KYC-AML Guideline

Nu Investors Technologies Private Limited had designed this policy of PMLA and effective AML program to prohibit and actively prevent the money laundering or the funding of terrorist or criminal activities or flow of illegal money or hiding money to avoid taxes.

The Directives as outlined below provide a general background and summary of the main provisions of the applicable anti-money laundering and anti-terrorist financing legislations in India. They also provide guidance on the practical implications of the Prevention of Money Laundering Act, 2002 (PMLA). The Directives also set out the steps that NU or its representatives shall implement to discourage and to identify any money laundering or terrorist financing activities.

These Directives are intended for use primarily by intermediaries registered under Section 12 of the Securities and Exchange Board of India Act, 1992 (SEBI Act), Stock Exchanges, Depositories and other recognised entities under the SEBI Act and Regulations and rules thereunder. While it is recognized that a “one-size-fits-all” approach may not be appropriate for the securities industry in India, each registered intermediary shall consider the specific nature of its business, organizational structure, type of clients and transactions, etc. when implementing the suggested measures and procedures to ensure that they are effectively applied. The overriding principle is that they shall be able to satisfy themselves that the measures taken by them are adequate, appropriate and abide by the spirit of such measures and the requirements as enshrined in the PMLA.

1. Background

As per the provisions of PMLA and the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 (PML Rules), as amended from time to time and notified by the Government of India, every reporting entity (which includes intermediaries registered under section 12 of the SEBI Act, i.e. a stock-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, asset management company, depository participant, merchant banker, portfolio manager, investment adviser and any other intermediary associated with the securities market and registered under Section 12 of the SEBI Act and stock exchanges), shall have to adhere to the client account opening procedures, maintenance records and reporting of such transactions as prescribed by the PMLA and rules notified there under.

The PML Rules empower SEBI to specify the information required to be maintained by the intermediaries and the procedure, manner and form in which it is to be maintained. It also mandates the reporting entities to evolve an internal mechanism having regard to any guidelines issued by the regulator for detecting the transactions specified in the PML Rules and for furnishing information thereof, in such form as may be directed by SEBI.

The PMLA inter alia provides that violating the prohibitions on manipulative and deceptive devices, insider trading and substantial acquisition of securities or control as provided in Section 12A read with Section 24 of the SEBI Act will be treated as a scheduled offence under schedule B of the PMLA.

2. Policies and Procedures to Combat Money Laundering and Terrorist Financing

2.1 Essential Principles

These Directives have taken into account the requirements of the PMLA as applicable to the intermediaries registered under Section 12 of the SEBI Act. The detailed directives have outlined relevant measures and procedures to guide the registered intermediaries in preventing ML and TF. Some of these suggested measures and procedures may not be applicable in every circumstance. NU shall consider carefully the specific nature of its business, organizational structure, type of client and transaction, etc. to satisfy itself that the measures taken by it are adequate and appropriate and follow the spirit of the suggested measures and the requirements as laid down in the PMLA and guidelines issued by the Government of India from time to time.

In case there is a variance in Client Due Diligence (CDD)/ Anti Money Laundering (AML) standards specified by SEBI and the regulators of the host country, branches/overseas subsidiaries of NU are required to adopt the more stringent requirements of the two.

If the host country does not permit the proper implementation of AML/CFT measures consistent with the home country requirements, financial groups shall be required to apply appropriate additional measures to manage the ML/TF risks, and inform SEBI.

2.2 Obligation to establish policies and procedures

Global measures taken to combat drug trafficking, terrorism and other organized and serious crimes have all emphasized the need for financial institutions, including securities market intermediaries, to establish internal procedures that effectively serve to prevent and impede money laundering and terrorist financing. The PMLA is in line with these measures and mandates that NU ensure the fulfilment of the aforementioned obligations.

The term “group” shall have the same meaning assigned to it in clause (cba) of sub-rule (1) of Rule 2 of the PML Rules as amended from time to time. Groups shall implement group-wide policies for the purpose of discharging obligations under Chapter IV of the PMLA.

