an inward remittance of foreign exchange to Quickenlancer (an Indian entity). All such foreign exchange must be received through an authorised person, RazorPay, or its affiliated financial institution, which acts as an intermediary (potentially an Authorised Person or through one) for receiving payments.  

Accounting Treatment: Platform Fees (coins sold) shall be recorded as revenue or deferred revenue per applicable accounting standards. The Platform will maintain a coin ledger recording issue, consumption, expiry (if any), and reconciliation statuses. The platform will maintain dual reporting lines: financial accounting and FX reporting to reconcile foreign remittances and receipts.  

Fees, Taxes, and Withholdings: All prices are exclusive of taxes unless displayed otherwise. The Platform may withhold taxes at source where legally required and will communicate gross and net amounts to Users and tax authorities as required.  

Exchange Rate Fluctuation: The applicable exchange rate may adjust regularly based on market conditions, as determined by the payment processor or correspondent bank.  

Conversion Fees: Users may incur conversion charges or fees imposed by the third-party payment provider or financial institution, which may differ from wholesale rates. Quickenlancer is not responsible for currency fluctuations that occur when billing or crediting a Payment Method denominated in a currency other than the base currency (e.g., U.S. Dollars).  

Rate Disclaimer: Quickenlancer does not set the FX rate and bears no responsibility for the specific conversion rate applied by RazorPay or other Payment Services Providers.  

No FX Rate Refunds: In alignment with the client mandate, Quickenlancer will provide no FX Rate Refunds. Once the funds are successfully received and the Coins are credited, the transaction is final.  

Risk of Loss: The User's authorisation of a payment using a foreign currency conversion rate displayed by the payment processor is at the User’s sole risk.  

Chargeback Waiver: Users must waive chargeback rights relating to the purchase of Coins/Fees, as initiation of a chargeback may be considered a material breach and lead to account suspension.  

Independent Contracting: All Project Payments between Users are independent contracts between parties. The Platform acts only as an introduction platform between the parties.  

No Platform Intermediation: By default, the Platform does not hold, process or negotiate Project Payments. Parties are responsible for selecting their payment channels, bearing all bank charges, foreign exchange conversions, correspondent bank fees, and any tax or withholding obligations in their jurisdictions.  

No Platform Liability: The Platform disclaims responsibility for the timing, exchange rates, reconversion, chargebacks, billing errors or disputes arising from Project Payments. Where parties transact off-platform, the Platform is not responsible for the enforcement of contracts, quality of deliverables, or collection of payments.  

Off-Platform Risks and Due Diligence: The Platform will provide guidance and best-practice checklists to encourage due diligence (verify identity, use written contracts, confirm bank details, prefer traceable payment methods), but such guidance is advisory only.  

Declaration and Representations by Users: Payment Partners must require Users to make statutory declarations where required by law, and the Platform will cooperate to ensure such declarations (e.g., export of services declarations) are procured and maintained.  

Rejection and Reporting by Authorised Persons: Payment Partners and authorised persons are required to reject suspicious transactions and report as necessitated by law. The Platform will require prompt notice of such rejections and the reasons for the same, and it will cooperate with any investigation.  

Bank Accounts and Nostro/Vostro Arrangements: The Platform shall maintain bank accounts with authorised banking partners for remittance collection and repatriation. Nostro/vostro arrangements will be managed by the CFO with documentation of beneficiary accounts, cut-off times, and reconciliation practices.  

Repatriation Mandate: Where any amount of foreign exchange is due or has accrued to Quickensol IT Solutions LLP (from Coin purchases or feature fees), the Platform shall take all reasonable steps to realise and repatriate to India such foreign exchange within such period and in such manner as may be specified by the Reserve Bank of India (RBI). Repatriating means bringing into India the realised foreign exchange and selling it to an authorised person in India in exchange for rupees, or holding the realised amount in an account with an authorised person in India to the extent notified by the Reserve Bank.  

Authorised Person Requirement: Quickenlancer must ensure that all foreign exchange dealings (receipt of payment for Coins) are handled through an authorised person. The Reserve Bank has the power to issue directions and inspect Authorised Persons.  

Nature of Transactions (Inflow): Coin purchases represent payment for services (access, chat, verification). Provision of services from India to any person outside India constitutes an export of services. Payments due in connection with foreign trade and services are classified as current account transactions as per FEMA.  

Realisation & Repatriation Process: The Platform shall realise and repatriate foreign exchange amounts in accordance with RBI timelines and via authorised persons. Realisation step includes actual receipt of foreign currency or its credit to authorised bank accounts and the sale/credit to rupee accounts where applicable.  

Documentation for Realisation: For each cross-border receipt, the Platform shall retain export documentation, including invoices, declarations, payment receipts, remittance advices, and any proof required by authorised persons and RBI.  

Timing & Accounting Entries: The Platform shall credit revenue in its books in the period of realisation consistent with applicable accounting standards, maintaining a clear audit trail linking the coin sale to banking remittances.  

Repatriation Exceptions: Where foreign currency receipts are retained in permitted foreign currency accounts (e.g., EEFC / foreign currency accounts as permitted under RBI schemes), the Platform shall maintain separate ledgers and shall comply with all restrictions and disclosures.  

