ANTI-MONEY LAUNDERING (AML) POLICY

Introduction
This policy is framed and adopted in accordance with the requirements of the Prevention of Money Laundering Act, 2002 (PMLA), and related rules issued thereunder. It has been formulated as per the guidance of the Securities and Exchange Board of India (SEBI) for Research Analysts to ensure compliance with anti-money laundering (AML) and combating the financing of terrorism (CFT) obligations. This policy provides a comprehensive framework of measures to prevent money laundering and terrorist financing activities and applies to all clients, employees and transactions undertaken by Aditya Arora Proprietor of Adlytick (Individual Research Analyst, SEBI Registration No. INH000011440, BSE Enlistment No. 5732) and any authorized staff or representatives.

I. Objective of the Policy
The objectives of this PMLA policy are:

To prevent the services of Aditya Arora Proprietor of Adlytick from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing.
To establish and maintain clear KYC and AML procedures in line with SEBI and FIU-IND requirements, and to ensure awareness of these standards among all employees and clients.
To ensure proper Client Due Diligence (CDD) before onboarding any client.
To monitor, detect, and report suspicious transactions in a timely manner.
To maintain proper records of all relevant transactions, particularly cash transactions exceeding ₹10 lakh, as per PMLA rules.
To ensure employees and onboarding staff are trained and aware of AML & CFT responsibilities.

II. Client Due Diligence (CDD) Process

Verification and Documentation

Obtain and verify valid KYC documents (identity and address proof) of all clients at the time of onboarding.
Conduct direct communication (telephonic or virtual) with the client before commencing research services/engagement to confirm authenticity, genuineness and intent.
Verify client data through KYC Registration Agencies (KRA) such as CVL KRA, NDML KRA, or BSE KRA.

Record Maintenance

Maintain complete and accurate records of all client interactions, KYC data, documents, and correspondence.
Ensure client data and records stored securely and made readily available to competent authorities upon request.

Ongoing Due Diligence

Periodically review existing client records to ensure data accuracy and completeness.
Update KYC details when there is a material change in client profile or ownership.
Conduct enhanced due diligence(EDD) where risk levels or client activity patterns change materially.

Enhanced Due Diligence (EDD)
Clients assessed as high-risk — such as politically exposed persons (PEPs), non-resident clients, or those from high-risk jurisdictions — shall undergo enhanced due diligence, including verification of source of funds, periodic review of transactions, and more frequent KYC updates.

III. Policy for Acceptance of Clients

No client shall be accepted or service engagement shall be initiated in fictitious, anonymous, or benami names.
No client shall be accepted if payment for services is offered in cash.
Clients whose identity or source of funds cannot be verified shall not be onboarded.
No client shall be onboarded if Aditya Arora/Adlytick is unable to complete appropriate Client Due Diligence (CDD) or KYC procedures. This includes situations where the information provided by the client is suspected to be false, incomplete, or where the client is uncooperative in providing required documentation or details.
Ensure that the identity of each client does not match any person with a known criminal background, or any individual/entity listed as banned or subject to sanctions, including freezing of assets/accounts or denial of financial services, as per:
• UN Security Council Sanctions List (UNSCR 1267) – https://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list
• Lists of debarred or banned individuals/entities issued by SEBI, RBI, or other competent authorities.
Verify that client names do not appear in:
The UN Sanctions List (https://www.un.org/securitycouncil/sanctions/1988/materials)

Any other official list of banned individuals/entities issued by SEBI, RBI, or other regulators.

Risk Categorization
Clients shall be classified as Low, Medium, or High Risk based on factors such as:

clients' location and jurisdiction (registered office address, correspondence addresses and other addresses if applicable)

Nature of income, trading turnover etc
Manner and mode of making payment for transactions undertaken
Background and public reputation

Additionally, as part of ongoing risk assessment and monitoring:
• Screening of clients’ names shall be carried out at onboarding and periodically thereafter against updated sanctions and debarment lists issued by:
– SEBI and Stock Exchanges
– United Nations Security Council Resolutions (UNSCRs)
– FIU-IND and Ministry of Home Affairs notifications.
• The screening process shall be conducted by the Principal Officer or any authorized representative, as applicable.
• Any potential match or link identified shall be promptly reviewed, and where required, reported to SEBI and FIU-IND.