Financial groups shall be required to implement group wide programmes for dealing with ML/TF, which shall be applicable, and appropriate to, all branches and majority owned subsidiaries of the financial group as under:

• a) policies and procedures for sharing information required for the purposes of CDD and ML/TF risk management;
• b) the provision, at group level compliance, audit, and/or AML/CFT functions, of customer, account, and transaction information from branches and subsidiaries when necessary for AML/CFT purposes. This shall include information and analysis of transactions or activities which appear unusual (if such analysis was done); similar provisions for receipt of such information by branches and subsidiaries from these group level functions when relevant and appropriate to risk management; and
• c) adequate safeguards on the confidentiality and use of information exchanged, including safeguards to prevent tipping-off.

To be in compliance with these obligations, the senior management of NU shall be fully committed to establishing appropriate policies and procedures for the prevention of ML and TF and ensuring their effectiveness and compliance with all relevant legal and regulatory requirements. The registered intermediaries shall:

• i. issue a statement of policies and procedures and implement, on a group basis where applicable, for dealing with ML and TF reflecting the current statutory and regulatory requirements;
• ii. ensure that the content of these Directives are understood by all staff members;
• iii. regularly review the policies and procedures on the prevention of ML and TF to ensure their effectiveness. Further, in order to ensure the effectiveness of policies and procedures, the person doing such a review shall be different from the one who has framed such policies and procedures;
• iv. adopt client acceptance policies and procedures which are sensitive to the risk of ML and TF;
• v. undertake CDD measures to an extent that is sensitive to the risk of ML and TF depending on the type of client, business relationship or transaction;
• vi. have a system in place for identifying, monitoring and reporting suspected ML or TF transactions to the law enforcement authorities; and
• vii. develop staff members’ awareness and vigilance to guard against ML and TF.

2.3 Policies and procedures to combat ML and TF shall cover:

• i. Communication of group policies relating to prevention of ML and TF to all management and relevant staff;
• ii. Client acceptance policy and client due diligence measures, including requirements for proper identification;
• iii. Maintenance of records;
• iv. Compliance with relevant statutory and regulatory requirements;
• v. Co-operation with the relevant law enforcement authorities, including the timely disclosure of information;
• vi. Role of internal audit or compliance function to ensure compliance with the policies, procedures, and controls relating to the prevention of ML and TF;
• vii. The internal audit function shall be independent, adequately resourced and commensurate with the size of the business and operations.

3. Written Anti Money Laundering Procedures

3.1 What is Money Laundering

Money Laundering involves disguising financial assets so that they can be used without detection of the illegal activity that produced them. Through Money laundering, the laundered transforms the monetary proceeds derived from criminal activity into funds with an apparently legal source.

As per Section (3) of the PMLA Act, 2002 enacted in the January 2003 and came to force on 01st July, 2005 defines Money Laundering as under:

Whosoever directly or indirectly attempts to indulge or knowingly assists or knowingly is a party or is actually involved in any process or activity connected with the proceeds of crime and projecting it as untainted property shall be guilty of offence of Money laundering.

3.2 Prevention of Money Laundering Act

The prevention of Money Laundering Act, 2002 (PMLA) has been brought into force with effect from 01st July, 2005. As per the PMLA, every Banking Company, Financial institution and Intermediaries shall have to maintain a record of all the transactions. For the purpose of PMLA, transactions include:

• 1. All cash transactions of the value of more than Rs. 10 Lakhs or its equivalent in foreign currency.
• 2. All series of Cash transactions integrally connected to each other which have been valued below Rs. 10 lakhs or equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds an amount of Rs. 10 lakhs rupees or its equivalent in foreign currency.
• 3. All suspicious transactions whether or not made in cash and including, interalia, credits or debits into from any non-monetary account such as demat account, security account maintained by the registered intermediary.

