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 with respect to anti money laundering measures to be taken by Sagar Agarwal, as a SEBI registered Research Analyst vide Registration Number INH000016436.

Objective of the PMLA Policy

The objective of the PMLA policy is as follows:

To prevent Sagar Agarwal from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.

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 / maintain records of all cash transactions done by the client of the value of more than Rs. 10 lacs.

Client Due Diligence (CDD) Process

As a part of Client Due Diligence process, Sagar Agarwal will do the following:

Maintain a record of Know Your Customer (KYC) documents (i.e valid identity proof and address proof) obtained from the entire client at the time of on boarding the clients.

In order to verify the genuineness of the clients, to speak with the clients before proceeding with any advisory services.

The records between the client and Sagar Agarwal to be maintained in proper order.

Policy for Acceptance of Client

No account shall be opened in 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 Sagar Agarwal is unable to apply appropriate CDD measures/ KYC policies. This shall apply to cases where the information provided to Sagar Agarwal is suspected to be non - genuine, or there is perceived non - cooperation of the client in providing full and complete information.

It will be ensured that the identity of the client does not match with any person having known criminal background or is not banned in any other manner or is included in the list of individuals and entities which are subject to various sanction measures such as freezing of assets/accounts, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs).

Each client shall be classified in low or medium or high risk categories depending upon the risk perception.

Clients of Special Category (CSC) shall include:

Non - resident clients;

High net-worth clients;

Trust, Charities, Non-Governmental Organizations (NGOs) and organizations receiving donations;

Companies having close family shareholdings or beneficial ownership;

Politically Exposed Persons (PEP);

Companies offering foreign exchange offerings;

Clients in high risk countries;

Non face to face clients;

Clients with dubious reputation etc.

Suspicious Transactions

Clients whose identity verification is difficult or client is not ready to cooperate.

Where the source of funds of the clients is not clear.

Substantial increases in business without apparent cause.

Clients based in high risk jurisdictions.

Clients transferring large sums to or from overseas locations.

Attempted transfer to unrelated third parties.

Unusual transactions by CSCs.

In the event of any suspicious transaction, Sagar Agarwal will make a report and submit it to the Director, Financial Intelligence Unit-India.

Even if transactions are abandoned or aborted, they will be reported as suspicious transactions.

Monitoring of transactions

Special attention shall be paid to complex or unusually large transactions.

Internal threshold limits shall be defined.

Records shall be maintained and made available to authorities.

Records shall be preserved for five years.

The following transactions shall be monitored:

All cash transactions above ten lakh rupees.

Series of connected transactions exceeding ten lakh rupees.

Transactions involving counterfeit currency.

All suspicious transactions of any type.

Record Keeping and Retention of Records

Maintain records as per SEBI regulations and PMLA.

Maintain sufficient transaction trail information.

Preserve records for five years.

Reporting to Financial Intelligence Unit-India

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

Appointment of Principal Officer and Designated Director

Name: Sagar Agarwal

Designation: Research Analyst

Email Id: compoundingcalls@gmail.com

Phone Number: +919711170609

Employees’ Hiring / Training / Investor Education

Have adequate screening procedures while hiring employees.

Have ongoing employee training programmes for AML and CFT.

Review of Policy

The policy shall be reviewed from time to time and changes will be implemented as per applicable rules, laws, acts and regulations.