AML POLICY

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RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

Anti-Money Laundering Policy (AML) of RA VIJAY KUMAR GUPTA: INH000020226

This policy has been formed in the 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 (‘Act’) and Rules framed thereunder

after making necessary amendments in the existing Anti-Money Laundering Policy of the

VIJAY KUMAR GUPTA: INH000020226.

In pursuance of above said circular and the provisions of the Act, the policy of the VIJAY

KUMAR GUPTA: INH000020226 is to prohibit and actively prevent money laundering and

any activity that facilitates money laundering or terrorist financing. Money Laundering (ML)

is generally understood as engaging in acts designed to conceal or disguise the true origins

of criminally derived proceeds or assets so that they appear to have been derived from

legitimate origins or constitute legitimate assets.

1. Initiatives by VIJAY KUMAR GUPTA: INH000020226:

The basic purpose of the AML Policy is to establish a system for VIJAY KUMAR GUPTA:

INH000020226 to participate in the international efforts against ML and to duly comply with

the guidelines as detailed in the above circular of SEBI, as amended and other legal

provisions and to ensure that VIJAY KUMAR GUPTA: INH000020226 is not used as a vehicle

for ML. The AML framework of VIJAY KUMAR GUPTA: INH000020226 would meet the

extant regulatory requirements.

2. Scope:

This AML Policy establishes the standards of AML compliance and is applicable to all

activities of VIJAY KUMAR GUPTA: INH000020226.

3. Objectives of the Policy:

i. To establish a framework for adopting appropriate AML Procedures and controls in the

operations / Business processes of VIJAY KUMAR GUPTA: INH000020226.

ii. To put in place appropriate controls for the detection and reporting of suspicious

activities in accordance with applicable laws/laid down procedures.

iii. To comply with applicable laws and regulatory guidelines.

iv. To take necessary steps to ensure that the concerned staff are adequately trained in

KYC/AML procedures.

v. To assist law enforcement agencies in their effort to investigate and track money

launderers.

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

4. Principal Officer – Designation and Duties:

The VIJAY KUMAR GUPTA: INH000020226 has designated the Research Analyst as the

Principal Officer for due compliance of its AML measures.

He will act as a central reference point in facilitating onward reporting of suspicious

transactions and for playing an active role in the identification and assessment of potentially

suspicious transactions.

The duties of the Principal Officer of VIJAY KUMAR GUPTA: INH000020226 will include

monitoring the company’s compliance with AML obligation and overseeing maintenance of

AML records, communication and training for employees.

The Principal Officer of VIJAY KUMAR GUPTA: INH000020226 will ensure filing of necessary

reports with the Financial Intelligence Unit (FIU–IND). Principal Officer is authorized to issue

additional circulars and advisories, to and seek information from the concerned officials for

due compliance of AML measures from time to time.

The VIJAY KUMAR GUPTA: INH000020226 has provided the FIU with contact information of

the Principal Officer and will promptly notify FIU of any change in this information.

5. Customer Due Diligence:

At the time of providing services, the VIJAY KUMAR GUPTA: INH000020226 will verify the

identity records and current address(es)including permanent address(es) of the client, the

nature of the business of the client and his financial status by scrupulously following the KYC

norms.

Adequate information to satisfactorily establish the identity of each new client and the

purpose of the intended nature of the relationship should be obtained.

KYC norms shall be followed while establishing the client relationship and may further be

followed while carrying out transactions for the client or when there is doubt regarding the

veracity or adequacy of previously obtained client identification data.

Reliance would be placed on the documents as prescribed by the Securities and Exchange

Board of India/KYC Records as applicable from time to time.

Service can be provided only after the completion of all the required documents and after

due verification with originals.

The concerned official of the VIJAY KUMAR GUPTA: INH000020226 will put his signature

with the stamp “verified with original” after due verification with the original documents on

the copy thereof.