“Suspicious Transactions” means a transaction whether or not made in Cash which to a person acting in good faith:

• Gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or
• Appears to be made in circumstances of unusual or unjustified complexity; or
• Appears to have no economic rationale or bonafide purpose.

3.3 Financial Intelligence Unit (FIU)-India

The Government of India set up Financial Intelligence Unit – India (FIU – IND) on November 18, 2004 as the central national agency responsible for receiving, processing, analyzing and disseminating information relating to suspect financial transactions. FIU – IND is also responsible for coordinating and strengthening efforts of national and international intelligence, investigation and enforcement agencies in pursuing the global efforts against money laundering and related crimes. FIU – IND is an independent body to report directly to the Economic Intelligence Council (EIC) headed by the finance minister.

3.4 Client Due Diligence Process parameters

NU shall adopt written procedures to implement the anti-money laundering provisions as envisaged under the PMLA. Such procedures shall include inter alia, the following four specific parameters which are related to the overall ‘Client Due Diligence Process’:

• a. Policy for acceptance of clients;
• b. Procedure for identifying the clients;
• c. Risk Management;
• d. Monitoring of Transactions.

4. Implementation of this Policy

4.1 Client Due Diligence (CDD)

Client Due Diligence means due diligence carried out on a client referred to in clause (ha) of sub-section (1) of section 2 of the PMLA using reliable and independent sources of identification. The CDD shall have regard to the money laundering and terrorist financing risks and the size of the business and shall include policies, controls and procedures, approved by the senior management, to enable the reporting entity to manage and mitigate the risk that have been identified either by the registered intermediary or through national risk assessment.

The CDD measures comprise the following:

• i. Obtaining sufficient information in order to identify persons who beneficially own or control the securities account.
• ii. Identify the clients, verify their identity using reliable and independent sources of identification, obtain information on the purpose and intended nature of the business relationship, where applicable.
• iii. Verify the client’s identity using reliable, independent source documents, data or information.
• iv. Identifying beneficial ownership and control — determine which individual(s) ultimately own(s) or control(s) the client:
  • a) Where the client is a company: the beneficial owner is the natural person(s) who has a controlling ownership interest or who exercises control through other means. “Controlling ownership interest” means ownership of or entitlement to more than 10% of shares or capital or profits.
  • b) Where the client is a partnership firm: the beneficial owner is the natural person(s) who has ownership of/entitlement to more than ten percent of capital or profits or who exercises control through other means.
  • c) Where the client is an unincorporated association or body of individuals: the beneficial owner is the natural person(s) who has ownership of or entitlement to more than fifteen percent of the property or capital or profits.
  • d) Where no natural person is identified under (a) or (b) or (c) above, the beneficial owner is the relevant natural person who holds the position of senior managing official.
  • e) Where the client is a trust: identification shall include the author of the trust, the trustee, the beneficiaries with 10% or more interest in the trust, settlor, protector and any other natural person exercising ultimate effective control.
  • f) Where the client or the owner of the controlling interest is an entity listed on a stock exchange in India, or a subsidiary of such listed entities, it is not necessary to identify and verify the identity of any shareholder or beneficial owner.
  • g) Applicability for foreign investors: NU dealing with foreign investors may be guided by SEBI Master Circular SEBI/HO/AFD-2/CIR/P/2022/175 dated December 19, 2022 and amendments thereto.
  • h) The Stock Exchanges and Depositories shall monitor the compliance through half yearly internal audits.
• v. Verify the identity of the beneficial owner, corroborating the information provided.
• vi. Understand the nature of business, ownership and control structure of the client.
• vii. Conduct ongoing due diligence and scrutiny throughout the course of the business relationship.
• viii. NU shall review CDD measures when there are suspicions of money laundering or financing of terrorism.
• ix. NU shall periodically update all documents, data or information collected under CDD, particularly for high-risk clients.
• x. NU shall register the details of a client, in case of client being a non-profit organisation, on the DARPAN Portal of NITI Aayog.
• xi. Where NU suspects transactions relate to money laundering or terrorist financing and believes CDD would tip-off the client, NU shall not pursue the CDD process and shall instead file a STR with FIU-IND.

