Anti Money Laundering Policy
The Government of India has serious concerns over money laundering activities which are not only illegal but anti-national as well. As a market participant it is evident that strict and vigilant tracking of all transactions of a suspicious nature is required.
Accordingly, the Company has laid down following policy guidelines:

Compliance Officer:
Ms. Bhawna Joshi is appointed as the Principal Officer. She will be responsible for the implementation of internal controls & procedures for identifying and reporting any suspicious transaction or activity to the concerned authorities.

Purpose & Scope:
As a Financial Market Intermediary (which includes a stock-broker, sub-broker) we need to maintain a record of all transactions, the nature and value of which has been prescribed in the Rules under the PMLA. Accordingly, all the back office and trading staff is instructed to observe the following

No Cash transactions for trading in securities shall be allowed from any client in the normal course of business.
A record of all transactions must be maintained, the nature and value of which has been prescribed in the Rules notified under the PMLA. Such transactions include:

o i. Cash transactions of a value of more than Rs 10 lakhs or its equivalent in foreign currency.
o ii. All series of cash transactions integrally connected to each other which have been valued below Rs 10 lakhs or its equivalent in foreign currency where such series of transactions take place within one calendar month.
o iii. All suspicious transactions whether or not made in cash.

 Frequent off market transfers from one BO account to another shall be scrutinized and asked for. In absence of a valid reason or if found suspicious, it shall be brought to the notice of the Principal Officer.

 Trading beyond one’s declared income: The turnover of the client should be according to their declared means of income. Any abnormal increase in clients turnover shall be reported to the Principal Officer. The Back Office staff should take due care in updating the clients financial details and shall periodically review the same.