(NA in RA, we take KYC documents as proof)

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

Additionally following norms shall be observed:

i) No service will be provided in a fictitious, benami name or anonymous basis.

ii) Adhering to parameters developed to enable classification of clients into low, medium,

and high risk. (NA in Research Analyst – Risk Profiling not allowed)

iii) Documentation requirements and other information may be collected in respect of

different classes of clients depending on the perceived risk and having regard to the

requirements of the Prevention of Money Laundering Act, 2002 and the guidelines issued by

SEBI from time to time.

iv) The VIJAY KUMAR GUPTA: INH000020226 shall consult the relevant authority, in case

return of securities or money that may be from suspicious trades is desired.

v) Any person other than the constituent can operate the account of the constituent only if

he/she has been duly authorized by the constituents. In case of body corporate or other

entities, accounts can be operated only by the authorized persons supported by necessary

documents. It is further clarified that the transaction limits for the operation, required

margin and the trading relations with the clients will be governed as per the Circular, Rules,

Regulations and Bye-law of SEBI/Exchange and as per agreement(s) with the constituents. It

is further reiterated that all payments should be received by cheque and all payments

should be made through cheque. Cash transactions are not allowed as per the direction of

the SEBI/Exchange and the company shall comply with the same.

vi) Before asking for service VIJAY KUMAR GUPTA: INH000020226 will ensure that the

identity of the client does not match with any person having known criminal background or

is not banned in any other manner, whether in terms of criminal or civil proceedings by any

enforcement agency worldwide and may take declaration to this affect from the prospective

client

On failure by prospective client to provide satisfactory evidence of identity, new service

shall not be provided and the matter shall be reported to the higher authority.

vii) No service will be provided without acceptance of a copy of the PAN Card as directed by

SEBI/Exchange. The said PAN received will be verified from the Income Tax/NSDL/KRA

website before any service is provided.

viii) Without diluting the above requirements, the personnel providing services may obtain

other independent information to satisfactorily establish the identity of each new client and

the purpose of the intended nature of the relationship.

ix) Records of all identification information shall be maintained for ten years after the

service has been closed unless some inquiry/investigation is pending at that time for which

retention for further period is directed by an agency/authority. Special care shall be taken

while providing services to Clients of Special Category (CSC).

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

Such clients include the following:

a. Non-resident clients

b. High net worth clients

c. Trust, Charities, NGOs, and organizations receiving donations

d. Companies having close family shareholdings or beneficial ownership

e. Politically exposed persons (PEP) of foreign origin e.g. current/former heads of state,

current/former senior high-profile politicians, senior government/ judicial/ military, senior

executives of state-owned corporations, and connected persons (immediate family, close

advisors and companies in which such individuals have interest or significant influence)

f. Companies offering foreign exchange offerings.

g. Clients in high-risk countries (where the existence/effectiveness of money laundering

controls is suspected, where there is unusual banking secrecy, countries active in narcotics

production, countries where corruption (as per transparency international corruption

perception index) is highly prevalent, countries against which government sanctions are

applied, countries reputed to be any of the following – havens/sponsors of international

terrorism, offshore financial centers, tax havens, countries where fraud is highly prevalent.)

h. non-face-to-face clients

i. Clients with dubious reputations as per public information available etc.

The above-mentioned list is only illustrative and the company exercises independent

judgment to ascertain whether new clients should be classified as CSC or not.

x) The Company shall duly comply with the KYC / client identification procedures that may

be specified by SEBI from time to time.

xi) The concerned officials at VIJAY KUMAR GUPTA: INH000020226 should take extra

caution in case of existing or potential Politically Exposed Persons (PEP). They may seek

additional information and also take the help of publicly available information.

xii) No business relationships can be established with PEP without the permission of any of

the Directors of the Company or the Principal Officer. Where a customer has been accepted

and the customer or beneficial owner is subsequently found to be, or subsequently

becomes a PEP, the approval from the above said officials is required to continue the

business relationship.

xiii) The Officials of the Company may track the financial soundness of the clients and shall

take reasonable measures to verify source of funds of clients identified as PEP.

6. Maintenance of records:

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

The Principal Officer of VIJAY KUMAR GUPTA: INH000020226 shall ensure the maintenance

of the following records:

 All cash transactions of the value of more than rupees ten lakhs or its equivalent in

foreign currency;

 All series of cash transactions integrally connected to each other which have been

valued below rupees ten lakhs or its equivalent in foreign currency where such series

of transaction have taken place within a month;

 All cash transactions where forged or counterfeit currency notes or bank notes have

been used as genuine and where any forgery of a valuable security has taken place;

4. All suspicious transactions - Suspicious transaction means a transaction whether or not

made in cash and including inter-alia, credits or debits into or from any non-monetary

account such as demat account, security account etc. which, to a person acting in good faith

gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or

appears to be made in circumstances of unusual or unjustified complexity; or appears to

have no economic rationale or bonafide purpose.

