aml-policy

Anti-Money Laundering (AML) Policy

Jyoti Deviprasad Budhia
SEBI Registered Research Analyst
Registration No: INH000002095

1. Objective

We aim to prevent misuse of our services for money laundering and terrorist financing.
We follow guidelines issued by Securities and Exchange Board of India and applicable laws in India.

2. Scope

This policy applies to:

All clients subscribing to our research services
All payment transactions received by us
Client onboarding and verification processes

3. Regulatory Framework

We comply with:

SEBI (Research Analysts) Regulations, 2014
Prevention of Money Laundering Act, 2002 (PMLA)
Rules and circulars issued by SEBI

4. Client Due Diligence (CDD)

We verify the identity of every client before providing services.

We collect:

Full name
PAN (mandatory)
Mobile number and email address
Basic address details

We may request additional documents in higher-risk cases.

We do not onboard anonymous clients.

5. Payment Policy

We accept payments only through:

UPI transfers via QR code in our registered name

You must ensure:

Payment is made from your own bank account
Name on the payment matches your registered details

We do not accept:

Third-party payments
Cash payments

We may request proof of payment ownership if required.

6. Risk Assessment

We classify clients based on risk level:

Low risk
- Individuals with clear identity
- Normal subscription value
Medium risk
- New clients with limited history
High risk
- High-value subscriptions
- Mismatch between client identity and payment source
- Politically exposed persons (PEPs) or non-resident clients

We apply enhanced checks for higher-risk clients.

7. Monitoring and Red Flags

We monitor transactions and client activity.

Red flags include:

Multiple payments from different UPI IDs
Payments not matching client name
Unusual or high-value transactions
Requests for third-party routing of funds

We review such cases before activating or continuing services.

8. Reporting Obligations

Where suspicious activity is identified:

We take action as required under PMLA
We may report to relevant authorities

We maintain strict confidentiality of such actions.

9. Record Keeping

We maintain records for a minimum of 5 years:

Client KYC details
Payment records (UPI transactions)
Communication and service records

10. Data Protection

We protect client information using secure systems.

We do not share client data except where required by law or regulatory authorities.

11. Employee / Associate Responsibility

If any associates are involved, they are required to:

Follow this AML policy
Report suspicious activities
Maintain confidentiality

12. Policy Review

We review this policy periodically.
We update it based on changes issued by Securities and Exchange Board of India.

13. Contact Details

For AML-related queries:

Name: Jyoti Deviprasad Budhia
SEBI Registration No: INH000002095
Email: jyoti.budhia@gmail.com