PMLA / Anti-Money Laundering Policy

Introduction

This policy is framed and adopted as a requirement by SEBI under the Prevention of Money Laundering Act, 2002 ("PMLA"). The policy provides a framework for the anti-money-laundering measures to be taken by Tradevisor Finnovations Private Limited as a SEBI Registered Research Analyst.

Objectives

• To prevent Tradevisor Finnovations Private Limited from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.
• To create awareness and provide clarity on KYC standards and AML measures.
• To have a proper Client Due Diligence (CDD) process before registering clients.
• To monitor and report suspicious transactions.
• To monitor and maintain records of all cash transactions of a value of more than ₹10 lakh done by a client.

Client Due Diligence (CDD)

• Maintain a record of Know Your Customer (KYC) documents (valid identity proof and address proof) obtained from every client at the time of onboarding.
• Speak with clients before proceeding with any research services, to verify the genuineness of the client.
• Maintain records between the client and Tradevisor Finnovations Private Limited in proper order.

Policy for acceptance of clients

• No account shall be opened in a fictitious name or on an anonymous basis.
• No account will be opened if the fee for services is offered by the client in cash.
• No account is opened where appropriate CDD/KYC measures cannot be applied — including where information provided is suspected to be non-genuine or there is perceived non-cooperation of the client.
• The identity of the client is checked so that it does not match any person with a known criminal background, or who is banned, or who is included in sanctions lists (such as those of the UN Security Council Committee).
• Each client is classified as low, medium, or high risk based on location, nature of business activity and turnover, and the manner of making payment.
• Clients of Special Category (CSC) — such as non-resident clients, high-net-worth clients, trusts/charities/NGOs, companies with close family shareholdings, Politically Exposed Persons, and clients in high-risk jurisdictions — require a higher degree of due diligence and regular KYC updates.

Suspicious transactions

Appropriate steps are taken to recognise suspicious transactions based on circumstances such as: difficulty in verifying a client's identity or lack of cooperation; unclear source of funds; substantial increases in business without apparent cause; clients based in high-risk jurisdictions; large transfers to or from overseas with instructions for cash payment; attempted transfers of investment proceeds to unrelated third parties; and unusual transactions by CSCs.

In the event of any suspicious transaction, a report is made with reference to the client, the transaction, and the nature/reason of suspicion, and submitted to the Director, Financial Intelligence Unit-India (FIU-IND).

Where transactions are abandoned or aborted by clients on being asked for details or documents, all such attempted transactions are reported in Suspicious Transaction Reports, even if not completed, irrespective of the amount.

Monitoring of transactions

• Special attention is paid to all complex, unusually large transactions or patterns which appear to have no economic purpose.
• Internal threshold limits are defined for each class of client account, and transactions exceeding these limits receive special attention.
• The background of such transactions, including documents and clarifications, is examined and findings recorded in writing and made available to auditors, SEBI, stock exchanges, and FIU-IND as required.
• All cash transactions of more than ₹10 lakh (or foreign-currency equivalent), integrally connected series of such transactions within a month, transactions involving forged/counterfeit currency, and all suspicious transactions (whether or not in cash) are monitored.
• Records of transactions are preserved for a period of five years from the date of the transaction with the client.

Record keeping & retention

We ensure compliance with the record-keeping requirements of the SEBI (Research Analyst) Regulations, 2014, the PMLA, and other relevant legislation, and maintain records sufficient to permit reconstruction of individual transactions so as to provide evidence, if necessary, for prosecution of criminal behaviour.

Information relating to transactions, whether attempted or executed, that is reported to the Director, FIU-IND is maintained and preserved for a period of five years from the date of the transaction. Where records relate to ongoing investigations or transactions subject to a suspicious-transaction report, they are retained until the case is confirmed closed.

Information maintained for each transaction includes the nature of the transaction, the amount and currency, the date on which it was conducted, and the parties to the transaction.

Reporting to FIU-IND

In terms of the PML Rules, information relating to cash and suspicious transactions is reported to the Director, Financial Intelligence Unit-India (FIU-IND), 6th Floor, Hotel Samrat, Chanakyapuri, New Delhi 110021 (website: http://fiuindia.gov.in).

Principal Officer & Designated Director

Principal Officer: Dhiraj Sagar · connect@tradevisor.in · +91 99091 31109.

Designated Director: Yash Mehta.

The Principal Officer and Designated Director act as the central reference point for identification and assessment of potentially suspicious transactions and for onward reporting to FIU-IND.

The Principal Officer has all-time access to customer identification and CDD data, complete independence and authority to access records, and is responsible for ensuring the PMLA policy framework is implemented effectively, that FIU data is downloaded and analysed, that records are available to competent authorities on a timely basis, and that staff are kept updated on changes to PMLA provisions.

The Designated Director is responsible for ensuring that all records are maintained as required by this policy.

Hiring, training & review

Adequate screening procedures are in place to ensure high standards when hiring employees, and an ongoing training programme ensures staff are adequately trained in Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) procedures.

This policy is reviewed from time to time, and changes are implemented as required by applicable rules, laws, and regulations.