Clients of Special Category (CSC) shall undergo enhanced due diligence. CSC includes, but is not limited to:

Non-Resident Clients (NRIs)
High Net-Worth Individuals (HNIs)
Trusts, Charities, NGOs, and similar entities and organizations receiving donations
Politically Exposed Persons (PEPs)
Clients in high-risk countries or with complex ownership structures
Non-face-to-face clients
Clients with adverse public reputation or negative media information

IV. Identification of Suspicious Transactions
Aditya Arora will ensure that appropriate steps are taken to recognize suspicious transactions or activities that may indicate money laundering, terrorist financing, or related offences under the Prevention of Money Laundering Act, 2002.Suspicious transactions are those that give reasonable grounds to suspect that they may involve the proceeds of crime, lack genuine economic purpose, or are inconsistent with a client’s known profile. The following circumstances may indicate suspicious activity:

Clients whose identity verification is difficult or who are unwilling or refuse to provide complete KYC information or cooperate during verification.

Unclear, inconsistent, or unverifiable sources of funds, or funding patterns not in line with the client’s declared financial status or business or transactions disproportionate to known client profile or income.

Sudden or unexplained increase in engagement/business volume or value without apparent reason.
Clients based in or linked to high-risk jurisdictions, as identified by FATF, SEBI, or FIU-IND.
Clients transferring or receiving large sums of money to/from overseas accounts with unclear purpose or requesting payments in cash.
Attempts to transfer research, recommendation or investment-related proceeds to unrelated third parties.
Abandoned or aborted transactions or engagements after being asked for additional KYC information or source-of-fund details.
Unusual or complex dealings by Clients of Special Category (CSC) such as PEPs, NRIs, or Trusts without legitimate economic justification.

In the event of any such suspicious activity, a detailed report shall be prepared containing:

Reference to the client(s) and transaction(s),
The nature and reason for suspicion, and
Any supporting documentation or background notes.

All suspicious or attempted suspicious transactions shall be reported promptly to the Director, Financial Intelligence Unit – India (FIU-IND), irrespective of transaction amount.

V. Monitoring of Transactions
Although Aditya Arora Proprietor of Adlytick, as an Individual Research Analyst, does not handle client investment accounts or execute financial transactions on behalf of clients, it is essential to ensure vigilance in respect of any financial dealings or observed client behavior that may indicate suspicious activity.
The transactions and activities shall be monitored in the following manner:

1. Continuous Monitoring

Pay special attention to any complex, unusually large, or illogical financial arrangements that appear to have no economic or legitimate purpose.
Identify and review transactions that exceed internally defined thresholds, particularly in relation to advisory fees or related financial flows.
Ensure that no cash payments are accepted for any research and recommendation services.
Any payment for research or advisory services shall only be accepted through traceable banking channels such as account transfer, UPI, or cheque.

2. Transactions Requiring Special Attention
The following categories of transactions shall be closely monitored:

All cash transactions of the value of ₹10 lakh or more (or equivalent in foreign currency).
All series of cash transactions that are integrally connected and collectively exceed ₹10 lakh in a month, even if individually below this threshold.
Any transaction involving forged, counterfeit, or suspicious instruments or any forgery of valuable documents facilitating such transactions.
Any unusual or suspicious transaction, whether or not made in cash, including transfers, credits, cheques, pay orders, demand drafts, money transfers or remittances that do not align with the client’s declared profile or purpose of engagement.

Periodic review shall ensure that no client is linked to any person or entity on UN/SEBI/RBI sanctions lists. Matches shall be promptly reported to SEBI and FIU-IND.

3. Background Examination and Record Availability

The background, supporting documents, internal notes, clarifications, and findings related to such transactions shall be examined carefully and recorded in writing.
These records shall be made available to SEBI, FIU-IND, stock exchanges, auditors, or any other competent authority during inspections or audits, or whenever requested.
Findings and supporting documents shall be preserved for a period of five years from the date of the transaction or account closure, whichever is later.

4. Ongoing Review

Periodic review of client records shall be conducted to ensure that no client or account is linked to any individual or entity appearing in sanctions lists issued by the United Nations Security Council (UNSCRs), SEBI, or other competent authorities.
Any resemblance or match shall be promptly reported to SEBI and FIU-IND in accordance with prescribed procedures.

