AML Policy

Last updated: June 2026

This Anti-Money Laundering (AML) Policy is designed specifically for SEBI-registered Research Analysts (RAs) who provide investment recommendations and research reports. RAs do not handle client funds or execute transactions. Clients are onboarded through signed Terms & Conditions, and KYC is performed via PAN verification using the KRA system. This policy aligns with SEBI Master Circular SEBI/HO/MIRSD/MIRSD-SEC-5/P/CIR/2023/022 dated February 03, 2023, and its subsequent updates.

Scope

This policy applies to all activities of the Research Analyst business, including:

• Onboarding clients (one-to-many research services);
• Verifying client identity via PAN through the KRA system;
• Delivering research reports and recommendations.

Research Analysts do not hold or manage client accounts or funds.

Definitions

CDD

Client Due Diligence

EDD

Enhanced Due Diligence

PEP

Politically Exposed Person

FIU-IND

Financial Intelligence Unit – India

STR

Suspicious Transaction Report

KRA

KYC Registration Agency

Governance and responsibilities

• Designated Director: ensures overall AML compliance and policy approval.
• Principal Officer: the individual RA (or Principal Officer in the case of a non-individual RA) responsible for reporting suspicious activities to FIU-IND.
• Compliance Officer: implements CDD processes, monitors client interactions, and maintains records.

AML / CFT policies and procedures

Client acceptance and risk categorisation

• Clients must sign the RA’s Terms & Conditions (including MITC) before onboarding.
• Perform CDD via PAN authentication through a registered KRA system.
• Classify clients based on the plan and nature of the plan subscribed. This does not amount to risk profiling; recommendation plans are made based on the risk involved in the securities being recommended.
• Apply EDD for PEPs, high-risk geographies, and unusual engagement requests.

Client Due Diligence (CDD)

• Verify client identity using PAN via the KRA system.
• Record client name, PAN, contact details, and engagement type.
• Identify and document any beneficial owners if the client is an entity.
• Understand the purpose and expected usage of research services.

Reliance on third parties

RAs may rely on KRA systems for PAN verification under the CDD Rules. Ultimate responsibility for CDD remains with the RA.

Risk assessment

• Conduct periodic risk reviews of the recommendation plans being offered.
• Update risk categories when client circumstances or regulations change.
• Document assessment results for audit and regulatory review.

Monitoring and reporting

• Monitor client interactions and requests for signs of irregular or illicit use of research.
• Report any suspicious client behaviour or requests to the Principal Officer / Individual RA.
• File STRs with FIU-IND within 7 days of detecting suspicious activity.
• Maintain confidentiality to prevent tipping-off.

Record keeping

• Retain signed T&C documents, PAN KYC records, and client correspondence for at least 5 years after the relationship ends.
• Keep a log of STRs and related documents for 5 years from the date of reporting.

Sanctions screening

• Screen client lists against UN and Indian sanctions databases before onboarding.
• Decline service to sanctioned individuals or entities and report to the relevant authorities.

Training and awareness

• Provide annual AML training for all staff involved in client onboarding and research dissemination.
• Update training materials to reflect regulatory changes and emerging risks.

Policy review

This policy shall be reviewed annually, or upon significant regulatory updates, and re-approved by the Designated Director.

Research Analyst

Rachit Jain

SEBI Reg. No.

INH000022738

BSE Enlistment No.

6756

Brand Name

Navkar Research

Navkar Research — SEBI Registered Research Analyst (Reg. No. INH000022738, BSE Enlistment No. 6756). For any clarification regarding this document, please contact us.