Legal

AML Policy

1. Introduction

Company

Commodity Samachar Securities Private Limited (CSSPL)

SEBI Research Analyst Registration

INH000017781

Registered/Correspondence Address

27 by 1 B, Office No. 311, Building, Suratwala Mark Plazzo, Infotech Park, Hinjawadi, Haveli, Pune, Maharashtra – 411057

Official Email

ankit@commoditysamachar.com

Validity

Jul 22, 2024 – Perpetual

2. Purpose & Scope

Commodity Samachar Securities Private Limited (“CSSPL”, “the Company”) is committed to full compliance with the Prevention of Money-Laundering Act, 2002 (PMLA), PML Rules, 2005, and applicable SEBI AML/CFT directions and master circulars for intermediaries, as relevant to Research Analysts (RAs).

This Policy establishes a risk-based framework to prevent the use of CSSPL’s research services and payment channels for money laundering, terrorism financing, sanctions evasion, fraud, or other unlawful activity.

Note: While Research Analysts do not handle client trading accounts, CSSPL voluntarily applies robust AML/CFT standards to client onboarding, payments, refunds, vendor relationships, and business counterparties.

3. Governance & Roles

• Board Oversight: The Board approves this Policy and reviews AML/CFT effectiveness at least annually.
• Designated Director (PML Rules): Mr. Ankit Kapoor
• Principal Officer (PML Rules) & Compliance Officer (SEBI): Mr. Ankit Kapoor
  Responsible for AML/CFT implementation, risk assessment, monitoring, internal reporting, and timely submission of suspicious transaction reports (STRs) to FIU-IND via FINGate 2.0, where applicable. The Company is under the process of getting the FIU registration.
• Lines of Defence:
  1. Business teams perform Customer Due Diligence and first-level monitoring.
  2. Compliance independently oversees, tests, and reports.
  3. Internal/independent review provides periodic assurance.

4. Risk-Based Approach (RBA)

• Enterprise-Wide Risk Assessment (EWRA): Conducted at least annually covering client types, geographies, delivery channels (online subscriptions), products (research reports/advisories), payment methods, third parties, and technology risks.
• Risk Categorization: Clients, partners, and counterparties are classified Low/Medium/High risk using defined criteria (e.g., PEPs, i.e. Politically Exposed Persons, high-risk jurisdictions, complex ownership, unusual payment patterns).
• Enhanced Due Diligence (EDD): Applied to high-risk cases, PEPs, adverse-media hits, or sanctions proximity. Approval by Principal Officer required.

5. Customer Acceptance & CDD/KYC

When CDD is performed: prior to onboarding subscribers to paid plans, signing T&C and MITC, institutional/corporate access or entering material vendor/outsourcing arrangements that touch client money or data.

Minimum KYC (natural persons)

• Full name, DOB, nationality, residence status
• Govt ID (PAN mandatory for Indian residents; passport/OCI for NRIs/foreign nationals)
• Address proof and recent photograph (digital acceptable)
• Contact details (email, mobile), occupation/source of funds declaration
• Payment instrument ownership confirmation; only bank/UPI/authorized gateways in client’s own name are permitted.

Non-individuals

• Certificate of incorporation/registration, PAN, constitutional docs, address proof
• Beneficial Ownership identification (≥10% ownership or control, as applicable)
• Board/authorized signatory list and KYC of authorized persons
• GSTIN (if applicable).

Additional rules

• No cash acceptance.
• Third-party payments not allowed; refunds only to original source.
• For non-face-to-face/online onboarding: apply EDD—e-KYC, penny-drop/micro-debit checks, and liveness/OTP controls.
• Sanctions Screening: Names screened against UN/Indian/other applicable sanctions lists and adverse media at onboarding and periodically.
• PEPs: Senior management approval, EDD, and ongoing enhanced monitoring.

6. Ongoing Monitoring

• Automated/manual reviews of:
  • Mismatch between client profile and subscription/payment behaviour
  • Multiple or rapid plan upgrades/cancellations with refund requests
  • Payments from/high activity while masking location (VPN/TOR) or from high-risk jurisdictions
  • Use of company cards by unrelated individuals; corporate subscriptions inconsistent with business profile
  • Affiliates/referrers requesting unusual fee splits or routing through layered entities
• Trigger-based refresh of KYC for material changes or risk re-ratings.
• Periodic name-screening rechecks for active clients and relevant third parties.

7. Red Flags (Illustrative)

• Identity inconsistencies or reluctance to provide KYC; forged/altered documents
• Payment instruments not in the subscriber’s name; frequent refunds to different accounts
• Subscriptions purchased from/for sanctioned or embargoed locations
• Attempts to route payments via crypto, cash proxies, or unregulated wallets
• Pressure to expedite onboarding with unusual urgency or incentives
• Adverse media on financial crime, bribery, terrorism, or market abuse.

8. Record Keeping & Data Protection

• Retention: CDD/transaction and screening records retained for 5 years from end of relationship/transaction—longer where required by law or on request by regulators/law-enforcement.
• Confidentiality: STR/AML records are confidential; access on a strict need-to-know basis.
• Data Security: Personal data handled per applicable data-protection laws; stored securely with access controls and audit trails.

9. Regulatory Reporting

• The Principal Officer evaluates alerts.
• CSSPL will cooperate with SEBI/FIU-IND/LEAs and maintain confidentiality prohibitions (no “tipping off”).
• Cash Transaction Reports (CTR) are not expected because cash is prohibited; any inadvertent cash incident is escalated immediately and reported if legally required.

10. Employee & Partner Controls

• Training: Mandatory AML/CFT induction and at least annual refreshers tailored to RA operations (KYC, screening, red flags, reporting).
• Outsourcing/Partners/Affiliates: Contractual clauses require AML adherence, audit rights, and immediate reporting of suspicious matters.
• Employee Due Diligence: Pre-employment screening proportionate to role; acknowledgment of AML responsibilities and confidentiality.

11. Internal Controls, Testing & Audit

• Documented SOPs for onboarding, screening, monitoring, escalation, STR filing, refunds, vendor/affiliate onboarding, and recordkeeping.
• Independent testing (internal audit/qualified external reviewer) at least annually to assess design and operating effectiveness; findings tracked to closure.
• Issue Escalation: Material issues reported to the Designated Director and the Board with remediation timelines.

12. Disciplinary Measures & Non-Retaliation

• Breaches of this Policy may result in disciplinary action, up to termination and reporting to authorities.
• Good-faith reporting of concerns is protected; retaliation is strictly prohibited.

13. Policy Ownership, Review & Versioning

• Owner: Principal Officer & Compliance Officer – Mr. Ankit Kapoor
• Review Cycle: At least annually or upon regulatory/business changes; Board approval required for amendments.
• Effective Date: 01 October 2025 (supersedes any prior versions).

For Commodity Samachar Securities Private Limited