MUDIT GOYAL
SEBI REGISTERED RESEARCH ANALYST
SEBI REG. NO.- INH000013022

PMLA (Anti-Money Laundering & Combating Financing of Terrorism) Policy

MUDIT GOYAL
SEBI Registered Research Analyst
SEBI Registration No.: INH000013022

Registered / Office Address:
Flat No. 801, Tower-J, Plot No. GC-03K/GH-03, Greater Noida West, VVIP Homes, Sector-16C, Noida, Gautam Buddha Nagar, Uttar Pradesh – 201301

Email: support@muditgoyal.co.in
Contact No.: +91 9958855400

INTRODUCTION

This Anti-Money Laundering (“AML”) and Combating the Financing of Terrorism (“CFT”) Policy has been framed and adopted by Mudit Goyal, an Individual Research Analyst registered with the Securities and Exchange Board of India (“SEBI”) bearing Registration No. INH000013022.

The Policy has been formulated having regard to the Prevention of Money Laundering Act, 2002 (“PMLA”), the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 (“PML Rules”), the SEBI (Research Analysts) Regulations, 2014, the applicable SEBI Master Circular for Research Analysts, SEBI's Master Circular on AML/CFT obligations of securities-market intermediaries dated June 6, 2024, and other applicable circulars, rules, regulations and amendments issued from time to time.

The purpose of this Policy is to establish appropriate procedures for identification and verification of clients, assessment of money-laundering and terrorist-financing risks, monitoring of transactions, maintenance of records and reporting of suspicious transactions to the appropriate authorities.

I. OBJECTIVES OF THE POLICY

The objectives of this Policy are:

  1. To prevent the Research Analyst's services from being intentionally or unintentionally used for money laundering, terrorist financing or other unlawful activities.
  2. To establish appropriate Know Your Client (“KYC”), Client Due Diligence (“CDD”) and risk-management procedures.
  3. To identify and verify clients before or at the commencement of the business relationship in accordance with applicable requirements.
  4. To identify beneficial owners wherever applicable.
  5. To classify clients according to their money-laundering and terrorist-financing risk.
  6. To identify, examine and report suspicious transactions or attempted transactions where required.
  7. To maintain appropriate records relating to clients, transactions, KYC, communications and compliance.
  8. To ensure compliance with applicable requirements of SEBI, FIU-IND and other competent statutory or regulatory authorities.

II. CLIENT DUE DILIGENCE (CDD)

Mudit Goyal shall undertake Client Due Diligence having regard to the nature of the client, nature of the relationship and the money-laundering or terrorist-financing risk involved.

CDD shall include, wherever applicable:

  1. Obtaining adequate information regarding the client.
  2. Identifying the client and verifying the client's identity through reliable and independent documents, data or information in accordance with applicable KYC requirements.
  3. Obtaining and maintaining valid identity proof, address proof and other KYC records as prescribed.
  4. Understanding the purpose and intended nature of the client relationship.
  5. Determining whether a person is acting on behalf of another person and verifying the authority and identity of such person wherever applicable.
  6. Identifying the ultimate beneficial owner of a non-individual client and taking reasonable measures to verify such beneficial ownership, wherever required.
  7. Conducting ongoing due diligence during the business relationship and ensuring that transactions and payments are consistent with the information available regarding the client, the client's profile and, where necessary, source of funds.
  8. Updating KYC and client information periodically or whenever circumstances require such information to be updated.

No client relationship shall knowingly be continued where adequate CDD cannot be completed and the circumstances raise concerns regarding the identity, legitimacy or activities of the client.

III. POLICY FOR ACCEPTANCE OF CLIENTS

A. Anonymous or Fictitious Clients

No client shall be accepted under an anonymous, fictitious, benami or false identity.

B. Verification of Identity

No client shall be accepted where reasonable identity verification or appropriate CDD cannot be completed.

C. Client Cooperation

Where a client refuses to provide required information or documents, provides information suspected to be false or misleading, or demonstrates deliberate non-cooperation with applicable KYC/CDD requirements, the relationship may be refused or discontinued subject to applicable law.

D. Mode of Payment

Research-service fees shall ordinarily be accepted only through legitimate banking or permitted digital payment channels capable of establishing an appropriate audit trail.

Cash payments shall not ordinarily be accepted for research services.

Payments from unrelated third parties shall be subject to appropriate scrutiny.

