Anti-Money Laundering (AML) Policy

This Anti-Money Laundering Policy (“AML Policy”) has been framed in accordance with SEBI Circulars on Anti Money Laundering (AML) and Combating Financing of Terrorism (CFT), Prevention of Money Laundering Act, 2002 (“PMLA”) and rules made thereunder, as amended from time to time.

The objective of this policy is to prohibit and actively prevent money laundering and any activity that facilitates money laundering or terrorist financing through Vijay Kumar Gupta (SEBI Registered Research Analyst – INH000020226).

1. Initiatives

The AML framework is designed to ensure that the Research Analyst does not become a vehicle for money laundering and complies with applicable regulatory requirements prescribed by SEBI and other statutory authorities.

2. Scope

This AML Policy is applicable to all activities carried out by Vijay Kumar Gupta in his capacity as a SEBI Registered Research Analyst.

3. Objectives of the Policy

• To establish appropriate AML procedures and controls.
• To detect and report suspicious transactions.
• To comply with applicable laws and SEBI guidelines.
• To ensure adequate AML/KYC training of staff.
• To assist law enforcement agencies.

4. Principal Officer – Designation & Duties

Vijay Kumar Gupta (INH000020226) is designated as the Principal Officer and is responsible for AML compliance, record maintenance, employee training and reporting suspicious transactions to FIU-IND.

5. Customer Due Diligence (CDD)

Client identity, address, PAN, and other KYC details are verified before providing services. Services are provided only after completion and verification of all required documents.

• No services to fictitious or anonymous clients
• PAN verification is mandatory
• No cash transactions are permitted
• Enhanced due diligence for special category clients

Clients of Special Category (CSC)

• Non-resident clients
• High Net-Worth Individuals
• Trusts, NGOs, Charities
• Politically Exposed Persons (PEP)
• High-risk jurisdictions
• Non-face-to-face clients

6. Maintenance of Records

Records of transactions, client identity, and suspicious activities are maintained as per PMLA and SEBI requirements to enable reconstruction of transactions when required by authorities.

7. Retention of Records

Client and transaction records are preserved for a minimum of ten (10) years from cessation of client relationship or closure of investigation.

8. Monitoring of Suspicious Transactions

Red flags such as unusual transaction size, unclear source of funds, high-risk jurisdictions, and abnormal activity are reported to the Principal Officer for further action.

9. Reporting to FIU-IND

Director, FIU-IND
Financial Intelligence Unit-India
6th Floor, Hotel Samrat, Chanakyapuri
New Delhi – 110021
Website: https://www.fingate.gov.in

All Cash Transaction Reports (CTR) and Suspicious Transaction Reports (STR) are filed confidentially within prescribed timelines. No tipping-off is permitted.

10. Internal Audit

Periodic internal reviews ensure AML compliance, adequacy of controls, and awareness among personnel.

11. Employee Training & Investor Education

Ongoing AML/CFT training is conducted to educate staff and investors about regulatory requirements and objectives.

12. Confidential Reporting

Employees may confidentially report AML non-compliance without fear of retaliation.

13. Review & Communication

This policy is reviewed periodically and communicated to all relevant stakeholders.