1. Introduction

Finlight Research India Private Limited is committed to complying with the provisions of the Prevention of Money Laundering Act, 2002 (PMLA) and the rules notified thereunder. This policy outlines the framework for implementing Anti-Money Laundering (AML) measures, including procedures for client due diligence, monitoring of transactions, and reporting obligations.

2. Regulatory Framework

• Prevention of Money Laundering Act, 2002 (PMLA)
• Securities and Exchange Board of India (SEBI) Guidelines
• Financial Intelligence Unit – India (FIU-IND) Guidelines
• Other relevant laws, rules, and regulations

3. Scope of the Policy

This policy applies to all clients, partners, and associates of Finlight Research India Private Limited involved in financial transactions.

4. Client Due Diligence (CDD) Process

a) Policy for Acceptance of Clients

• No account shall be opened in a fictitious or anonymous name.
• Clients must provide valid Know Your Customer (KYC) documents.
• Accounts will not be opened for individuals/entities banned by SEBI/Stock Exchanges.
• Risk assessment of clients shall be conducted using various parameters such as geographical location, nature of business, and financial transactions.

b) Procedure for Identifying Clients

• Collect and verify PAN Card, Aadhaar, or other government-issued identity proof.
• Validate KYC details through SEBI-registered KYC Registration Agencies (KRAs).
• Conduct enhanced due diligence for high-risk clients.

c) Identifying Beneficial Ownership and Control

• Identify and verify the ultimate beneficial owner (UBO) of an account.
• Establish ownership/control of an entity in cases where the client is a corporate entity or a trust.

5. Transaction Monitoring and Reporting

a) Monitoring Transactions

• Volume, frequency, and pattern of trades
• Unusual or unjustified complexity
• Lack of economic rationale
• Transactions involving high-risk jurisdictions

b) Suspicious Transaction Reporting (STR)

• Involve proceeds of criminal activities.
• Appear unusually complex or lack an economic purpose.
• Suggest an attempt to avoid regulatory reporting thresholds.

c) Cash Transaction Reporting (CTR)

• Transactions involving cash deposits or withdrawals of ₹10 lakh or more (or equivalent in foreign currency) in a single day will be reported to FIU-IND.

6. Record-Keeping

• All records related to client identification, transaction history, and AML compliance will be maintained for a minimum period of 10 years.
• Records shall be made available to regulatory authorities upon request.

7. Employee Training & Awareness

• Annual AML training sessions will be conducted as applicable.
• Any suspicious activities must be reported to the relevant authorities immediately.
• Awareness sessions will be conducted on the latest AML regulatory developments.

8. Internal Audit and Review

• Finlight Research India Private Limited will conduct regular internal audits to assess the effectiveness of its AML measures.
• Any observations from the audit will be reviewed and corrective actions will be taken.

9. Review of Policy

• This policy shall be reviewed annually or as required by regulatory changes.
• Updates shall be communicated to all relevant stakeholders.

10. Confidentiality and Compliance

• All reports and client data shall be treated confidentially.
• No disclosure shall be made to clients regarding AML investigations or reports filed.
• Strict disciplinary action will be taken against any violations of AML regulations.

11. Cooperation with Law Enforcement Authorities

• Finlight Research India Private Limited will fully cooperate with regulatory authorities such as SEBI, FIU-IND, and law enforcement agencies in matters related to AML compliance.
• Any request for information from such agencies shall be responded to promptly.