E. Risk Classification

Clients shall, where applicable, be classified into Low, Medium or High Risk categories based on factors such as:

  • identity and profile of the client;
  • place of residence or business;
  • nature of occupation or business activity;
  • source and manner of payment;
  • nature and purpose of the relationship;
  • beneficial ownership;
  • whether the relationship is non-face-to-face;
  • association with a high-risk jurisdiction;
  • politically exposed person (“PEP”) status; and
  • any other relevant money-laundering or terrorist-financing risk factor.

Risk classification shall be reviewed periodically and whenever material changes occur.

IV. CLIENTS REQUIRING ENHANCED DUE DILIGENCE

Higher or enhanced due diligence shall be undertaken wherever the risk assessment so requires.

Such clients may include, depending upon the circumstances:

  1. Non-resident clients.
  2. Politically Exposed Persons (“PEPs”), their family members and close associates as applicable under prevailing requirements.
  3. High-net-worth clients where circumstances warrant enhanced scrutiny.
  4. Trusts, charities, non-profit organisations and similar entities.
  5. Entities having complex or unusually close family ownership or beneficial-ownership structures.
  6. Clients connected with jurisdictions identified as presenting increased money-laundering, terrorist-financing or proliferation-financing risk.
  7. Non-face-to-face clients where enhanced verification is appropriate.
  8. Clients whose source of funds, identity or business activity requires additional verification.
  9. Clients having an adverse or dubious reputation based on reliable public information.

Enhanced due diligence may include obtaining additional documents or information regarding identity, beneficial ownership, source of funds, occupation/business, purpose of the relationship or other appropriate matters.

V. SANCTIONS, TERRORIST FINANCING AND PROHIBITED PERSONS

Reasonable measures shall be taken to ensure that clients are not persons or entities prohibited or sanctioned under applicable law.

Screening and due diligence shall, as applicable, have regard to:

  • applicable United Nations Security Council sanctions;
  • notifications and directions issued under the Unlawful Activities (Prevention) Act, 1967;
  • requirements relating to weapons of mass destruction and their delivery systems;
  • applicable Government of India notifications;
  • applicable SEBI directions; and
  • FATF-related high-risk jurisdiction requirements.

Where a potential match or prohibited relationship is identified, appropriate action shall be taken in accordance with applicable legal and regulatory requirements.

VI. IDENTIFICATION OF SUSPICIOUS TRANSACTIONS

Mudit Goyal shall take reasonable steps to recognise transactions, attempted transactions or activities that may be suspicious.

Indicators may include, among others:

  1. A client whose identity is difficult to verify or who is unwilling to cooperate with KYC/CDD requirements.
  2. Information or documentation that appears forged, altered, false, inconsistent or misleading.
  3. Payments whose source appears inconsistent with the client's known profile or circumstances.
  4. Payment by an unrelated third party without a reasonable explanation.
  5. Requests to route fees, refunds or other payments through unrelated persons or accounts.
  6. Unusually large, complex or irregular payment activity having no apparent legitimate purpose.
  7. Deliberate splitting or structuring of payments apparently intended to avoid identification or reporting requirements.
  8. Clients associated with high-risk jurisdictions.
  9. Unusual cross-border payment activity inconsistent with the nature of the research service.
  10. A client abruptly abandoning or attempting to cancel a transaction or relationship after being asked to provide KYC, source-of-funds or other compliance information.
  11. Any attempted transaction which appears suspicious even though the transaction was not completed.
  12. Any other activity giving reasonable grounds to suspect money laundering, terrorist financing, proceeds of crime or another unlawful activity.

The determination of whether a transaction is suspicious shall be based upon the facts and circumstances of the particular case and not merely upon the amount involved.

VII. MONITORING OF TRANSACTIONS AND CLIENT RELATIONSHIPS

Client relationships and relevant financial transactions connected with the provision of research services shall be subject to appropriate monitoring.

Special attention shall be given to:

  1. Complex or unusually large transactions.
  2. Transactions or patterns having no apparent economic or legitimate purpose.
  3. Payments inconsistent with the client's known profile.
  4. Repeated third-party payments.
  5. Transactions involving high-risk jurisdictions.
  6. Transactions exceeding internal risk thresholds, where such thresholds are maintained.
  7. Transactions or attempted transactions displaying suspicious characteristics.

Where necessary, the background, purpose and circumstances of such transactions shall be examined and findings recorded.

Records and supporting documents shall be made available to SEBI, FIU-IND, RAASB or other competent authorities as required under applicable law.

VIII. RECORD KEEPING AND RETENTION

Mudit Goyal shall maintain records sufficient to provide an appropriate audit trail and, where required, permit reconstruction of individual transactions.

