Company PMLA Policy

(Issued as per the requirements of the PMLA Act 2002)
Version 6.0 adopted March 2018

Applicable on

Dhwani Stocks and Shares (DSAS), SEBI Registered Intermediary

In compliance with

- The PMLA Act 2005 as modified and rules thereof
- SEBI Circular and Directives

1. Group Policy

It is our policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.

2. Principal Officer

The Company has designated Mr Rajesh P Shah as the Principal Officer and Mr Mukesh P Shah as the Designated Director with full responsibility for the Company’s AML program.

The Company has provided the FIU with contact information for the Principal Officer and Designated Director as under:
- The details of appointment of Mr Rajesh P Shah as principal officer has been intimated to the FIU vide DSAS letter dated 17.10.2015
- The details of appointment of Mr Mukesh P Shah as Designated Director has been intimated to the FIU vide DSAS letter dated 18.02.2016

3. Client Due Diligence (CDD)
The company CDD measures shall comprise the following: The SEBI KRA/ CKYC process shall followed at all times as applicable

4. Policy for acceptance of clients:
The following safeguards are to be followed while accepting the clients:
5. Risk-based Approach

It is generally recognized that certain clients may be of a higher or lower risk category depending on the circumstances such as the client’s background, type of business relationship or transaction etc. As such, we shall apply each of the client due diligence measures on a risk sensitive basis. The basic principle enshrined in this approach is that we shall adopt an enhanced client due diligence process for higher risk categories of clients. Conversely, a simplified client due diligence process may be adopted for lower risk categories of clients. In line with the risk-based approach, the type and amount of identification information and documents that we shall obtain necessarily depend on the risk category of a particular client. Further, low risk provisions shall not apply when there are suspicions of ML/FT or when other factors give rise to a belief that the customer does not in fact pose a low risk.

6. Clients of special category (CSC):
Such clients include the following. The above mentioned list is only illustrative and we shall exercise independent judgment to ascertain whether any other set of clients shall be classified as CSC or not.

7. Client identification procedure
We shall be in compliance with the following requirements while putting in place a Client Identification Procedure

Taking into account the basic principles enshrined in the KYC norms which have already been prescribed or which may be prescribed by SEBI from time to time, we shall frame our own internal directives based on our experience in dealing with their clients and legal requirements as per the established practices. Further, we shall conduct ongoing due diligence where it notices inconsistencies in the information provided. The underlying objective shall be to follow the requirements enshrined in the PMLA, SEBI Act and Regulations, directives and circulars issued thereunder so that we are aware of the clients on whose behalf we are dealing.

We shall formulate and implement a CIP which shall incorporate the requirements of the PML Rules Notification No. 9/2005 dated July 01, 2005 (as amended from time to time), which notifies rules for maintenance of records of the nature and value of transactions, the procedure and manner of maintaining and time for furnishing of information and verification of records of the identity of the clients of the banking companies, financial institutions and intermediaries of securities market and such other additional requirements that it considers appropriate to enable it to determine the true identity of its clients.

It may be noted that irrespective of the amount of investment made by clients, no minimum threshold or exemption is available to us from obtaining the minimum information/documents from clients as stipulated in the PML Rules/SEBI Circulars (as amended from time to time) regarding the verification of the records of the identity of clients. Further no exemption from carrying out CDD exists in respect of any category of clients. In other words, there shall be no minimum investment threshold/ category-wise exemption available for carrying out CDD measures by us. This shall be strictly implemented by us.

Reliance on third party for carrying out Client Due Diligence (CDD)
8. Procedure for freezing of funds, financial assets or economic resources or related services

We are aware that under section 51A of Unlawful Activities (Prevention) Act, 1967, the Central Government is empowered to freeze, seize or attach funds and other financial assets or economic resources held by, on behalf of, or at the direction of the individuals or entities listed in the Schedule to the Order, or any other person engaged in or suspected to be engaged in terrorism. The Government is also further empowered to prohibit any individual or entity from making any funds, financial assets or economic resources or related services available for the benefit of the individuals or entities listed in the Schedule to the Order or any other person engaged in or suspected to be engaged in terrorism.

In case if any client is found to be guilty under the PMLA provisions then the following procedure will be followed by the Company:

9. Record Keeping
10. Information to be maintained

We shall maintain and preserve the following information in respect of transactions referred to in Rule 3 of PML Rules:

11. Retention of Records
12. Monitoring of transactions
13. Suspicious Transaction Monitoring & Reporting
14. List of Designated Individuals/Entities

An updated list of individuals and entities which are subject to various sanction measures such as freezing of assets/accounts, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs) can be accessed at its website at We shall ensure that accounts are not opened in the name of anyone whose name appears in said list. We shall continuously scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list. Full details of accounts bearing resemblance with any of the individuals/entities in the list shall immediately be intimated to SEBI and FIU-IND.

15. Reporting to Financial Intelligence Unit-India
16. Employees’ Hiring/Employee’s Training/ Investor Education
17. Risk Assessment
18. Updation of the policy
The policy shall be revised/ updated as and when required
Revised policy has been approved by me

For Dhwani Stocks And Shares