The records shall contain the following information:

 the nature of the transactions;

 the amount of the transaction and the currency in which it was denominated;

 the date on which the transaction was conducted; and

 the parties to the transaction.

VIJAY KUMAR GUPTA: INH000020226 shall also endeavour to maintain such records as are

sufficient to permit reconstruction of individual transactions (including the amounts and

types of currencies involved, if any) so as to provide, if necessary, evidence to the

investigating agencies for the prosecution of criminal behaviour. For this purpose, the

company shall retain the following documents as to:

a. the beneficial owner of the account;

b. the volume of the funds flowing through the account; and

c. for selected transactions:

i. the origin of the funds;

ii. the form in which the funds were offered or withdrawn, e.g. cash, cheques, etc.;

iii. the identity of the person undertaking the transaction;

iv. the destination of the funds;

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

v. the form of instruction and authority.

VIJAY KUMAR GUPTA: INH000020226 shall ensure that all customer and transaction records

and information are available on a timely basis to the competent investigating authorities.

Where appropriate, he may consider retaining certain records, e.g. customer identification,

account files, and business correspondence, for periods which may exceed that required

under the SEBI Act, Rules and Regulations framed there-under PMLA 2002, other relevant

legislation, Rules and Regulations or Exchange bye-laws or circulars.

7. Retention of Records:

The records of the identity of clients is maintained and preserved for a period of ten years

from the date of cessation of transactions between the client and the Research Analyst. In

situations where the records relate to on-going investigations or transactions which have

been the subject of a suspicious transaction reporting, they should be retained until it is

confirmed that case has been closed.

8. Monitoring Accounts for Suspicious Activity:

The following kinds of activities are to be treated as red flags and reported to the Principal

Officer of VIJAY KUMAR GUPTA: INH000020226:

i. Clients whose identity verification seems difficult or clients appear not to cooperate

ii. ii. Where the source of the funds is not clear or not in keeping with the clients apparent

standing /business activity;

iii. Clients in high-risk jurisdictions or clients introduced by such clients or banks or affiliates

based in high-risk jurisdictions;

iv. Substantial increases in business without apparent cause;

v. Unusually large cash deposits made by an individual or business;

vi. Clients transferring large sums of money to or from overseas locations with instructions

for payment in cash;

vii. Transfer of investment proceeds to apparently unrelated third parties;

viii. Unusual transactions by CSCs and businesses undertaken by shell corporations, offshore

banks /financial services, and businesses reported to be in the nature of export/import of

small items.

The above-mentioned list is only illustrative and whether a particular transaction is

suspicious or not will depend upon the background, details of the transactions and other

facts and circumstances.

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

When any functionary of the company detects any red flag, he or she will cause it to be

further investigated for his/her satisfaction or report the same to the Principal Officer for

further investigation and necessary action.

9. Reporting to Financial Intelligence Unit –India

In terms to the PMLA rules, Principal Officer is required to report information relating to

cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND)

at the following address:

Director, FIU-IND,

Financial Intelligence Unit-India,

6th Floor, Hotel Samrat, Chankyapuri,

New Delhi – 110 021.

Website: https://www.fingate.gov.in/

For Cash Transaction Reporting:

Dealings in Cash, if any, requiring reporting to the FIU IND will be done in the CTR format

and in the manner and at intervals as prescribed by the FIU IND.

Procedure for Suspicious Transactions Reporting:

The staff at operating terminal shall be adequately trained with PMLA requirements and

reporting suspicious transaction to Principal Officerof VIJAY KUMAR GUPTA: INH000020226.

The Principal Officer of VIJAY KUMAR GUPTA: INH000020226 will make a note of suspicion

transaction that have not been explained to his satisfaction and thereafter report the same

to the FIU IND within the required deadlines.

Where a client aborts/abandons a suspicious transaction on being asked some information

by the company officials, the matter shall be reported to FIU in the STR irrespective of the

amount by the Principal Officer.