Reporting: Quickenlancer shall furnish declarations and particulars relating to payment for such services to the RBI or specified authorities.  

Foreign Currency Balances and Hedging: The Platform may maintain limited foreign currency balances subject to authorisation. Any hedging or forward contracts will be undertaken only through authorised persons and following Board approval.  

Due Diligence: Verification processes, including Aadhaar/PAN verification via Surepass API for domestic users and mandatory video verification for international users, serve as a crucial component of Know Your Customer (KYC) and AML compliance.  

KYC Levels & Risk Profiling: Standard KYC (low-risk): name, email, verified phone, basic identity checks. Enhanced KYC (medium-risk): official government ID (PAN/Aadhaar for India), proof of address, and video verification. Enhanced Due Diligence (EDD) (high-risk): mandatory for politically exposed persons (PEPs), high volume accounts, or transactions with sanctions exposure — includes source of funds/wealth documentation, corporate ownership structure, and senior management identification.  

Domestic KYC (India): Indian individual Users: Aadhaar or PAN verification via Surepass or equivalent. The Platform does not store Aadhaar/PAN raw data; only secure verification tokens/IDs and audit trails are retained in accordance with the retention policy. Indian corporate Users: GST, incorporation documents, director/authorised signatory verification.  

International KYC: Non-Indian Individuals: Certified passport/government ID, proof of residence, and mandatory video verification at onboarding. Non-Indian Corporations: certificate of incorporation, list of directors, ultimate beneficial owner (UBO) declarations, and mandatory verification of an authorised representative (video + ID).  

Video KYC Protocol: Metadata such as timestamp, location/IP and verification outcomes are logged. Retention ranges from 30–90 days for routine verifications, and longer where required by law for ongoing investigations. Please refer to our Data Privacy Policy for the same. 

Sanctions Screening: All Users are screened at onboarding and periodically thereafter against applicable Sanctions Lists. Any hit will trigger an immediate EDD review, transaction blocking, and escalation to the Compliance Officer with possible suspension pending resolution.  

UBO and Corporate Transparency: For entities, the Platform requires identification of UBO(s) and will perform verification consistent with the risk profile. The Platform may refuse to onboard or continue a relationship where beneficial ownership is opaque.  

Data Protection and Consent: Users must consent to KYC for data processing. Where additional jurisdictional consents are required (e.g., EU), the Platform will present those onboarding.  

Prohibited Jurisdictions/Persons: Users are prohibited from using the platform to bypass economic sanctions or trade restrictions imposed by the United States, European Union, or any other applicable jurisdiction. Users affirm they are not residents of, nationals of, or entities located in any country subject to U.S. OFAC regulations or other applicable laws.  

Financial Monitoring: Quickenlancer reserves the right to suspend a withdrawal request or activity if the source of funds (for Coin purchase) is suspected to be fraudulent. The platform reserves the right to take action to prevent or stop activity considered illegal, fraudulent, unethical, or legally actionable. The Platform reserves the right to refuse service, suspend accounts, or restrict transactions where KYC is incomplete, or where a reasonable suspicion of money laundering or sanctions breach exists.  

Transaction Monitoring System: The Platform will implement automated and manual monitoring to flag unusual transaction patterns, rapid coin purchases with unusual IP/geographic origins, rapid coin redemptions, multiple failed payment attempts, or unusual project payment instructions that suggest layering or evasion.  

Thresholds and Triggers: The Compliance Officer will maintain an internal rulebook with monetary and behavioural thresholds (daily/weekly purchase volumes, geolocation anomalies, high-risk country flags) to trigger alerts and investigations.  

 Investigation and STR Filing: Where a transaction is suspicious under applicable laws, the Platform shall file a Suspicious Transaction Report (STR) with the appropriate Indian enforcement authority within prescribed timelines and shall preserve the relevant records pending inquiry.  

 Freezing and Blocking: In case of confirmed suspicion or where required by statutory freeze orders or sanctions, the Platform shall block transactions, freeze coins, and cooperate with law enforcement and authorised persons.  

Collaboration with Payment Processors: Payment Partners shall be contractually obliged to provide transaction logs, trace information, and cooperate with investigations. The Platform shall ensure timely access to these records.  

Employee Reporting: Employees must report suspicious activity immediately to the Compliance Officer. The Platform prohibits retaliation against good-faith whistleblowers.  

No Liability for Project Funds: Payments for services rendered (Service Provider Fees) are negotiated and executed solely between the Service Provider and the Project Admin, at their discretion. Quickenlancer takes no commission on these amounts and bears no liability for non-payment, disputes, or FX fluctuations related to these third-party transactions.  

User Responsibility: Service Providers and Project Admins are solely responsible for compliance with their respective domestic and international FX, tax (including TDS/TCS for Indian users), and AML obligations related to the transfer of funds for project work. They must conduct their own due diligence before engaging.  

Offsetting Penalty: Users engaging in communications and transactions outside the platform in violation of terms (circumvention) may incur severe penalties, reflecting the economic interest in retaining internal transactions (e.g., penalties seen in other marketplace models).