AML / CFT Policy — Vishwesh Diware (SEBI Registered Research Analyst)

1. Purpose & Scope

This AML / CFT Policy (Anti-Money Laundering & Counter Financing of Terrorism) outlines the measures and procedures adopted by Vishwesh Diware (operating under Vishwesh Research) to prevent, detect, and report money laundering, terrorist financing, and suspicious transactions, in compliance with:

• The Prevention of Money Laundering Act, 2002 (PMLA) & rules thereunder;
• SEBI’s Guidelines on AML / CFT (Master Circular, 06 June 2024): NSDL circular PDF.

This policy applies to all clients, transactions, and operational activities performed by or under the supervision of this research analyst.

2. Definitions & Key Terms

• Client / Customer — any person who subscribes to or uses research services.
• Beneficial Owner — natural person(s) who ultimately own or control the client or transaction.
• Know Your Client (KYC) / Client Due Diligence (CDD) — identifying and verifying client identity and beneficial ownership.
• Enhanced Due Diligence (EDD) — additional checks for higher-risk clients or jurisdictions.
• Suspicious Transaction Report (STR) — reporting transactions that appear unusual or inconsistent with a client’s profile.

3. Client Acceptance & KYC / CDD Process

• Client acceptance is subject to verification of documents under KYC norms: identity proof (PAN, Aadhaar, passport, etc.) and address proof (utility bill, bank statement, etc.).
• CDD is done at the onboarding stage, and for existing clients if material changes happen.
• Beneficial ownership must be identified (e.g. in company, trust, partnership) and verified, especially after 2023 changes (ownership thresholds reduced to 10%) — see summary: AZB Partners – SEBI AML/CFT amendments.
• EDD shall apply for high-risk clients, clients from high-risk jurisdictions, politically exposed persons (PEPs), etc.
• No anonymous or fictitious accounts shall be allowed.

4. Risk Assessment

• A risk-based approach is followed — clients, transactions, jurisdictions and service channels are periodically assessed for money laundering / terrorism financing risk.
• High-risk relationships receive enhanced monitoring and review.

5. Monitoring & Reporting

• All transactions and subscription/payment flows are monitored for suspicious or unusual activity.
• A Designated Officer / Compliance Officer is appointed to review and report any suspicious transactions to FIU-India / relevant authorities.
• Reports shall be filed promptly as mandated under PMLA and SEBI guidelines.

6. Record Keeping & Retention

• All client identification, KYC records, transaction logs, and communications shall be retained for at least 5 years (or as required under law).
• Records must be in a manner retrievable and available for regulatory review.

7. Internal Controls & Compliance

• Senior management ensures that procedures, controls, and policies are in place and periodically reviewed.
• Independent audit or compliance review shall be conducted periodically to ensure effectiveness.
• Roles and responsibilities are clearly defined (e.g., compliance officer, nodal officer).

8. Training & Awareness

• Personnel (if any) or associates shall receive periodic training on AML / CFT laws, detection of suspicious transactions, and internal reporting procedures.
• Staff must remain vigilant to detect and escalate unusual patterns.

9. Confidentiality & No Tipping-Off

• Client identity and information are treated confidentially.
• No “tipping-off” to clients regarding investigations or reports shall occur.
• Information may be shared with competent authorities as mandated by law.

10. Review & Amendments

• This Policy is reviewed at least annually or whenever new SEBI / PMLA amendments are made.
• The updated version with effective date is published on the website.

11. Contact & Reporting