PMLA 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 Prajapati Pavan Jitendrabhai, as a SEBI registered Research Analyst vide Registration Number INH000025416.

I. Objective of the PMLA Policy

1. To prevent Prajapati Pavan Jitendrabhai 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 lakhs.

II. Client Due Diligence (CDD) Process

As a part of Client Due Diligence process, Prajapati Pavan Jitendrabhai will:

1. Maintain a record of Know Your Customer (KYC) documents (valid identity proof and address proof) obtained from clients at the time of onboarding.
2. Verify the genuineness of clients by interacting with them before providing advisory services.
3. Maintain proper records of all communications and transactions with clients.

III. Policy for Acceptance of Client

• No account shall be opened in a fictitious or anonymous name.
• No account will be opened if the service fee is offered in cash.
• No account shall be opened where appropriate CDD/KYC measures cannot be applied.
• Client identity will be verified against criminal/sanction lists (including UNSCR lists).
• Each client will be classified as Low, Medium, or High Risk based on:
  • Client location
  • Nature of business activity
  • Payment methods

Clients of Special Category (CSC):

1. Non-resident clients
2. High net-worth clients
3. Trusts, Charities, NGOs
4. Companies with close family shareholding
5. Politically Exposed Persons (PEP)
6. Companies offering foreign exchange
7. Clients in high-risk countries
8. Non face-to-face clients
9. Clients with doubtful reputation

IV. Suspicious Transactions

Indicators of suspicious transactions:

• Difficulty in client identity verification
• Unclear source of funds
• Unusual increase in transactions
• Clients from high-risk jurisdictions
• Large overseas transfers with cash instructions
• Transfers to unrelated third parties
• Unusual transactions by CSC clients

In case of suspicious transactions, a report will be submitted to the Director, Financial Intelligence Unit-India (FIU-IND).

Even attempted or aborted suspicious transactions will be reported, regardless of transaction amount.

V. Monitoring of Transactions

• Special attention to complex or unusually large transactions.
• Internal threshold limits will be defined.
• All related documents and records will be examined and documented.
• Records will be available for auditors, SEBI, FIU-IND, and authorities.
• Records will be preserved for 5 years.

Transactions to be monitored:

1. Cash transactions above Rs. 10 lakh.
2. Multiple connected transactions exceeding Rs. 10 lakh monthly.
3. Transactions involving counterfeit currency or forgery.
4. All suspicious transactions (cash/non-cash).

VI. Record Keeping and Retention

• Maintain records as per SEBI and PMLA regulations.
• Ensure complete audit trail of transactions.
• Maintain details such as:
  • Beneficial owner
  • Source and destination of funds
  • Transaction method
• Records preserved for minimum 5 years.

VII. Information to be Maintained

• Nature of transaction
• Amount and currency
• Date of transaction
• Parties involved

VIII. Reporting to Financial Intelligence Unit-India

Director, FIU-IND
Financial Intelligence Unit-India
6th Floor, Hotel Samrat,
Chanakyapuri, New Delhi – 110021
Website: http://fiuindia.gov.in

IX. Principal Officer and Designated Director

Name: Prajapati Pavan Jitendrabhai
Designation: Research Analyst
Email: pavan.rapidsms@gmail.com
Phone: +91 8758396016

X. Responsibilities of Principal Officer

• Access to all client and CDD data
• Ensure proper implementation of PMLA policy
• Monitor and report suspicious transactions
• Ensure timely data availability to authorities
• Respond to regulatory queries
• Keep staff updated with AML changes

XI. Responsibilities of Designated Director

• Ensure proper record maintenance
• Accountable for non-compliance

XII. Employee Hiring, Training & Investor Education

• Proper employee screening during hiring
• Regular AML/CFT training programs for staff

XIII. Review of Policy

This policy will be reviewed periodically and updated as per applicable laws, regulations, and guidelines.