Legal & Support Info

Anti-Money Laundering Policy

SEBI-REGISTERED RESEARCH ANALYST

1. Introduction and Objective

This Policy establishes the framework for preventing and detecting money laundering (ML), terrorist financing (TF) and related illicit activities. It sets out the client acceptance, identification, due diligence, risk assessment, monitoring, reporting, record-keeping, employee awareness and escalation procedures applicable to the Research Analyst.

The Policy is designed with regard to the nature of Research Analyst services. The Research Analyst provides research and recommendation services and does not execute securities transactions on behalf of clients or operate clients' trading/demat accounts as part of such services, unless its authorised business activities expressly provide otherwise.

2. Regulatory Framework

Prevention of Money Laundering Act, 2002 (PMLA), as amended from time to time.
Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 (PML Rules), as amended from time to time.
SEBI Master Circular SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78 dated June 06, 2024 relating to AML standards, CFT and obligations of securities market intermediaries.
Applicable SEBI regulations, circulars, directions and KYC requirements.
Applicable requirements under the Unlawful Activities (Prevention) Act, 1967, the WMD Act, Government/SEBI designated lists and FIU-IND directions.
Any subsequent amendments, circulars or directions applicable to the Research Analyst.

3. Applicability to the Research Analyst Business

The Research Analyst's AML/CFT controls shall be proportionate to its actual activities, client profile, payment flows and identified ML/TF risks. The following business-model considerations apply:

The Research Analyst does not execute trades for clients.
The Research Analyst does not maintain or operate clients' trading or demat accounts as part of its Research Analyst services.
The Research Analyst does not receive, hold or transfer client securities.
The principal financial interaction with clients is generally the receipt of fees for research services through permitted banking/electronic channels.
Where securities-account execution or transaction information is not handled by the Research Analyst, the Research Analyst does not independently monitor such execution activity.
Nothing in this section limits any CDD, reporting or other obligation that becomes applicable if the nature of the Research Analyst's activities changes.

4. Policy for Acceptance of Clients

The following safeguards shall be followed while accepting clients:

No client shall be accepted under a fictitious, benami or anonymous identity.
The Research Analyst shall obtain sufficient information to establish the identity of the client and complete applicable KYC/CDD checks.
The Research Analyst shall not commence services where mandatory identification information cannot be satisfactorily obtained or verified.
The Research Analyst shall assess whether the client is acting for itself or on behalf of another person/entity and obtain appropriate information where required.
Applicable screening shall be conducted against SEBI/Government/UN sanctions and designated lists and potential matches shall be escalated.
A risk assessment shall be undertaken before or as part of onboarding and appropriate controls shall be applied according to the client's risk category.
The Research Analyst may refuse or discontinue a relationship where ML/TF risks cannot be appropriately mitigated or where continuation would breach applicable law.

5. Procedure for Identifying Clients

Client identification shall be carried out at the time of establishing the client relationship. The Research Analyst shall collect and verify such KYC information as is applicable to a Research Analyst and required under applicable law and regulation.

PAN and other prescribed identity information, as applicable.
Name, contact details and address information, as applicable.
Entity constitution/incorporation and authorised-person information for non-individual clients.
Purpose and intended nature of the relationship.
PEP and sanctions/designated-list screening.
Client risk classification and supporting rationale.

Failure by a prospective client to provide satisfactory evidence of identity or other mandatory information shall be documented and escalated to the appropriate authority. Services shall not commence until applicable onboarding requirements are satisfactorily completed.

6. Beneficial Ownership and Control

Where the client is a legal person or arrangement, the Research Analyst shall identify and verify beneficial ownership/control in accordance with the applicable PML Rules and SEBI requirements.

Where the Research Analyst does not maintain or operate the client's securities account and does not receive securities execution data, responsibility for beneficial ownership of that securities account remains with the relevant intermediary/broker handling the account. This does not remove the Research Analyst's own obligations in relation to its direct client relationship.

7. Client Due Diligence and Risk Assessment

The Research Analyst shall apply a risk-based approach to identify, assess and mitigate ML/TF risks. Relevant factors may include the client's profile, geography, ownership/control structure, PEP status, adverse information, payment behaviour, nature of the relationship and other relevant circumstances.

Risk Category	Illustrative Factors	Minimum Control
Low	Straightforward profile; transparent relationship; no material adverse indicators	Standard CDD and periodic review
Medium	Some elevated risk indicators or moderately complex profile	Additional checks and enhanced monitoring
High	PEP/high-risk jurisdiction; complex ownership; adverse information; unexplained activity/payment; significant risk indicators	Enhanced Due Diligence, appropriate senior management involvement and enhanced monitoring

The risk assessment shall be documented and periodically updated. Low-risk treatment shall not be applied where there is a suspicion of ML/TF or other circumstances indicate that the client does not in fact pose a low risk.

8. Enhanced Due Diligence

Non-resident or higher-risk geographic relationships, where relevant.
Politically Exposed Persons (PEPs) and relevant connected persons as applicable.
Complex ownership/control structures.
Trusts, charities, NGOs or similar structures where relevant.
Clients with material adverse information or unexplained payment/source information.
Non-face-to-face relationships where enhanced measures are required.
Any other relationship assessed as high risk.

EDD may include additional identification information, source-of-funds/source-of-wealth information where applicable, senior management approval, enhanced monitoring and more frequent review.

9. PEP and Sanctions / Designated List Screening

Screen prospective clients and relevant persons against applicable sanctions/designated lists at onboarding and periodically thereafter.
Maintain and update applicable designated-list information as required.
Where a potential match is identified, immediately escalate to the Principal Officer/Designated Director for verification and appropriate action.
PEP relationships shall be subject to appropriate approval and enhanced measures as required.
Applicable UAPA, WMD Act and Government/SEBI directions shall be followed.

