Anti-Money Laundering (AML) & Combating Financing of Terrorism (CFT) Policy

This policy has been formed in light of SEBI Circulars on Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) as amended — obligations of intermediaries under the Prevention of Money Laundering Act, 2002 (“the Act”) and rules framed thereunder, after making necessary amendments in the existing Anti-Money Laundering Policy of the Company.

The Company is committed to prohibit and actively prevent money laundering and any activity that facilitates money laundering or terrorist financing. Money laundering is understood as any act designed to conceal or disguise the true origin of criminally derived proceeds so that they appear to be legitimate.

1. Initiatives by the Company

The objective of this AML Policy is to establish a robust system to ensure compliance with SEBI guidelines and applicable laws, and to ensure that the Company is not used as a vehicle for money laundering.

Objectives of the AML Policy

• To establish appropriate AML procedures and internal controls.
• To detect and report suspicious activities in accordance with applicable laws.
• To comply with all regulatory requirements.
• To ensure adequate employee training on AML / KYC procedures.
• To assist law enforcement agencies in investigation and tracking of money laundering activities.

4. Principal Officer

The Company has designated the Company Secretary as the Principal Officer responsible for AML compliance. The Principal Officer acts as the central reference point for reporting suspicious transactions and liaison with FIU-IND.

5. Customer Due Diligence (CDD)

The Company follows strict KYC norms while establishing client relationships. Identity, address, nature of business, and financial status of the client are verified before account opening.

• No fictitious or anonymous accounts shall be opened.
• Clients are classified as low, medium, or high risk.
• Accounts are opened only after verification of original documents.
• PAN verification is mandatory.
• Cash transactions are not permitted.

Clients of Special Category (CSC)

• Non-resident clients
• High net-worth individuals
• Trusts, NGOs, charities
• Politically Exposed Persons (PEPs)
• Clients from high-risk jurisdictions

6. Maintenance of Records

The Company maintains records of all cash and suspicious transactions as required under PMLA, including nature, amount, date, and parties involved. Records are sufficient to reconstruct individual transactions when required by authorities.

7. Retention of Records

Client identity and transaction records are preserved for a minimum period of ten years from the date of cessation of transactions or closure of account, or longer if required by law.

Red Flags

• Difficulty in client identity verification
• Unclear source of funds
• Unusual transaction patterns
• Large or unexplained transfers
• Transactions involving shell entities

9. Reporting to FIU-IND

The Principal Officer shall report Cash Transaction Reports (CTR) and Suspicious Transaction Reports (STR) to FIU-IND as prescribed under PMLA rules.

10. Internal Audit

Internal Audit ensures periodic review of AML compliance systems, detection mechanisms, and staff awareness.

11. Employee Training & Investor Education

The Company conducts continuous AML training programs for employees and educates investors on AML/CFT requirements.

12. Monitoring Employee Conduct

Employee accounts are subject to AML procedures under supervision of the Principal Officer.

13. Confidential Reporting

Employees may confidentially report AML violations without fear of retaliation.

14. Review of Policy

This policy is reviewed periodically and updated as per regulatory amendments.

15. Communication

The policy is communicated to all employees, management, directors, and relevant stakeholders.