AML / CFT / PMLA POLICY

AML / CFT / PMLA POLICY

(Anti-Money Laundering & Counter Financing of Terrorism)

Name: Siddharth Sharma
Proprietor: Equi Pulse
SEBI Registered Research Analyst
SEBI Registration No.: INH000024046

1. Introduction & Regulatory Framework

This Anti-Money Laundering and Counter Financing of Terrorism Policy (“AML / CFT Policy”) is framed and adopted by Siddharth Sharma, Proprietor – Equi Pulse, in compliance with:

· The Prevention of Money Laundering Act, 2002 (PMLA) and rules made thereunder;

· SEBI Master Circulars / Guidelines on AML & CFT as amended from time to time;

· Obligations applicable to SEBI-registered intermediaries, including Research Analysts.

This Policy establishes procedures and controls to prevent misuse of the Research Analyst’s services for money laundering or terrorist financing activities.

2. Objective of the Policy

The objectives of this Policy are to:

· Prevent the Research Analyst from being used for money laundering or terrorist financing

· Establish robust KYC and Client Due Diligence procedures

· Identify, monitor, and report suspicious transactions

· Maintain records as required under PMLA and SEBI guidelines

· Ensure regulatory compliance and investor protection

3. Key Definitions

· Client / Customer: Any person or entity subscribing to or using research services.

· Beneficial Owner: The natural person(s) who ultimately own or control the client or transaction.

· KYC / CDD: Procedures to identify, verify, and understand the client and beneficial ownership.

· Enhanced Due Diligence (EDD): Additional scrutiny for high-risk clients or situations.

· Politically Exposed Person (PEP): Individuals holding prominent public functions, including family and close associates.

· Suspicious Transaction: Any transaction, attempted or executed, that raises reasonable suspicion of money laundering or terrorist financing.

4. Client Acceptance Policy

The Research Analyst shall ensure that:

· No anonymous, fictitious, or benami accounts are permitted

· Clients are onboarded only after satisfactory KYC / CDD

· No services are provided where CDD measures cannot be applied

· Client identity is screened against UN Security Council Sanctions Lists

· Clients are risk-classified into low, medium, or high risk categories

· Clients of Special Category (CSC) are subject to enhanced scrutiny

5. Client Due Diligence (KYC / CDD)

· KYC documents are obtained and verified prior to onboarding

· Beneficial ownership is identified and verified

· Periodic review of client information is conducted

· Enhanced Due Diligence is applied for high-risk clients and PEPs

· Services shall not be provided without completion of KYC

.

6. Risk Assessment & Monitoring

· A risk-based approach is adopted for AML compliance

· Transactions are monitored for unusual or suspicious patterns

· Special attention is given to large, complex, or abnormal transactions

7. Identification & Reporting of Suspicious Transactions

· Suspicious and attempted suspicious transactions are identified based on red-flag indicators

· Such transactions are escalated to the Principal Officer

· Reports are filed with FIU-IND within prescribed timelines

· Reporting decisions are not solely threshold-based

8. Reporting to FIU-IND

Information relating to cash transactions and suspicious transactions shall be reported to:

Director, Financial Intelligence Unit – India (FIU-IND)
As per procedures, formats, and timelines prescribed under PMLA Rules.

· Reporting decisions are not based solely on transaction thresholds.

· No tipping-off is permitted under any circumstances.

· Nil reporting is not required unless specifically mandated.

9. Record Maintenance & Retention

· Client identification and transaction records are maintained

· Records include nature, value, date, and parties to transactions

· Records are retained for a minimum of 5 years or longer if required

· Records are made available to SEBI / FIU-IND / auditors upon request

10. Appointment of Principal Officer

The Research Analyst shall act as the Principal Officer / Designated Officer and shall be responsible for:

· AML / CFT compliance

· Suspicious transaction reporting

· Regulatory coordination

· Record availability and policy updates

11. Internal Controls & Audit

· Adequate internal controls are maintained to ensure AML compliance.

· Periodic internal reviews or audits may be conducted to assess effectiveness.

· Any deficiencies identified shall be promptly addressed.

12. Training & Awareness

· Persons involved in operations or compliance shall receive periodic AML / CFT awareness.

· Training covers red-flag identification, reporting obligations, confidentiality, and legal consequences of non-compliance.

· Clients may be sensitized regarding AML requirements where necessary.

13. Confidentiality & Prohibition on Tipping-Off

· Client information is treated as confidential.

· No client shall be informed about filing or existence of STRs or investigations.

· Information may be disclosed only to competent authorities as required by law.

14. Review & Amendments

· This Policy is reviewed annually or upon regulatory changes

· Amendments take effect as per applicable law

· Updated Policy is published on the website

Declaration

This AML / CFT / PMLA Policy is adopted and implemented in good faith to ensure full compliance with applicable laws, regulations, and SEBI guidelines.