1. Introduction

Money Bells Global Research Services Pvt. Ltd. (“the Company”) is committed to full compliance with the Prevention of Money Laundering Act, 2002 (PMLA), the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, and guidelines issued by the Securities and Exchange Board of India (SEBI) and the Financial Intelligence Unit – India (FIU-IND).
Although the Company operates exclusively as a SEBI-registered Research Analyst and does not handle client funds or execute trades, adherence to AML and CFT standards is mandatory to ensure ethical conduct, transparency, and regulatory compliance.

2. Objective

     This policy aims to:

• Ensure compliance with SEBI’s AML/CFT obligations applicable to intermediaries.
• Safeguard the integrity of the securities market and promote investor confidence.
• Facilitate reporting of suspicious transactions and promote awareness among employees and stakeholders.
• Establish a robust internal control framework to detect and prevent any activity that may relate to money laundering or terrorist financing.

3. Scope and Applicability

This policy applies to all directors, employees, associates, authorized representatives, and stakeholders of Money Bells Global Research Services Pvt. Ltd.
While the Company provides only research and advisory services, it must remain vigilant in identifying and reporting any suspicious or irregular activity related to client interactions or financial dealings

4. Key Components

4.1 Policy for Acceptance of Clients

• No relationship shall be established in fictitious, anonymous, or benami names.
• Clients must provide valid identity and address proofs (PAN, Aadhaar, etc.).
• Clients appearing on any SEBI debarred list, UN Sanctions List, or FATF blacklist will not be onboarded.
• Services will not be rendered if the Company is unable to perform basic due diligence.
• Client verification will be performed prior to the commencement of services.

4.2 Client Due Diligence (CDD)

• Basic KYC documentation (identity and address proof) must be obtained and verified.
• Beneficial ownership verification will be limited to the extent possible, as the Company does not manage client accounts or handle financial transactions.
• Any incomplete, forged, or suspicious KYC information will lead to immediate rejection of onboarding.
• All client records must be retained for a minimum of 10 years or longer in case of regulatory inquiry.

4.3 Transaction Monitoring

• As a Research Analyst, the Money Bells only financial transactions are receipt of service fees through official banking channels.
• Cash payments are strictly prohibited.
• Fees shall be collected only through digital or bank transfer methods.
• Any suspicious or irregular payment pattern (for example, multiple small transfers or third-party payments) must be immediately reported to the Compliance Officer.

4.4 Reporting of Suspicious Transactions

• Any employee identifying an unusual or suspicious transaction must promptly notify the Principal Officer.
• The Principal Officer shall be responsible for preparing and submitting Suspicious Transaction Reports (STRs) or Cash Transaction Reports (CTRs) to FIU-IND as required.
• Reports will be filed confidentially and securely, ensuring no “nil” reporting unless required by law.
• Address for communication:
  Director, FIU-IND, 6th Floor, Hotel Samrat, Chanakyapuri, New Delhi-110021

4.5 Record Maintenance

The Company shall maintain all relevant records, including client details, KYC documentation, and transaction history, for at least 10 years, in compliance with PMLA Rules and SEBI circulars.

5. Roles and Responsibilities

5.1 Principal Officer

• Serve as the central point of contact for AML/CFT compliance.
• Ensure timely reporting to FIU-IND.
• Communicate policy updates and regulatory changes to all employees.
• Monitor the effectiveness of AML controls and initiate corrective measures.
• Conduct internal training and awareness sessions annually.

5.2 Employees and Onboarding Staff

• Must follow the client acceptance and verification process diligently.
• Report any suspicious activity or non-compliance immediately to the Principal Officer.
• Ensure that no client is accepted without completing the minimum KYC.
• Failure to comply may lead to disciplinary action as per company policy.

6. Role of the Principal Officer

Mr. Sagar Goel, the Principal Officer, shall:

• Disseminate AML updates to concerned staff
• Receive and assess suspicious activity reports
• Ensure timely submissions to FIU-IND
• Monitor overall compliance and recommend corrective actions.

7. Responsibilities of Onboarding & Client-Facing Teams

Regular AML/CFT training sessions will be conducted for all relevant staff to ensure understanding of regulatory obligations, red-flag indicators, and reporting procedures. A refresher session shall be organized annually during the first week of April.

9. Review and Update

This policy shall be reviewed at least once a year or whenever there is a change in SEBI, FIU-IND, or PMLA guidelines. The updated version will be communicated to all employees and retained in the Company’s compliance records.