PMLA (Anti Money Laundering) Policy

Introduction

This policy is framed and adopted as a requirement by SEBI under the Prevention of Money Laundering Act, 2002 ("PMLA"). The policy provides a framework with respect to anti money laundering measures to be taken by RANGAONE FINWALA PRIVATE LIMITED, as a SEBI registered Research Analyst.

I. Objective of the PMLA Policy

The objective of the PMLA policy is as follows:

1. To prevent RANGAONE FINWALA PRIVATE LIMITED from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.
2. Create awareness and provide clarity on KYC standards and AML measures.
3. To have a proper Client Due Diligence (CDD) process before registering clients.
4. To monitor and report suspicious transactions.
5. To monitor / maintain records of all cash transactions done by the client of the value of more than Rs. 10 lacs.

II. Client Due Diligence (CDD) Process

As a part of Client Due Diligence process, RANGAONE FINWALA PRIVATE LIMITED will do the following:

1. Maintain a record of Know Your Customer (KYC) documents (i.e valid identity proof and address proof) obtained from the entire client at the time of on boarding the clients.
2. In order to verify the genuineness of the clients, to speak with the clients before proceeding with any research services.
3. The records between the client and RANGAONE FINWALA PRIVATE LIMITED to be maintained in proper order.

III. Policy for Acceptance of Client

RANGAONE FINWALA PRIVATE LIMITED will ensure that-

• No account shall be opened in fictitious name or on an anonymous basis.
• No account will be opened if the fee for services is offered by the client in cash.
• No account is opened where RANGAONE FINWALA PRIVATE LIMITED is unable to apply appropriate CDD measures/ KYC policies.
• It will be ensured that the identity of the client does not match with any person having known criminal background or is not banned in any other manner.
• Each client shall be classified in low or medium or high risk categories depending upon the risk perception.
• Clients of Special Category (CSC) require higher degree of due diligence and regular update of Know Your Client (KYC) profile.

IV. Suspicious Transactions

RANGAONE FINWALA PRIVATE LIMITED will ensure that appropriate steps are taken to enable suspicious transactions to be recognized and reported to the Director, Financial Intelligence Unit-India.

V. Monitoring of Transactions

The transactions shall be monitored with special attention to all complex unusually large transactions / patterns which appear to have no economic purpose.

VI. Record Keeping and Retention of Records

Records of transactions shall be preserved for a period of five years from the date of transaction with the client.

VII. Information to be Maintained

Following information in respect of all transactions shall be maintained:

• The nature of the transactions
• The amount of the transaction and the currency in which it is denominated
• The date on which the transaction was conducted
• The parties to the transaction

VIII. Reporting to Financial Intelligence Unit-India

RANGAONE FINWALA PRIVATE LIMITED will report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND).

IX. Appointment of Principal Officer and Designated Director

X. Rights, Obligation and Responsibilities of Principal Officer

The principal officer shall ensure effective implementation of the PMLA Policy framework and compliance with all regulatory requirements.

XI. Rights, Obligations and Responsibilities of Designated Director

The Designated Director should ensure that all the records are maintained as mentioned in this Policy.

XII. Employees' Hiring/ Employee's Training/ Investor Education

RANGAONE FINWALA PRIVATE LIMITED will have adequate screening procedures and ongoing employee training programme for Anti-Money Laundering standards (AML) and Combating the Financial of Terrorism (CFT) procedures.

XIII. Review of Policy

The policy shall be reviewed from time to time as and when required changes will be implemented as per the applicable rules, laws, acts and regulations.