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Anti-Money Laundering (AML) Policy
(Independent Research Analyst)
1. Objective
This Anti-Money Laundering (AML) Policy is adopted in accordance with the requirements of the Securities and Exchange Board of India and the provisions of the Prevention of Money Laundering Act, 2002. The objective of this policy is to prevent the misuse of research services for money laundering or terrorist financing activities. The Research Analyst follows a risk-based approach to identify and monitor suspicious activities.
2. Client Identification Procedure
Before onboarding a client for paid research services, we collect basic details such as Name, Country, Work category, KYC status, Mobile Number, Email id etc. The Research Analyst does not independently verify or certify the authenticity of client documents submitted and relies on information provided by the client in good faith unless circumstances indicate heightened risk.
3. Payment Controls
To reduce AML risks, the Research Analyst will accept payments only through traceable banking channels such as: Bank transfer, UPI , Payment gateway, Cheque etc only. The following payment modes will not be accepted: Cash payments, Payments from unrelated third parties.
Payments should preferably originate from the same individual or entity receiving the service.
4. Risk Categorization of Clients
Clients may be categorized into broad risk levels based on available information:
Low Risk : Individual investors, Salaried, Self employed professionals.
Medium Risk: Business owners
High Risk : Politically exposed persons (PEPs)
5. Clients unwilling to provide identification
The Research Analyst reserves the right to decline or discontinue services for high-risk clients.
6. Monitoring for Suspicious Activity
The Research Analyst will remain alert to possible suspicious activities such as refusal to provide basic identification or unusual urgency or secrecy regarding transactions. If suspicious activity is observed, the Research Analyst may: Decline service, Request additional documentation or Maintain records for regulatory purposes.
7. Principal Officer
As an independent Research Analyst, the Research Analyst shall act as the Principal officer handling AML compliance
8. Limitation of Responsibility
The Research Analyst relies on information/documents provided by clients in good faith. The RA does not undertake forensic verification of documents.
The RA provided subscription based ( Annual or Half yearly) stock recommendation service. The RA does not accept or never manage client funds. The stock transactions should be handled by customers independently with their SEBI registered brokers using their discretion.