No transaction or account-based relationship shall be undertaken without following the CDD procedure.

4.2 Policy for acceptance of clients

NU does have client acceptance policies and procedures that aim to identify the types of clients that are likely to pose a higher-than-average risk of ML or TF. The following safeguards are to be followed while accepting the clients:

• i. NU does not allow the opening of or keeping any anonymous account or account in fictitious names.
• ii. Factors of risk perception of the client are clearly defined having regard to clients’ location, nature of business activity, trading turnover etc. The parameters shall enable classification of clients into low, medium and high risk.
• iii. NU shall undertake enhanced due diligence measures for Clients of Special Category (CSC), which include:
  • a. Non-resident clients;
  • b. High net-worth clients;
  • c. Trust, Charities, NGOs and organizations receiving donations;
  • d. Companies having close family shareholdings or beneficial ownership;
  • e. Politically Exposed Persons (PEPs);
  • f. Clients in high-risk countries;
  • g. Non face to face clients;
  • h. Clients with dubious reputation as per public information available.
• iv. Documentation requirements depending on the perceived risk and having regard to PML Rules.
• v. Ensure that an account is not opened where the NU is unable to apply appropriate CDD measures.
• vi. The circumstances under which the client is permitted to act on behalf of another person/entity shall be clearly laid down.
• vii. Necessary checks to be put into place before opening an account to ensure that the identity of the client does not match with any person having known criminal background.
• viii. The CDD process shall necessarily be revisited when there are suspicions of ML/TF.

4.3 Client identification procedure

The KYC policy shall clearly spell out the client identification procedure (CIP). NU shall be in compliance with the following requirements:

• i. NU shall proactively put in place appropriate risk management systems to determine whether their client or potential client or the beneficial owner is a PEP.
• ii. NU is required to obtain senior management approval for establishing business relationships with PEPs.
• iii. NU shall also take reasonable measures to verify the sources of funds as well as the wealth of PEPs.
• iv. The client shall be identified using reliable sources including documents/information.
• v. The information must be adequate enough to satisfy competent authorities in future that due diligence was observed.
• vi. Failure by prospective client to provide satisfactory evidence of identity shall be noted and reported to higher authority within the NU.

NU shall formulate and implement a CIP which shall incorporate the requirements of the PML Rules. Irrespective of the amount of investment, no minimum threshold or exemption is available from obtaining the minimum information/documents from clients. No exemption from carrying out CDD exists in respect of any category of clients.

4.4 Reliance on third party for carrying out Client Due Diligence (CDD)

NU may rely on a third party for the purpose of identification and verification of the identity of a client, and determination of whether the client is acting on behalf of a beneficial owner. Such reliance shall be subject to:

• i. NU shall immediately obtain necessary information of such client due diligence carried out by the third party;
• ii. NU shall take adequate steps to satisfy itself that copies of identification data will be made available from the third party upon request without delay;
• iii. NU shall be satisfied that such third party is regulated, supervised or monitored for CDD and record-keeping requirements;
• iv. The third party is not based in a country or jurisdiction assessed as high risk;
• v. NU shall be ultimately responsible for CDD and undertaking enhanced due diligence measures.

5. Risk Management

5.1 Risk-based Approach

NU shall apply a Risk Based Approach (RBA) for mitigation and management of the identified risk and should have policies approved by their senior management, controls and procedures in this regard. The basic principle is that the NU shall adopt an enhanced client due diligence process for higher risk categories of clients. Conversely, a simplified client due diligence process may be adopted for lower risk categories. Low risk provisions shall not apply when there are suspicions of ML/FT.