10. Ongoing Due Diligence

Review the client relationship against the Research Analyst's knowledge of the client and its risk profile.
Update KYC and beneficial ownership information periodically and whenever material changes or inconsistencies arise.
Reassess the client's risk when the client profile, ownership, geography or activity changes materially.
Re-perform due diligence where there are suspicions of ML/TF or doubts regarding the adequacy or veracity of previously obtained information.
Document material reviews and decisions.

11. Transaction Monitoring and Fee Collection

As the Research Analyst does not execute or settle securities transactions for clients and does not operate client trading/demat accounts, transaction monitoring under this Policy is primarily directed toward transactions and activities actually handled by the Research Analyst.

Research-service fees shall be received through designated bank/electronic payment channels.
Cash collection of research-service fees shall not be permitted.
Payments from unrelated third parties shall be identified and escalated where unexplained or inconsistent with the client relationship.
Unusual, complex or unusually large payments, unexplained refunds, repeated payment attempts or payment patterns without an apparent lawful/economic purpose shall be reviewed.
Where the Research Analyst becomes aware of information suggesting that its services or payment relationship may be connected with proceeds of crime or terrorist financing, the matter shall be escalated to the Principal Officer.

12. Suspicious Transaction Identification and Reporting

The following may be treated as indicators requiring review, depending on the circumstances:

Unexplained third-party payments.
Repeated attempts to avoid or bypass KYC/CDD requirements.
False, inconsistent or unverifiable identity information.
Unusual payment behaviour inconsistent with the client profile.
Complex or unusually large activity without apparent economic purpose.
Links to sanctioned/designated persons or high-risk jurisdictions.
Adverse information indicating possible criminal activity or proceeds of crime.
Any activity giving reasonable grounds to suspect ML/TF.

Employees shall promptly escalate such concerns to the Principal Officer/Compliance Function. The Principal Officer shall review the facts, document the assessment and, where the statutory criteria are met, ensure timely reporting to FIU-IND.

The fact that an STR has been filed or is being considered shall be kept confidential. No employee shall disclose such information to the client or any unauthorised person.

13. Reporting to FIU-IND and Other Authorities

The Principal Officer shall be responsible for applicable FIU-IND reporting.
STRs shall be filed within the applicable statutory/regulatory timeline.
CTR/NTR or other reports shall be made where applicable to the Research Analyst's activities and required by law.
The Research Analyst shall respond to lawful requests from SEBI, FIU-IND, law-enforcement or other competent authorities within the prescribed timeframe.
All regulatory reporting and related records shall be maintained confidentially and securely.

14. Maintenance of Records

The Research Analyst shall maintain client identification, CDD, risk assessment, screening, payment/transaction, escalation, investigation and reporting records in a manner that permits reconstruction and regulatory review.

Record Type	Retention Period
Records relating to transactions covered under the PML Rules	At least five years from the date of the transaction
Records relating to client identification, KYC/CDD, account files and business correspondence	At least five years after the business relationship has ended or the account has been closed, whichever is later
Records relating to suspicious transactions and related assessments/reporting	Maintained for the applicable statutory period and for such longer period as may be required by law or in connection with an ongoing investigation

15. Audit and Independent Review

AML/CFT controls shall be subject to periodic review/audit by an independent professional/person as permitted by applicable regulation and the Research Analyst's governance framework. Audit observations shall be documented, reported to management and addressed on a priority basis.

Client onboarding and KYC completeness.
Risk classification and EDD.
PEP/sanctions screening and escalation.
Fee/payment monitoring.
STR decision-making and confidentiality.
Record retention.
Employee AML/CFT training.
Corrective-action tracking.

16. Role of the Principal Officer

Communicating the AML/CFT Policy to relevant employees.
Receiving and reviewing internal reports of suspicious activity.
Providing guidance on AML/CFT requirements and employee queries.
Ensuring relevant employees understand and follow the Policy.
Coordinating and making applicable reports to FIU-IND.
Maintaining confidentiality and preventing tipping-off.
Reviewing the effectiveness of AML/CFT controls and recommending improvements.
Escalating material AML/CFT matters to senior management/Designated Director.

17. Role of Onboarding / Client-Facing Staff

Collecting and verifying required client information.
Completing prescribed onboarding and screening checks.
Ensuring clients are not knowingly onboarded under anonymous/fictitious identities.
Escalating incomplete, inconsistent or suspicious information.
Not commencing services where mandatory onboarding requirements remain unresolved.
Maintaining confidentiality of AML/CFT reviews and reports.

18. Employee Training and Communication

A copy of this Policy shall be made available to relevant management and employees. AML/CFT awareness training shall be conducted at induction and periodically thereafter, including at least an annual awareness session and additional training when material regulatory or process changes occur.

19. Confidentiality and Prevention of Tipping-Off

AML/CFT records and investigations shall be accessible only to authorised personnel.
Information relating to STRs and related analysis shall not be disclosed to clients.
Confidentiality shall not prevent lawful sharing with FIU-IND, SEBI, law-enforcement or other competent authorities.
No employee shall disclose the fact of an STR filing or proposed filing to the concerned client.

20. Cooperation with Law-Enforcement and Regulators

The Research Analyst shall cooperate with SEBI, FIU-IND and other competent authorities and shall provide client, KYC, payment, correspondence and other relevant information when lawfully requested, subject to applicable confidentiality and legal requirements.

21. Policy Review and Amendment

Management shall review this Policy at least annually and whenever there is a material change in applicable AML/CFT laws, SEBI/FIU-IND requirements, the Research Analyst's business model, client profile, payment methods, technology or identified ML/TF risk. Amendments shall be approved through the applicable governance process.