This Anti-Money Laundering (AML) Policy (the Policy) has been prepared in accordance Prevention of Money Laundering Act, 2002 (PMLA Act).

This Policy also takes into account the provisions of the PMLA Act and other Rules laid down by SEBI, FMC and FIU.

1. OVERVIEW:

Seema Jain always gives credence to move with ethical and lawful manner. And wishes to be at the forefront, towards ensuring compliance with all the regulatory requirements and is committed to maintaining and promoting high ethical standards and business practices.

As an effort in the same direction we have prepared this Anti-Money Laundering Policy & Procedures ("Policy") in order to ensure compliance under the Prevention of Money Laundering Act, 2002.

Seema Jain as a market intermediary under the Prevention of Money Laundering Act, 2002, (“PMLA”) is required to have a system in place for identifying, monitoring and reporting suspected money laundering or terrorist financing transactions to law enforcement authorities. The Policy is intended to establish certain guiding principles for all employees and consultants of Seema Jain.

As per PMLA, every banking company, financial institution and intermediary shall have to maintain a record of all the transactions.

• All cash transactions of the value of more than Rs. 10 lakhs or its equivalent in foreign currency.
• All series of cash transactions integrally connected to each other within one calendar month.
• All suspicious transactions whether or not made in cash.

2. OBJECTIVE:

• Prevent the Organisation from being used for money laundering activities.
• To enable to know/understand the customers/clients.
• To verify the identity, suitability, and risks.
• To adopt and implement KYC, AML and CFT standards.
• To have a proper Customer Due Diligence (CDD) process.
• To monitor and report suspicious transactions.
• To maintain records of all transactions.

3. NEED FOR SUCH POLICIES:

Global measures taken to combat drug trafficking, terrorism and other organized crimes have emphasized the need to establish internal procedures.

4. PRINCIPAL OFFICER:

• Compliance of the provisions of the PMLA and AML Guidelines
• Monitoring the implementation of AML and CFT Policy
• Reporting of Transactions
• Submission of periodical reports

Name: Seema Jain
Designation: Research Analyst
Mail Id: Seemajain2001@Gmail.Com
Contact No.: +91 9810711012

5. CLIENT DUE DILIGENCE (CDD)

• Identifying beneficial owners
• Verifying client identity
• Understanding ownership structure
• Ongoing due diligence
• Periodic updating of documents

6. RELIANCE ON THIRD PARTY FOR CARRYING OUT CLIENT DUE DILIGENCE

Reliance may be placed on a third party for identification and verification of clients and beneficial owners.

7. CLIENT’S ACCEPTANCE POLICY

• No fictitious / Benami accounts
• Clients classified into low, medium, and high risk
• Enhanced due diligence for high-risk clients

8. CLIENT IDENTIFICATION PROCEDURE:

• Identification of PEPs
• Senior management approval
• Verification of source of funds
• Verification of original documents

9. RECORD KEEPING & RETENTION OF RECORDS

• Maintain transaction records for five years
• Preserve customer identification records
• Provide records to authorities on request

10. MONITORING OF TRANSACTIONS:

• Regular monitoring of transactions
• Attention to unusual transactions
• Internal threshold limits

11. RISK PARAMETERS

• Country of residence
• Nature of business
• Trading turnover
• Manner of payment
• Reputation

12. REPORTING TO FINANCIAL INTELLIGENCE UNIT-INDIA:

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

13. REVIEW OF POLICY:

The AML policy will be reviewed as and when new circulars are issued by SEBI or relevant exchanges.