1. Introduction

Indian Market View

SEBI Research Analyst Registration: INH000010371

Registered/Correspondence Address: D 1, 4th Floor, Plot 576, Niti Khand 1, Indirapuram, Ghaziabad, Uttar Pradesh – 201014

Official Email: info@indianmarketview.com

Validity: Jul 22, 2024 – Perpetual

2. Purpose & Scope

Indian Market View (“the Firm/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 Indian Market View’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, Indian Market View voluntarily applies robust AML/CFT standards to client onboarding, payments, refunds, vendor relationships, and business counterparties.

3. Governance & Roles

• Board/Management Oversight: Management approves this Policy and reviews AML/CFT effectiveness at least annually.

• Designated Director (PML Rules): Mr. Sumit

• Principal Officer (PML Rules) & Compliance Officer (SEBI): Mr. Sumit

  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 Firm is in the process of completing FIU registration.

Lines of Defence:

1. Business Teams: Perform Customer Due Diligence (CDD) 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 as 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):

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

• Non-Individuals:
  

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

Additional Rules:

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

6. Ongoing Monitoring

Automated/manual reviews of:

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

7. Red Flags (Illustrative)

1. Identity inconsistencies or reluctance to provide KYC; forged/altered documents
2. Payment instruments not in the subscriber’s name; frequent refunds to different accounts
3. Subscriptions purchased from/for sanctioned or embargoed locations
4. Attempts to route payments via crypto, cash proxies, or unregulated wallets
5. Pressure to expedite onboarding with unusual urgency or incentives
6. 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.

• Indian Market View 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 Management 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. Sumit

• Review Cycle: At least annually or upon regulatory/business changes; Board/Management approval required for amendments.

• Effective Date: 01 October 2025 (supersedes any prior versions).

For Indian Market View

Mr. Sumit

(Designated Director & Compliance Officer)