Anti-Money Laundering (AML) Policy for SEBI Research Analysts
Privacy Policy
SR Alpha Investment Advisers SEBI Registered Research Analyst Registration No: INH000025975
Principal Officer: Rounak Rajendra Agrawal
1. Introduction
This AML Policy is designed specifically for SR Alpha Investment Advisers, a SEBI-registered Research Analyst providing investment recommendations and research reports. Research Analysts do not handle client funds or execute transactions. They onboard clients through signed Terms & Conditions and perform KYC through 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.
2. Scope
This policy applies to all activities of the Research Analyst business, including:
-Onboarding clients for one-to-many research services
-Verifying client identity through PAN using the KRA system
-Delivering research reports and recommendations
SR Alpha Investment Advisers does not hold or manage client accounts or funds.
3. 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
4. Governance and Responsibilities
4.1 Designated Director
The Designated Director ensures overall AML compliance and policy approval.
4.2 Principal Officer
Mr. Rounak Rajendra Agrawal, Principal Officer of SR Alpha Investment Advisers, is responsible for reporting suspicious activities to FIU-IND.
4.3 Compliance Officer
The Compliance Officer implements CDD processes, monitors client interactions and maintains records.
5. AML/CFT Policies and Procedures
5.1 Client Acceptance and Risk Categorisation
Clients must sign the Research Analyst’s Terms & Conditions, including the Most Important Terms and Conditions, before onboarding.
Perform CDD through PAN authentication using 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 provided as recommendations.
Apply EDD for PEPs, high-risk geographies and unusual engagement requests.
5.2 Client Due Diligence
Verify client identity using PAN through the KRA system.
Record the client’s name, PAN, contact details and engagement type.
Identify and document beneficial owners where the client is an entity.
Understand the purpose and expected usage of the research services.
5.3 Reliance on Third Parties
SR Alpha Investment Advisers may rely on KRA systems for PAN verification under the CDD Rules.
Ultimate responsibility for CDD remains with SR Alpha Investment Advisers.
5.4 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.
5.5 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.
File STRs with FIU-IND within seven days of detecting suspicious activity.
Maintain confidentiality to prevent tipping off.
5.6 Record Keeping
Retain signed Terms & Conditions documents, PAN KYC records and client correspondence for at least five years after the relationship ends.
Keep a log of STRs and related documents for five years from the date of reporting.
5.7 Sanctions Screening
Screen client lists against United Nations and Indian sanctions databases before onboarding.
Decline services to sanctioned individuals or entities and report them to the relevant authorities.
5.8 Training and Awareness
Provide annual AML training to all staff involved in client onboarding and research dissemination.
Update training materials to reflect regulatory changes and emerging risks.
6. Policy Review
This policy shall be reviewed annually or upon significant regulatory updates and re-approved by the Designated Director.