Anti-Money Laundering (AML) Policy

Bhakti Wealth > Anti-Money Laundering (AML) Policy

Bhakti Wealth
SEBI Registration Number: [Insert SEBI RA Number here]
Address: Office No. 424, Apollo Tower, Mahatma Gandhi Rd, New Palasia, Indore, Madhya Pradesh 452001

Introduction

This document outlines the Anti-Money Laundering (AML) Policy of Bhakti Wealth, a SEBI-registered Research Analyst Firm. This policy complies with the Prevention of Money Laundering Act, 2002 (PMLA) and its rules, along with SEBI guidelines. The purpose of this policy is to ensure that the operations of Bhakti Wealth are not misused for money laundering or terrorist financing activities.

Objective

The primary objective of this policy is to create a robust framework for detecting, preventing, and reporting suspicious transactions, while ensuring full compliance with applicable laws and regulations.

This policy covers:

  • Acceptance of clients.
  • Identification and verification of clients.
  • Client Due Diligence (CDD) process.
  • Transaction monitoring and reporting, including Suspicious Transaction Reporting (STR).

Client Due Diligence (CDD)

Policy for Acceptance of Clients

  • No account will be opened in a fictitious or anonymous name.
  • Clients will be accepted only if valid KYC documentation is provided.
  • Accounts will not be opened if adequate due diligence cannot be applied.
  • Clients’ identities will be verified against lists of banned persons/entities issued by SEBI, stock exchanges, or government authorities.
  • Risk assessments will be conducted, including checks against sanctions lists maintained by the United Nations Security Council Resolutions (UNSCRs).

Procedure for Identifying Clients

  • Only reliable and independent sources will be used for client verification.
  • All KYC documents will be verified and discrepancies, if any, will be escalated.
  • Ongoing due diligence will be performed by periodically updating client records.

Maintenance of Records

  • All records relating to client identity and transactions will be maintained for a minimum of 10 years, or until resolution of any regulatory action.

Monitoring and Reporting of Transactions

Monitoring Transactions

  • Bhakti Wealth only collects service fees from clients.
  • Fees will be accepted only through official banking channels.
  • No cash transactions are permitted.

Reporting Suspicious Transactions

  • Any suspicious activity will be reported to the Compliance Officer with full details of the client, nature of the transaction, and reasons for suspicion.
  • The Compliance Officer will file Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) with the Financial Intelligence Unit – India (FIU-IND) in a timely manner.
  • Strict confidentiality will be maintained while reporting.

Roles and Responsibilities

Principal Officer

  • Communicate the AML policy to all employees.
  • Ensure overall compliance with AML regulations.
  • Report suspicious transactions to FIU-IND.
  • Provide clarification to staff regarding AML obligations.

Onboarding Staff

  • Follow KYC and CDD procedures diligently during onboarding.
  • Report any suspicious behavior or transaction.
  • Ensure compliance with AML requirements at all times.

Communication of Policy

  • All relevant employees will be provided a copy of this AML Policy.
  • Annual training sessions will be conducted to build awareness and ensure compliance.

Compliance and Cooperation

Bhakti Wealth will:

  • Comply with all statutory and regulatory requirements.
  • Cooperate fully with regulators, SEBI, and law enforcement authorities.
  • Provide necessary information to competent authorities upon request.

Review of Policy

This AML Policy will be reviewed periodically to ensure its continued relevance, effectiveness, and compliance with updated SEBI guidelines and regulatory changes.