5.2 Risk Assessment

NU shall carry out risk assessment to identify, assess and take effective measures to mitigate its money laundering and terrorist financing risk with respect to its clients, countries or geographical areas, nature and volume of transactions, payment methods used by clients, etc. The risk assessment shall be documented, updated regularly and made available to competent authorities as required.

The Stock Exchanges and NU shall identify and assess the ML/TF risks that may arise in relation to new products, business practices, and new technologies, and shall ensure:

• a. To undertake the ML/TF risk assessments prior to the launch or use of such products, practices, services, technologies; and
• b. Adoption of a risk based approach to manage and mitigate the risks.

Risk Based Client Categorization

Each client will be marked into three categories — High Risk, Medium Risk and Low Risk — from the point of view of the anti-money laundering laws. The categorization will be based on the following parameters:

• 1. High Net-worth clients
• 2. Trusts / NGOs / Charities receiving donations
• 3. Companies having close family shareholdings
• (The above are considered of High Risk as per SEBI guidelines)

The other parameters are nature of business activity, trading turnover, manner of making payment etc. The high risk client will require regular KYC update. Clients who make the payment on time and take delivery of shares can be considered as Low risk clients. Intra-day clients or speculative clients whose turnover is not in line with the Financials declared are considered as Medium risk clients. Client doing large activity in Dormant Account, trading on a regular basis in illiquid scrips in large volume, those who have defaulted in the past and have suspicious background are to be considered as High Risk Category.

5.3 Monitoring of Transactions

Regular monitoring of transactions is vital for ensuring effectiveness of the AML procedures. NU shall pay special attention to all complex unusually large transactions/patterns which appear to have no economic purpose. NU may specify internal threshold limits for each class of client accounts. The background including all documents pertaining to such transactions and purpose thereof shall be examined carefully and findings shall be recorded in writing.

NU shall ensure a record of the transactions is preserved and maintained in terms of Section 12 of the PMLA and that transactions of a suspicious nature are reported to the Director, FIU-IND.

5.4 Suspicious Transaction Monitoring and Reporting

Suspicious transactions involve funds derived from illegal activities or transactions intended to hide or disguise funds derived from illegal activities. Criteria giving rise to suspicion include but are not limited to:

• a) Complex/unusually large transactions with no economic purpose
• b) Client having suspicious background or links with known criminals
• c) Clients whose identity verification seems difficult
• d) Client appears not to co-operate
• e) Use of different accounts alternatively
• f) Sudden activity in dormant accounts
• g) Multiple accounts with no rationale
• h) Unexplained transfers between multiple accounts
• i) Asset management services where sources of funds is not clear
• j) Substantial increase in business without apparent cause
• k) Activity materially inconsistent with declared business
• l) Unusual transactions by CSCs and shell corporations
• m) Transactions giving rise to suspicion of proceeds of crime
• n) Transactions that appear to be insider trading
• o) Transactions that reflect likely market manipulations
• p) Suspicious off market transactions
• q) Value of transaction just under the reporting threshold in an apparent attempt to avoid reporting
• r) Inconsistency in payment patterns
• s) Trading activity in accounts of high risk clients
• t) Accounts used as ‘pass through’ for funds transfers/layering purposes
• u) Large deals at prices away from the market
• v) Purchases made in one client’s account and later transferred to a third party through off market transactions
• w) Multiple transactions of value just below the threshold limit

Any suspicious transaction shall be immediately notified to the Designated/Principal Officer within the NU. The notification may be done in the form of a detailed report with specific reference to the clients, transactions and the nature/reason of suspicion. It shall be ensured that the client is not told of the report/suspicion. The Designated/Principal Officer and other appropriate compliance, risk management staff shall have timely access to client identification data and CDD information, transaction records and other relevant information.

Registered intermediaries shall report all attempted transactions in STRs, even if not completed by clients, irrespective of the amount of the transaction.

6. Record Management

6.1 Information to be maintained

NU are required to maintain and preserve the following information in respect of transactions referred to in Rule 3 of PML Rules:

• i. the nature of the transactions;
• ii. the amount of the transaction and the currency in which it is denominated;
• iii. the date on which the transaction was conducted; and
• iv. the parties to the transaction.

