Anti Money Laundering Program

In order to discharge the statutory responsibility to detect possible attempts of money laundering, financing of terrorism or any other proceeds of crime, Market Intermediaries need to have an AML program that should, at a minimum, include:

• Principal Officer
• Internal policies, procedures, and controls;
• Recruitment of staff;
• Training of Staff on PMLA awareness;
• Identifying and Reporting Suspicious Transactions
• Record Keeping and Retention of Records
• Review of the policy

Internal policies, procedures and controls:
Know Your Client (KYC):
Considering the potential threat of usage of the financial services by a money launderer, it is essential to make reasonable efforts to determine the true identity of clients accounts requesting for trading. While opening the account of the client obtain copies of the mandatory documents that are prescribed by SEBI and verify the same with the originals as per the procedures laid down in the operating instructions & communiques issued by exchanges and SEBI to us. Such communiques are issued to us based on mandatory requirements given by SEBI from time to time and based on operational requirements. We are thus responsible for following the client identification procedures & procedures to obtain requisite details for proper identification of new customers.

We must follow the Customer Due Diligence (CDD) procedure Annexure ‘I’ that includes the following.

• Recruitment & Training of employees: We would ensure adequate screening procedures when hiring employees. It would ensure that the employees dealing with PMLA requirements are suitable and competent to perform their duties.

• Identifying & reporting Suspicious Transactions: Any suspicious transaction should be immediately notified to the Money Laundering Control Officer or any other designated officer within the intermediary. The notification may be done in the form of detailed report with specific reference to the clients, transactions and the nature/reason of suspicion. However, it should be ensured that there is continuity in dealing with client as normal until told otherwise and the client should not be told of the report.

Compliance Cell should randomly examine a selection of transaction undertaken by clients to comment on their nature i.e. whether they are in the suspicious transactions or not.

• Record Keeping and Retention of Records: PMLA stipulates that all relevant documents like account opening and their supporting documents should be maintained at least for a minimum period of 10 years after the account is closed.

In view of this, We maintain the records in terms of the provisions of PMLA. The retention period shall be modified on receiving appropriate instructions from any regulatory authority like SEBI, FIU-IND or any other statutory authority. We will also follow the procedures for regular back up, etc. The records of the transactions in clients accounts shall be maintained for a period of 10 years as required by PMLA.

• Review of Policy: We shall review the aforesaid policy at regular intervals. MD & CEO or any other authorized official shall be the authority to give directions for review of policy and undertake additions, changes, modifications etc. as directed by SEBI/ FIU-IND.

Annexure ‘I’
Customer Due Diligence (CDD) Procedure.
We obtain a copy of one of the following documents as Proof of Identity and Proof of Address. In addition, obtaining PAN Card details of the client is compulsory. The official person accepting the account opening form should verify the photocopy of the PAN Card against the original. The documents / information to be submitted by clients ( Individual/Non Indivisual) are as follows: –
Individuals
Proof of Identity:
• Passport
• Voter ID Card
• Driving license
• PAN card with photograph
• MAPIN card
• Identity card/document with applicant’s photo, issued by –
• Central/State Government and its Departments,
• Statutory/Regulatory Authorities,
• Public Sector Undertakings,
• Scheduled Commercial Banks,
• Public Financial Institutions,
• Colleges affiliated to Universities,
• Professional Bodies such as ICAI, ICWAI, ICSI, Bar Council, etc., to their Members,
• Credit cards/Debit cards issued by Banks with photographs.

Proof of Address:
• Ration card
• Passport
• Voter ID Card
• Driving license # Bank passbook # Verified copies of
• Electricity bills (not more than two months old),
• Residence Telephone bills (not more than two months old),
• Leave and License Agreement / Agreement for sale.
• Self-declaration by High Court & Supreme Court judges, giving the address in respect of their own accounts.
• Identity card/document with address, issued by:
• Central/State Government and its Departments,
• Statutory/Regulatory Authorities,
• Public Sector Undertakings,
• Scheduled Commercial Banks,
• Public Financial Institutions,
• Colleges affiliated to universities,
• Professional Bodies such as ICAI, ICWAI, ICSI, Bar Council, etc., to their Members.

Corporate
Proof of Identity:
• Certified true copy of Board Resolution, duly certified by Managing Director/Company Secretary, authorizing person to trade and opening of client account specifying the name of persons authorized. The resolution must specify the manner of operation of the account and authority given to the authorised signatories to open and operate the account.
• Names of the authorized signatory(ies), designation, photograph and their specimen signatures duly verified by Managing Director/Company Secretary.
• Memorandum and Articles of Association of the Corporate Investor.