Records may include:

  1. Client identification and KYC documents.
  2. Beneficial-ownership information, where applicable.
  3. Client agreements and onboarding records.
  4. Payment and transaction records.
  5. Relevant communications and business correspondence.
  6. Records relating to source-of-funds enquiries, where undertaken.
  7. Risk classifications and enhanced due-diligence records.
  8. Details and supporting documents relating to unusual or suspicious transactions.
  9. Copies and records of reports submitted to FIU-IND or other competent authorities.

Records of transactions required under applicable PML Rules shall be maintained and preserved for at least five years from the date of the transaction, or for such longer period as may be prescribed.

Records evidencing the identity of clients and beneficial owners, account/client files and relevant business correspondence shall be maintained for at least five years after the business relationship has ended or the account/relationship has been closed, whichever is later, or for such longer period as may be prescribed.

Where records relate to an ongoing investigation, regulatory enquiry or transaction that has been the subject of suspicious-transaction reporting, such records shall be retained until confirmation that the relevant matter has been closed, where required.

Records shall be maintained in a manner that permits timely retrieval when requested by a competent authority.

IX. INFORMATION TO BE MAINTAINED

In respect of transactions required to be recorded under applicable PML requirements, the following information shall be maintained as applicable:

  1. Nature of the transaction.
  2. Amount of the transaction.
  3. Currency in which the transaction is denominated.
  4. Date on which the transaction was conducted or attempted.
  5. Parties to the transaction.
  6. Relevant supporting records and documentation.
  7. Such other information as may be prescribed by SEBI, FIU-IND or applicable law.

X. REPORTING TO FINANCIAL INTELLIGENCE UNIT – INDIA

Where Mudit Goyal, acting through the Principal Officer, is satisfied that a transaction or attempted transaction is suspicious and reporting is required under applicable law, a Suspicious Transaction Report (“STR”) shall be furnished to the Director, FIU-IND within the prescribed timeline.

Under the applicable PML framework, an STR is required to be furnished promptly and, where applicable, not later than seven working days after being satisfied that the transaction is suspicious.

Appropriate confidentiality shall be maintained in respect of STRs and related enquiries.

No client or unauthorised person shall be informed that an STR has been filed, is proposed to be filed or that information has been requested in relation to a suspicious transaction where such disclosure would constitute prohibited “tipping off”.

Reports shall be filed through the mechanism/portal prescribed by FIU-IND from time to time.

Financial Intelligence Unit – India

Director, FIU-IND
Financial Intelligence Unit – India
6th Floor, Tower-2
Jeevan Bharati Building
Connaught Place
New Delhi – 110001, India

Official Website: fiuindia.gov.in

XI. PRINCIPAL OFFICER AND PERSON RESPONSIBLE FOR OVERALL COMPLIANCE

For implementation of this Policy and compliance with applicable PMLA/AML/CFT obligations, the following person shall be responsible:

Name: Mudit Goyal
Capacity: Individual SEBI Registered Research Analyst
SEBI Registration No.: INH000013022
Designation for AML/PMLA purposes: Principal Officer
Designated Director / Person responsible for overall PMLA compliance: Mudit Goyal
Email: support@muditgoyal.co.in
Phone: +91 9958855400
Address: Flat No. 801, Tower-J, Plot No. GC-03K/GH-03, Greater Noida West, VVIP Homes, Sector-16C, Noida, Gautam Buddha Nagar, Uttar Pradesh – 201301

The required particulars and any changes therein shall be communicated to FIU-IND and/or any other authority wherever required under applicable law.

XII. RESPONSIBILITIES OF THE PRINCIPAL OFFICER

The Principal Officer shall:

  1. Oversee implementation of the AML/CFT framework.
  2. Have timely access to client identification, KYC, CDD, payment and other relevant information.
  3. Assess potentially suspicious transactions or activities.
  4. Ensure that suspicious transactions are reported to FIU-IND where required.
  5. Maintain appropriate confidentiality in relation to suspicious-transaction reporting.
  6. Ensure maintenance and preservation of records required under applicable law.
  7. Respond appropriately and promptly to requests for information from SEBI, FIU-IND, RAASB and other competent authorities.
  8. Monitor changes in applicable PMLA, PML Rules, SEBI guidelines and other AML/CFT requirements and implement necessary changes.
  9. Ensure appropriate review of the effectiveness of this Policy.

XIII. PERSON RESPONSIBLE FOR OVERALL PMLA COMPLIANCE / DESIGNATED DIRECTOR

Mudit Goyal shall be responsible for overall compliance with the obligations imposed under the applicable provisions of the PMLA, PML Rules and this Policy.