6.2 Record Keeping

NU shall ensure compliance with the record keeping requirements contained in the SEBI Act, 1992, Rules and Regulations, PMLA as well as other relevant legislation. NU shall maintain such records as are sufficient to permit reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of criminal behaviour.

NU shall put in place a system of maintaining proper record of the nature and value of transactions which has been prescribed under Rule 3 of PML Rules:

• i. all cash transactions of the value of more than 10 lakh rupees or its equivalent in foreign currency;
• ii. all series of cash transactions integrally connected which have been individually valued below rupees 10 lakh where the monthly aggregate exceeds ten lakh rupees;
• iii. all cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine;
• iv. all suspicious transactions whether or not made in cash.

6.3 Retention of Records

NU shall take appropriate steps for proper maintenance and preservation of records in a manner that allows easy and quick retrieval. Records mentioned in Rule 3 of PML Rules have to be maintained and preserved for a period of maximum 8 years from the date of transactions. Records evidencing the identity of clients and beneficial owners as well as account files and business correspondence shall be maintained for a period of maximum 8 years after the business relationship has ended or the account has been closed, whichever is later.

7. Employees Hiring, Training and Monitoring

7.1 Hiring of Employees

• 1. Department Heads shall be involved in hiring and shall adequately carry out screening procedures.
• 2. Bona fides of employees are checked to ensure no link with terrorist or other anti-social organizations.
• 3. Candidate references shall be verified.
• 4. Background of the candidate should be clean.
• 5. Third party verification should be done if necessary.
• 6. Candidate should appear for the skilled test depending on the exposure.
• 7. Candidate should be aware of PMLA 2002 guidelines. Proper training should be given if he/she is not aware.

7.2 Training on prevention of Money Laundering

The registered intermediaries shall have an ongoing employee training programme so that the members of the staff are adequately trained in AML and CFT procedures. Training requirements shall have specific focuses for frontline staff, back office staff, compliance staff, risk management staff and staff dealing with new clients.

7.3 Monitoring Employee Conduct and Accounts

We will subject employee Accounts to the same AML procedures as customer accounts, under the supervision of the Principal Officer. We will also review the AML performance of supervisors as part of their annual performance review. The Principal Officer’s Accounts will be reviewed by the Board of Directors.

8. Investor Education

Implementation of AML/CFT measures requires NU to demand certain information from investors which may be of personal nature. This can sometimes lead to raising of questions by the client with regard to the motive and purpose of collecting such information. There is a need for NU to sensitize their clients about these requirements. NU shall prepare specific literature/pamphlets to educate the client of the objectives of the AML/CFT programme.

9. Procedure for freezing of funds, financial assets or economic resources or related services

NU ensures that in terms of Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA) and amendments thereto, we do not have any accounts in the name of individuals/entities appearing in the lists circulated by the United Nations Security Council (UNSC). The Government of India has outlined a procedure through an order dated February 02, 2021 for strict compliance, further amended vide Gazette Notification dated June 08, 2021, with Corrigendum dated March 15, 2023 and April 22, 2024.

10. Procedure for implementation of Section 12A of the Weapons of Mass Destruction Act, 2005

The Government of India, Ministry of Finance has issued an order dated January 30, 2023 detailing the procedure for implementation of Section 12A of the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 (“WMD Act”). In terms of Section 12A of the WMD Act, the Central Government is empowered to freeze, seize or attach funds or other financial assets owned or controlled by designated persons, and prohibit any person from making funds available for the benefit of such designated persons.

