There are no items in your cart
Add More
Add More
| Item Details | Price | ||
|---|---|---|---|
Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) Policy
Sanjeev Kumar – SEBI Registered Research Analyst
SEBI Registration No.: INH000028024
Effective Date: 10 June 2026
Last Reviewed On: 22 August 2026
1. Purpose
This Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) Policy (“Policy”) sets out the framework adopted by Sanjeev Kumar, SEBI Registered Research Analyst (“Research Analyst” or “RA”), to identify, assess, mitigate and appropriately escalate risks relating to money laundering, terrorist financing, fraud, identity misuse and suspicious financial activity.
This Policy shall be read in accordance with the applicable provisions of the Prevention of Money Laundering Act, 2002 (PMLA), the rules made thereunder, applicable SEBI regulations, the SEBI Master Circular for Research Analysts, circulars, guidelines and directions issued by SEBI or the recognised stock exchange administering the Research Analyst registration framework, and other applicable laws and regulatory directions, as amended from time to time.
2. Scope
This Policy applies to all prospective clients, clients, employees (if any), consultants, authorised representatives, agents, referral partners, payment arrangements and third parties connected with the Research Analyst’s services.
3. Nature of Research Analyst Services
The Research Analyst provides research services strictly in accordance with the applicable SEBI framework governing Research Analysts.
The Research Analyst does not accept, hold, manage, pool, transfer or trade client funds or securities.
The Research Analyst receives only permitted fees for research services through traceable banking channels or authorised payment gateways. The Research Analyst does not provide portfolio management, custody, broking, execution, fund management or client-money handling services unless separately registered and specifically permitted under applicable law.
4. Client Onboarding and Digital KYC
All clients are onboarded through the Research Analyst’s official website using a secure digital onboarding process.
The onboarding process includes collection of prescribed client information, PAN verification, Aadhaar OTP-based identity authentication and execution of the Client Agreement through Aadhaar-based eSign, wherever applicable.
The Research Analyst shall obtain and maintain appropriate client information and records, including, where applicable:
• Full name and contact details.
• PAN and other identity details.
• Residential address and onboarding information.
• Mobile number and email address.
• Digital KYC and verification records.
• Aadhaar OTP/eSign confirmation and audit trail.
• Executed Client Agreement.
• Invoice, fee payment and refund records.
• Relevant client communications and service delivery records.
The Research Analyst may request additional information, documents or verification whenever the client's identity, payment source, beneficial ownership or transaction behaviour appears incomplete, inconsistent, unusual or suspicious.
5. Payment Controls
The Research Analyst accepts fees only through traceable banking channels or authorised payment gateways. Cash payments are not accepted.
Fees should ordinarily be received only from the verified client’s own bank account, UPI ID, debit card, credit card or any other authorised payment instrument.
Any of the following situations shall require additional verification and may be rejected:
• Third-party payments.
• Mismatch between KYC details and payment details.
• Unexplained multiple or split payments.
• Unusual payment patterns inconsistent with the subscribed research service.
• Requests for refund to an account different from the original payment source.
Refunds, wherever approved under the applicable Refund Policy, shall ordinarily be processed only to the original verified source of payment. Any exception shall require documented verification and approval by the Research Analyst.
6. Client Risk Assessment
The Research Analyst follows a risk-based approach for client onboarding and ongoing monitoring.
Clients may be classified as Low Risk, Medium Risk or High Risk based on relevant factors including:
• Completeness and reliability of KYC information.
• Payment behaviour and consistency of payment source.
• Whether payment is received from a third party.
• Type of client and beneficial ownership structure (for non-individual clients).
• Geographic, regulatory or reputational risk indicators.
• Politically Exposed Person (PEP) status, where relevant.
• Whether the client appears in any applicable sanctions list, including the United Nations Security Council (UNSC) sanctions list, or any other sanctions list required under applicable law.
• Adverse information, suspected fraud or identity-related concerns.
• Any other factor indicating elevated money laundering or terrorist financing risk.
Higher-risk clients may be subject to enhanced due diligence, additional documentation, closer monitoring, delayed onboarding or rejection, wherever appropriate.
7. Suspicious Activity Monitoring
The Research Analyst shall monitor client onboarding, fee payments, refunds and related communications for suspicious activities.
Illustrative red flags include:
• Refusal, delay or reluctance to provide required KYC information.
• False, inconsistent, incomplete or unverifiable identity or payment details.
• Payment by an unrelated third party without a satisfactory explanation.
• Multiple or split payments without a legitimate business purpose.
• Unusual payment patterns inconsistent with the subscribed research service.
• Requests for refund to an account other than the original payment source.
• Suspected impersonation, forged documents or misuse of identity.
• Requests or conduct indicating that the services may be used for unlawful purposes.
• Any activity that appears to have no apparent legitimate purpose.
The existence of a red flag does not automatically establish wrongdoing. Every case shall be assessed based on available facts, documents and applicable regulatory requirements.
8. Internal Escalation and Reporting
Any suspicious transaction, attempted transaction or suspicious activity shall be documented and promptly reviewed by the Research Analyst.
Where necessary, the Research Analyst may:
• Pause or reject client onboarding.
• Seek additional information or supporting documents.
• Decline or reverse a payment where legally permissible.
• Suspend or terminate services in accordance with the Client Agreement and applicable law.
Where reporting is required under applicable law, SEBI regulations or directions of a competent authority, the Research Analyst shall report the matter to the Financial Intelligence Unit – India (FIU-IND) or any other competent authority within the prescribed timeline and through the prescribed reporting mechanism.
The Research Analyst shall maintain strict confidentiality regarding any suspicious activity review or regulatory reporting process and shall not disclose or “tip off” any client or unauthorised person regarding such review or report.
9. Record Keeping
The Research Analyst shall maintain records relating to:
• Client KYC and onboarding documents.
• Executed Client Agreements.
• Aadhaar eSign and verification records.
• Invoices and fee payment records.
• Refund records.
• Client communications.
• Client risk classifications.
• Suspicious activity assessments and supporting documents.
Such records shall be retained for the period prescribed under applicable laws, SEBI regulations, FIU-IND requirements and internal record retention procedures.
Records shall be maintained in a manner that enables timely retrieval whenever required by SEBI, BSE, FIU-IND, auditors or any other competent authority.
10. Staff Awareness and Training
Where the Research Analyst engages employees, consultants or support personnel involved in client onboarding, billing, client servicing or compliance, they shall be made aware of this Policy and trained to identify and promptly escalate potential AML/CFT red flags.
11. Policy Review
This Policy shall be reviewed at least once every year or earlier whenever there is any change in applicable laws, SEBI regulations, FIU-IND requirements, business model, client onboarding process, payment process or risk assessment framework.
12. Client Contact Details
For AML, KYC or compliance-related queries, clients may contact:
Name: Sanjeev Kumar
Designation: SEBI Registered Research Analyst
SEBI Registration No.: INH000028024
Email: support@happinessallaroundwithsanjeev.com
Website: happinessallaroundwithsanjeev.com
Declaration
I, Sanjeev Kumar, SEBI Registered Research Analyst (SEBI Registration No. INH000028024), hereby confirm that this Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) Policy has been adopted for implementation in connection with my Research Analyst business and shall be updated from time to time in accordance with applicable laws, SEBI regulations and regulatory directions.
Signature:
Name: Sanjeev Kumar
SEBI Registration No.: INH000028024
Date: 22 August 2026
Place: Bhagalpur, Bihar, India
Launch your Graphy