He shall ensure, among other things, that:

  1. Required systems and procedures for CDD, monitoring and reporting are maintained.
  2. Statutory records are appropriately maintained and preserved.
  3. Appropriate cooperation is extended to FIU-IND, SEBI and other competent authorities.
  4. Material deficiencies identified in the AML/CFT framework are addressed promptly.
  5. This Policy is kept updated with applicable regulatory requirements.

XIV. CLERICAL AND OFFICE-ADMINISTRATIVE SUPPORT

Mudit Goyal may obtain assistance from persons performing routine clerical, operational or office-administrative functions.

Such administrative support persons shall:

  • have no role in formulation of research views or recommendations;
  • not prepare or issue research reports;
  • not provide investment recommendations or research services;
  • not undertake client-facing research, sales or relationship-management functions; and
  • not independently communicate research recommendations to clients or the public.

Persons who perform only clerical or office-administrative functions with no connection to research services and no client contact shall be treated in accordance with the exclusions and requirements provided under the applicable SEBI Research Analyst framework.

No particular clerical or administrative support person is required to be identified by name in this Policy merely by reason of providing such limited assistance.

If the role of any such person changes so that the person participates in research services or client/public-facing functions, the applicable qualification, certification and other regulatory requirements shall be reviewed before permitting such functions.

XV. HIRING, TRAINING AND AWARENESS

Where any employee or other person is engaged in a role to which AML/CFT obligations apply, appropriate screening and training shall be undertaken having regard to the nature of the person's duties.

Relevant persons shall, where applicable, be made aware of:

  1. AML/CFT obligations.
  2. KYC and CDD requirements.
  3. Identification of suspicious transactions.
  4. Confidentiality and prohibition against tipping off.
  5. Record-maintenance requirements.
  6. Escalation of suspicious activity to the Principal Officer.

Administrative personnel whose functions are strictly clerical and unrelated to research services shall nevertheless be instructed to maintain confidentiality and to immediately escalate any unusual or suspicious matter coming to their attention.

XVI. INVESTOR / CLIENT AWARENESS

Where appropriate, clients may be informed that identity verification, KYC information or additional documentation is required in order to comply with legal and regulatory obligations.

No client shall be permitted to avoid applicable KYC or CDD requirements merely on account of inconvenience or unwillingness to provide prescribed information.

XVII. CONFIDENTIALITY AND PROHIBITION AGAINST TIPPING OFF

Information obtained for the purposes of KYC, CDD, AML/CFT monitoring or reporting shall be handled confidentially and used in accordance with applicable law.

Information relating to an STR, proposed STR, regulatory enquiry or suspicion shall not be disclosed to the concerned client or any unauthorised person where such disclosure is prohibited by law or could prejudice an investigation.

XVIII. POLICY REVIEW

This Policy shall be reviewed periodically and whenever there is:

  1. A material amendment to the PMLA or PML Rules;
  2. A relevant change in SEBI regulations or circulars;
  3. A change in applicable FIU-IND requirements;
  4. A material change in the nature, scale or risk profile of the Research Analyst's business; or
  5. Any other regulatory development requiring modification of the Policy.

Necessary amendments shall be implemented promptly so that the Policy remains consistent with applicable laws, rules, regulations and regulatory directions.

XIX. REGULATORY REFERENCES

This Policy shall be read together with, and subject to, the latest applicable versions of:

  • Prevention of Money Laundering Act, 2002;
  • Prevention of Money-Laundering (Maintenance of Records) Rules, 2005;
  • SEBI Act, 1992;
  • SEBI (Research Analysts) Regulations, 2014, as amended;
  • SEBI Master Circular for Research Analysts dated February 6, 2026 and subsequent amendments/circulars;
  • SEBI Master Circular No. SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78 dated June 6, 2024 relating to AML/CFT obligations;
  • applicable SEBI KYC requirements;
  • directions and reporting requirements issued by FIU-IND; and
  • other applicable Government of India, SEBI, FIU-IND and statutory/regulatory requirements, as amended from time to time.

In case of any inconsistency between this Policy and a mandatory statutory or regulatory requirement, the prevailing statutory or regulatory requirement shall apply.

POLICY REVIEW

The Policy shall be reviewed periodically and amended whenever necessary to remain consistent with applicable laws, rules, regulations and regulatory directions.

For Mudit Goyal – SEBI Registered Research Analyst

Mudit Goyal
SEBI Reg. No.: INH000013022

Place: Noida, Uttar Pradesh