VI. Record Keeping and Retention of Records
 Compliance with Law
Aditya Arora shall ensure full compliance with the record-keeping requirements prescribed under the Prevention of Money Laundering Act, 2002 (PMLA), the SEBI (Research Analyst) Regulations, 2014, and other applicable laws and circulars.
 Scope of Records
Maintain records of all transactions, client documents, communications, and due diligence information sufficient to permit the reconstruction of individual transactions, including:

Identity and contact details of the client;
Beneficial ownership details (if applicable);
Source and mode of payment of advisory fees;
Nature, amount, and date of the transaction; and
Purpose and destination of funds where applicable.

 Audit Trail
Records shall be maintained in a manner that allows a clear audit trail and, if required, provides evidence for any regulatory or investigative proceedings.
 Retention Period
All records shall be retained for a minimum period of five years from the date of the transaction, cessation of the relationship, or account closure — whichever is later.
 Suspicious or Under-Investigation Transactions
In cases involving suspicious or under-investigation transactions, records shall be retained until the investigation or proceedings are formally concluded and closure is confirmed by the relevant authority.
 Reporting and Accessibility
Records and related information concerning suspicious transactions shall be reported to the Director, Financial Intelligence Unit – India (FIU-IND) as required, and shall be readily accessible to competent authorities upon request.

VII. Information to be Maintained
For all reportable transactions, the following information shall be maintained:

Nature and type of transaction
Amount and currency denomination
Date of transaction
Parties to the transaction
Purpose, source, and destination of funds

VIII. Reporting to Financial Intelligence Unit –
India In compliance with the PML Rules, all relevant information relating to cash and suspicious transactions shall be reported to:Director
Financial Intelligence Unit – India (FIU-IND)
6th Floor, Hotel Samrat, Chanakyapuri,
New Delhi – 110021
Website: https://fiuindia.gov.inIn case there are no transactions qualifying for reporting, no NIL report shall be filed with FIU-IND.

IX. Appointment of Principal Officer & Designated Director
To ensure effective discharge of obligations under the Prevention of Money Laundering Act, 2002, Aditya Arora shall act as the Principal Officer and Designated Director responsible for overall compliance, monitoring, and reporting of suspicious transactions to the Financial Intelligence Unit – India (FIU-IND).Principal Officer & Designated Director Details :
Name: Mr. Aditya Arora
Designation: Individual Research Analyst
Email: adlytick@gmail.com
Phone: +91 7434000132
SEBI Registration No.: INH000011440
BSE Enlistment No.: 5732Responsibilities of the Principal Officer The Principal Officer shall:

Have complete independence and unrestricted access to all customer identification data and other CDD information at all times.
Act as the central point of contact for AML compliance and coordination with FIU-IND.
Ensure full and effective implementation of the PMLA framework across all operations.
Monitor and analyze client transactions to identify suspicious patterns or anomalies.
Report all suspicious activities promptly and directly to FIU-IND.
Respond without delay to any request for information or records from SEBI, FIU-IND, or other competent authorities.
Ensure that all employees (if any) and associates are regularly updated and trained regarding changes in AML/CFT requirements and procedures.

Responsibilities of the Principal Officer The Designated Director shall:

Ensure that all records and compliance requirements under this Policy are properly maintained and implemented.
Be responsible for ensuring overall adherence to AML/CFT obligations under the PMLA.
Be liable for non-performance or negligence in carrying out these duties, and may be subject to penalties and disciplinary action as per applicable law.

X. Employee Hiring, Training & Investor Education

Ensure that employees and associates meet high integrity and professional standards during hiring.
Conduct ongoing training and awareness sessions on AML/CFT procedures.
Support staff and onboarding personnel may assist in prospective client and client engagement, documentation, and administration. All such personnel shall :

 Comply with AML/CFT procedures in this policy.
 Conduct KYC verification before client onboarding. maintain confidentiality of client data and financial information
 Immediately report any unusual or suspicious client behavior to the Principal Officer.
 Participate in periodic AML awareness and compliance training.

Educate investors about AML obligations, risk awareness, and responsible participation in financial markets.
If no employees are currently engaged, this requirement shall apply as and when staff or associates are appointed.

XI. Review of Policy
This policy shall be reviewed periodically and revised as necessary to reflect any changes in regulatory requirements, FIU-IND directives, SEBI circulars, or internal business practices.

Disclaimer This PMLA (Anti-Money Laundering) Policy has been framed in accordance with applicable Indian laws including the Prevention of Money Laundering Act, 2002, the SEBI (Research Analyst) Regulations, 2014, and related circulars and guidelines .
The policy is subject to revision based on amendments in the relevant Acts, Rules, or SEBI directives.

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ANTI-MONEY LAUNDERING (AML) POLICY