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

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.

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

Corporate