Anti-Money Laundering (AML) Policy

1. Introduction

This Anti-Money Laundering (AML) Policy is prepared in accordance with the Prevention of Money Laundering Act (PMLA), 2002, and the applicable guidelines issued by SEBI and FIU-IND. It aims to establish a robust framework for identifying, preventing, and reporting potential instances of money laundering and terrorist financing.

2. Scope and Applicability

This policy applies to all employees, representatives, and stakeholders of Money Bells Global Research Services Pvt Ltd. Although the company operates solely as a Research Analyst and does not handle client funds or execute trades, compliance with AML norms remains essential.

3. What Constitutes a Suspicious Transaction?

Involve proceeds of crime

• Are structured to evade legal thresholds
• Lack legitimate economic purpose
• Are unusually complex or opaque
• Appear linked to terrorism financing

4. Client Due Diligence (CDD)

4.1 Client Acceptance Policy

• No accounts will be opened under fictitious, anonymous, or benami names
• Valid KYC documentation (identity and address proof) is mandatory
• Clients will be screened against:
  • SEBI’s Debarred List (BSE)
  • UN 1267 Sanctions List

4.2 Client Identification Process

• Identity verification is completed during onboarding
• KYC documents are securely stored and reviewed
• Discrepancies are escalated immediately for internal review

4.3 Beneficial Ownership

As a non-transactional entity, detailed BO identification lies with the client’s broker. Basic ownership and control information will still be recorded.

5. Transaction Monitoring & Reporting

5.1 Monitoring

• Only fee-based payments are accepted
• All payments must be made through banking channels
• Cash payments are strictly prohibited

5.2 Reporting Thresholds

• Cash transactions above ₹10,00,000 or foreign currency equivalents
• Structured transactions below ₹10,00,000 within a single month
• Any transaction flagged as suspicious, regardless of value

5.3 Reporting Protocol

Suspicious transactions will be reported to:

Director, FIU-IND
Financial Intelligence Unit - India
6th Floor, Hotel Samrat,
Chanakyapuri, New Delhi - 110021

Reports will be submitted in prescribed formats (CTR/STR). Nil reporting is not mandatory if no suspicious activity is observed.

6. Role of the Principal Officer

Mr. Sagar Goel, the Principal Officer, shall:

• Disseminate AML updates to concerned staff
• Receive and assess suspicious activity reports
• Ensure timely submissions to FIU-IND
• Monitor overall compliance and recommend corrective actions

7. Responsibilities of Onboarding & Client-Facing Teams

• Strictly follow KYC and client onboarding protocols
• Escalate any fraudulent or unethical behavior
• Maintain vigilance during client communication

8. Internal Training & Awareness

All client-facing staff will be trained annually. Annual AML refresher training to be conducted every first week of April.

9. Audit & Compliance Oversight

AML procedures are subject to independent audit. Non-compliance will be immediately addressed through corrective measures.

10. Record Keeping

All client-related KYC and identification records shall be retained for a minimum of 10 years, or longer if required by legal proceedings.

11. Review of the Policy

This policy will be reviewed annually or in response to regulatory changes. Updates and implementation are the responsibility of senior management.

📄 Authorized By

Mr. Sagar Goel
SEBI Registered Research Analyst
Money Bells Global Research Services Pvt Ltd
📧 support@moneybells.in