PMLA (Anti Money Laundering) Policy

Introduction

This policy is framed and adopted as required by SEBI under the Prevention of Money Laundering Act, 2002 (“PMLA”). The policy provides a framework for anti-money laundering measures to be taken by Ravinder Sharma, SEBI Registered Research Analyst (Registration No. INH000024578).

Objective of the PMLA Policy

• Prevent use of services for money laundering or terrorist financing activities.
• Create awareness and clarity on KYC standards and AML measures.
• Ensure proper Client Due Diligence (CDD) before onboarding clients.
• Monitor and report suspicious transactions.
• Maintain records of cash transactions exceeding ₹10 lakhs.

Client Due Diligence (CDD)

• Maintain KYC records (valid identity and address proof).
• Verify genuineness of clients before advisory services.
• Maintain proper records of all client interactions.

Policy for Acceptance of Client

• No fictitious or anonymous accounts.
• No accounts opened if fee is offered in cash.
• No account where proper CDD/KYC cannot be completed.
• Ensure client identity does not match sanction lists or criminal background.
• Clients categorized as Low, Medium, or High Risk.

Clients of Special Category (CSC)

• Non-resident clients
• High net-worth individuals
• Trusts, NGOs, Charities
• Politically Exposed Persons (PEP)
• Clients in high-risk jurisdictions
• Non face-to-face clients
• Clients with doubtful public reputation

Suspicious Transactions

• Difficult identity verification
• Unclear source of funds
• Unusual business patterns
• High-risk jurisdictions
• Large overseas transfers

Any suspicious transaction will be reported to the Director, Financial Intelligence Unit-India (FIU-IND). Attempted or aborted transactions shall also be reported.

Monitoring of Transactions

• Monitor unusually large or complex transactions.
• Define internal threshold limits.
• Maintain written records of findings.
• Preserve records for five years.
• Monitor cash transactions above ₹10 lakhs.

Record Keeping

• Maintain records sufficient for audit trail.
• Preserve transaction records for five years.
• Provide records to authorities when required.

Reporting to FIU-IND

Director, Financial Intelligence Unit-India (FIU-IND)
6th Floor, Hotel Samrat, Chanakyapuri, New Delhi - 110021
Website: http://fiuindia.gov.in

Principal Officer & Designated Director

Name: Ravinder Sharma
Designation: Research Analyst
Email: trade.verse2407@gmail.com

Responsibilities of Principal Officer

• Access to customer identification data.
• Authority to report suspicious transactions.
• Ensure policy implementation.
• Ensure compliance with FIU reporting.
• Ensure prompt response to regulatory requests.

Responsibilities of Designated Director

• Ensure records are properly maintained.
• Ensure compliance with this policy.

Employee Training & Investor Education

• Adequate employee screening procedures.
• Ongoing AML & CFT training.

Review of Policy

This policy shall be reviewed periodically and updated as required under applicable laws, rules and regulations.