In pursuance of the above provisions, Share Biz Research prohibits and actively prevents money laundering and any activity that facilitates money laundering or terrorist financing. Money Laundering (ML) refers to acts designed to conceal or disguise the true origin of proceeds derived from criminal activities.

1. Initiatives by Share Biz Research

The purpose of this AML Policy is to ensure compliance with SEBI circulars and legal provisions and to ensure that Share Biz Research is not used as a vehicle for money laundering or terrorist financing.

This policy establishes AML standards applicable to all activities of Share Biz Research.

2. Objectives of the AML Policy

• Establish AML procedures and internal controls.
• Detect and report suspicious transactions.
• Ensure compliance with applicable laws and regulations.
• Train staff on KYC and AML procedures.
• Assist law-enforcement agencies when required.

3. Principal Officer – Designation & Duties

Share Biz Research has designated a Principal Officer responsible for AML compliance. The Principal Officer acts as the central reference point for reporting suspicious transactions and liaising with regulatory authorities.

Duties include monitoring AML compliance, maintaining records, training employees, and filing reports with the Financial Intelligence Unit – India (FIU-IND).

4. Customer Due Diligence (KYC)

Client identity, address, business nature, and financial status are verified at the time of onboarding in accordance with SEBI-prescribed KYC norms.

• No fictitious, benami, or anonymous accounts are permitted.
• PAN verification is mandatory.
• Risk-based client classification (low / medium / high).
• Enhanced due diligence for Politically Exposed Persons (PEP).
• Cash transactions are strictly prohibited.

5. Clients of Special Category (CSC)

• Non-resident clients
• High-net-worth individuals
• Trusts, NGOs, charities
• Politically Exposed Persons (PEP)
• High-risk jurisdictions
• Non-face-to-face clients

6. Maintenance of Records

The Principal Officer ensures maintenance of records related to:

• Cash transactions above ₹10 lakhs
• Series of connected transactions
• Suspicious transactions (STR)
• Client identity and transaction details

7. Retention of Records

Client identity and transaction records are retained for a minimum of 10 years after cessation of business or until investigations are closed.

8. Red Flags

• Unclear source of funds
• Unusual transaction patterns
• Large unexplained fund transfers
• High-risk jurisdiction involvement
• Suspicious third-party transactions

9. Reporting to FIU-IND

Suspicious and cash transactions are reported to:

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

10. Internal Audit & Training

Periodic audits are conducted to ensure AML compliance. Employees receive regular training to identify red flags and comply with reporting obligations.

11. Confidential Reporting

AML violations can be confidentially reported to the Principal Officer without fear of retaliation.

12. Review & Communication

This policy is reviewed periodically and communicated to management, staff, and relevant stakeholders.