The Principal Officer of VIJAY KUMAR GUPTA: INH000020226 will not base the decision on

whether to file a STR solely on whether the transaction falls above a set threshold.

The Principal Officer of VIJAY KUMAR GUPTA: INH000020226 will file a STR and notify law

enforcement of all transactions that raise an identifiable suspicion of criminal or terrorist

corrupt activities.

VIJAY KUMAR GUPTA: INH000020226 will not notify any person involved in the transaction

that the transaction has been reported, except as permitted by the PML Act and Rules

thereof.

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

Utmost confidentiality shall be maintained in filing of CTR and STR to FIU-IND. The reports

may be transmitted by speed/registered post/fax at the notified address.

No nil reporting needs to be made to FIU-IND in case there are no cash/suspicious

transactions to be reported.

VIJAY KUMAR GUPTA: INH000020226 shall not put any restrictions on operations in the

accounts where an STR has been made.

VIJAY KUMAR GUPTA: INH000020226 and its directors, officers and employees (permanent

and temporary) shall beprohibited from disclosing ((“tipping off”) the fact that a STR or

related information is being reported or provided to the FIU-IND.

It should be ensured that there is no tipping off to the client at any level. The company will

create and maintain STRs and CTRs and relevant documentation on customer identity and

verification and will maintain STRs and their accompanying documentation for such period

as prescribed from time to time.

10. Internal Audit:

Internal Audit shall ensure compliance with policies, procedures, and controls relating to the

prevention of money laundering and terrorist financing, including the testing of the system

for detecting suspected money laundering transactions, evaluating and checking the

adequacy of exception reports generated on large and/or irregular transactions, the quality

of reporting of suspicious transactions and the level of awareness of front line staff of their

responsibilities in this regard.

11. Employee’s Hiring /Employee’s Training / Investor Education:

VIJAY KUMAR GUPTA: INH000020226 has an ongoing employee training under the

leadership of the Principal Officer. The training includes, inter alia: how to identify red flags

and signs of money laundering that arise during the course of the employees’ duties; what

to do once the risk is identified.

What are the employees’ roles in the company’s compliance efforts and how to perform

them; the company’s record retention policy; and the disciplinary consequences for non-

compliance with the Act.

Means of the training may include educational pamphlets, videos, internet systems, in-

person lectures, and explanatory memos.

The operations are reviewed periodically to see if certain employees, such as those in

compliance, margin, and corporate security, require additional specialized training.

The implementation ofAML/CFT measures require intermediaries to demand certain

information from investors which may be of personal nature or which have hitherto never

RESEARCH ANALYST: VIJAY KUMAR GUPTA

RESEARCH ANALYST REGISTRATION NUMBER: INH000020226

been called for. Such information can include documents evidencing the source of

funds/income tax returns/bank records etc.

This can sometimes lead to the raising of questions by the customer with regard to the

motive and purpose of collecting such information.

Therefore, the Principal Officer and other officials of the company will sensitize the

customers about these requirements as the ones emanating from AML and CFT framework

so as to educate the customer of the objectives of the AML/CFT programme.

12 Monitoring Employee Conduct and Accounts:

VIJAY KUMAR GUPTA: INH000020226 subjects employee accounts to the same AML

procedures as customer accounts, under the supervision of the Principal Officer.

The Principal Officer’s account is reviewed by the Managing Director.

13 Confidential Reporting of AML Non-Compliance:

Employees report any violations of the VIJAY KUMAR GUPTA: INH000020226 AML

compliance program to the Principal Officer of VIJAY KUMAR GUPTA: INH000020226 unless

the violations implicate the Principal Officer, in which case the employee shall report to the

Managing Director. Such reports are confidential, and the employee suffers no victimization

for making them.

14 Review:

The Company conducts a periodic review of the policy. In case of amendment in statutory

provisions/ regulations necessitating amendment, the relevant portions of the policy shall

be deemed to have been modified from the date of amendment in relevant statutory

provisions. In such case the modified policy shall be placed for review by the Board in

regular course.

15 Communication:

Principal Officer of VIJAY KUMAR GUPTA: INH000020226 shall ensure that this policy is

communicated to all management and relevant staff including Directors, Head of the