PMLA (Anti-Money Laundering) Policy

01.Objectives of the PMLA Policy

• To prevent Saanvi Research from being used, intentionally or unintentionally, by criminal syndicates for money laundering or terrorist financing activities.
• To institute clear Client Due Diligence (CDD) and Know Your Customer (KYC) standards prior to onboarding clients.
• To identify, monitor, and report suspicious transactions (STR) directly to FIU-IND.
• To ensure compliance with statutory cash transaction reporting limits (> Rs. 10 Lakhs), alongside an absolute prohibition against accepting cash fees.
• To train employees and raise investor awareness regarding anti-money laundering norms.

02.Client Due Diligence (CDD) Framework

Prior to activating any research service subscription, Saanvi Research executes full CDD verification:

• KYC Verification: Obtaining verified identity proof (PAN card mandatory) and official valid address proof (Aadhaar, Passport, Voter ID) via CKYC/KRA integration.
• Direct Verification: Interacting with the client via registered telephonic or video channels to confirm identity authenticity.
• System Records: Digitally archiving all correspondence, fee receipts, and onboarding agreements in an encrypted audit trail.

03.Policy for Acceptance of Clients

• No Anonymous or Fictitious Accounts: Under no circumstances will services be rendered under fictitious names or anonymous accounts.
• Cash Fee Prohibition: Under no circumstances are fee payments accepted in cash. All subscriptions must originate from authorized banking channels (NEFT/RTGS/UPI/Net Banking).
• Non-Cooperation Rejection: Accounts will be immediately declined where the prospective client fails or refuses to provide complete KYC information.
• UNSCR Sanctions Screening: The applicant's identity is screened against United Nations Security Council Resolutions (UNSCR 1267) lists and domestic ban lists before account activation.
• Risk Categorization: Clients are classified into Low, Medium, or High Risk based on geographic origin, turnover scale, and professional occupation.

04.Identification & Reporting of Suspicious Transactions (STR)

Saanvi Research maintains systems to recognize suspicious patterns, including:

• Clients uncooperative with identity verification or attempting to conceal beneficial ownership.
• Unusual source of funds disproportionate to the client's declared financial standing.
• Transfers originating from high-risk offshore jurisdictions without clear economic rationale.
• Attempted routing of subscription fees through unrelated third-party bank accounts.
• Transactions abruptly abandoned or aborted when KYC or identity queries are initiated. (All aborted suspicious transactions are documented and reported as STR).

05.Monitoring of Transactions

• Special scrutiny of unusually large fee payments or complex settlement patterns.
• Threshold limits defined for each class of client; any exceeding payments undergo manual compliance review.
• All cash transactions over Rs. 10,000,000 (or equivalent foreign currency) or series of connected cash transactions within 30 days are statutorily flagged.
• Periodic reviews to verify existing client databases against updated UN sanctions lists.

06 & 07.Record Keeping & Five-Year Retention Mandate

In compliance with SEBI Regulations and Rule 3 of PML Rules, all records of client identity, transaction trail, fee invoices, bank account origins, and suspicious transaction filings are preserved securely for a minimum period of five (5) years from the date of the transaction or termination of the business relationship.

08.Statutory Reporting to Financial Intelligence Unit-India (FIU-IND)

In terms of the PML Rules, all suspicious transactions are directly submitted to the Director, FIU-IND:

09, 10 & 11.Principal Officer & Designated Director Particulars

To ensure complete compliance and direct reporting to authorities, the designated officers act as the central reference points:

12 & 13.Staff Training, Investor Education & Policy Review

• Screening Procedures: Comprehensive background checks and qualification verifications are conducted when hiring research analysts and operations staff.
• Ongoing AML Training: All analytical and support personnel undergo periodic refresher training on AML/CFT typologies and red flag identification.
• Annual Policy Review: This PMLA Policy is reviewed annually or whenever SEBI/FIU-IND updates regulatory circulars, ensuring continuous regulatory alignment.