NU shall comply with the procedure laid down and shall:

• i. Maintain the Designated List and update it without delay;
• ii. Verify if particulars of entities/individuals match with the Designated List and immediately inform the Central Nodal Officer (CNO) — The Director FIU-INDIA (Tel: 011-23314458, Email: [email protected]);
• iii. Run a check at the time of establishing a relation with a client and on a periodic basis;
• iv. Send a copy of the communication to the Nodal Officer of SEBI ([email protected]);
• v. Prevent such individual/entity from conducting financial transactions under intimation to the CNO;
• vi. File a Suspicious Transaction Report (STR) with the FIU-IND.

11. List of Designated Individuals / Entities

The Ministry of Home Affairs declares lists of designated individuals/terrorists. NU take note of such lists as communicated by SEBI. Updated lists can be accessed at the UN website at https://press.un.org/en/content/press-release. NU ensures that accounts are not opened in the name of anyone in said list and continuously scans all existing accounts.

NU does have a tool for effective implementation of name screening to meet the sanctions requirements. Full details of accounts bearing resemblance with any designated individuals/entities shall immediately be intimated to the Central Nodal Officer for the UAPA (Fax: 011-23092551, Tel: 011-23092548, Email: [email protected]) and to SEBI and FIU-IND.

12. Jurisdictions that do not or insufficiently apply the FATF Recommendations

FATF Secretariat releases public statements and places jurisdictions under increased monitoring to address strategic deficiencies. NU shall take into account the risks arising from the deficiencies in AML/CFT regimes of the jurisdictions included in the FATF Statements. However, NU is not precluded from having legitimate trade and business transactions with such countries and jurisdictions.

13. Reporting to Financial Intelligence Unit-India

In terms of the PML Rules, NU shall report information relating to cash and suspicious transactions to:

14. Designation of Officers — Appointment of Principal Officer and Designated Director

To ensure proper discharge of legal obligations, the Principal Officer would act as a central reference point for reporting suspicious transactions and shall have access to senior management. The registered intermediaries shall also designate a ‘Designated Director’ to ensure overall compliance with the obligations imposed under Chapter IV of the PMLA.

	Designated Director	Principal Officer
Name	Brajesh Upadhyay	Deepak Sharma
Office Address	Galaxy, Unit No. 603, A Wing, Everest Grand, Mahakali Caves Road, Opp. Ahura Centre, Andheri East, Chakala Midc, Mumbai, Maharashtra, India – 400093	Galaxy, Unit No. 603, A Wing, Everest Grand, Mahakali Caves Road, Opp. Ahura Centre, Andheri East, Chakala Midc, Mumbai, Maharashtra, India – 400093
Mobile Number	8040011316	08040011314
Email ID	[email protected]	[email protected]
Appointment date	27th April 2026	14th April 2026

Reporting Obligations

• i. The Cash Transaction Report (CTR) for each month shall be submitted to FIU-IND by 15th of the succeeding month;
• ii. The Suspicious Transaction Report (STR) shall be submitted within 7 days of arriving at a conclusion that the transaction is suspicious;
• iii. The Non Profit Organization Transaction Reports (NTRs) for each month shall be submitted to FIU-IND by 15th of the succeeding month;
• iv. The Principal Officer will be responsible for timely submission of CTR, STR and NTR;
• v. Utmost confidentiality shall be maintained in filing of CTR, STR and NTR;
• vi. No NIL reporting needs to be made to FIU-IND in case there are no reportable transactions;
• vii. NU, its Directors, officers and all employees shall ensure that the fact of maintenance and furnishing of information is kept confidential;
• viii. NU shall not put any restrictions on operations in accounts where an STR has been made. NU shall be prohibited from “tipping off” — disclosing the fact that an STR is being reported, before, during and after the submission;
• ix. NU shall file STR irrespective of the amount of transaction and/or the threshold limit if they have reasonable grounds to believe that the transactions involve proceeds of crime.

Review of the PMLA Policy & Procedures: The policy shall be reviewed annually as and when required by the Management and also implement the change after any change in the Anti Money Laundering Act 2002 or change in any other act, bye-laws, rules, regulations of SEBI or in any statutory and regulatory government department.

This policy has been considered and adopted by the Board of Directors of the Company.