Know Your Customer And Anti-Money Laundering Policy

This document is the sole property of Bondbazaar Securities Private Limited (“BBSPL”). Any use or duplication of this document without express permission of BBSPL is strictly forbidden and illegal.

1. Introduction

   This policy is framed to ensure effective implementation of Anti Money Laundering (AML) and Combating Financing of Terrorism (CFT) Procedures and guidelines. It aims at creating a program to prohibit and actively prevent the money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities or flow of illegal money. 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.

   This policy provides a detailed account of the procedures and obligations to be followed to ensure compliance with issues related to KNOW YOUR CLIENT (KYC) Norms, ANTI MONEY LAUNDERING (AML), CLIENT DUE DILIGENCE (CDD) and COMBATING FINANCING OF TERRORISM (CFT).

   This policy specifies the requirements applicable to SEBI registered entities, ranging from client acceptance, risk based client due diligence measures, identifying, monitoring and reporting suspicious transactions to FINANCIAL INTELLIGENT UNIT (FIU-IND) and staff training for awareness and vigilance against money laundering and terrorist financing. This Policy also takes into account the provisions of the PML Act and other Rules laid down by FIU-IND and SEBI.

   As per PMLA, all reporting entities which include every banking company, financial institution (which includes Chit Fund company, a co-operative bank, a housing finance institution and a non-banking financial company) and Intermediary (which includes a Depository Participants, Stock-broker, sub-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, merchant banker, underwriter, Portfolio Manager, Investment adviser and any other intermediary associated with securities market and registered under section 12 of the Securities and Exchange Board of India Act, 1992) shall have to maintain a record of all the transactions, the nature and value of which has been prescribed in the Rules notified under the PMLA. For the purpose of PMLA, transactions include:

   1. All cash transaction of the value of more than Rs.10 Lakhs or its equivalent in foreign currency.
   2. All series of cash transactions integrally connected to each other, which have been valued below Rs.10 Lakhs or its equivalent in foreign currency, such series of transactions within one calendar month.
   3. All suspicious transactions whether or not made in cash and including, inter-alia, credits or debits into from any non-monetary account such as DP account, security account maintained by the registered intermediary. “Suspicious Transactions” means a transaction whether or not made in cash which to a person acting in good faith -
   1. Gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or
   2. Appears to be made in circumstances of unusual or unjustified complexity; or
   3. Appears to have no economic rationale or bonafide purpose.

2. Background

   Bondbazaar Securities Private Limited (BBSPL) is a SEBI registered Stock Broker having Registration No. INZ000303236 and is a Trading Member of National Stock Exchange of India Limited (Member ID 90247) and of BSE Limited (Member ID 6768). BBSPL is also registered with CDSL as Depository Participant having Registration no. IN_DP-700-2022.Thus, this document covers the KYC & AML requirements for the services offered by BBSPL as a Stock Broker and DP.

3. Objectives

   The policy aims to develop a diligent and compliance sensitive culture through a focused approach for customer acceptance and identification procedures for risk categorisation and identification of suspicious transactions. The key objectives of the policy are as follows:

   • Put in place appropriate procedures for customer acceptance based on their risk category and customer identification based on due diligence at the time of client on-boarding
   • To know / understand its customers and their financial dealings better and manage its risks in a prudent manner.
   • Make prudent policies which will prevent BBSPL from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities, through the various channels, products and services it offers
   • Develop a comprehensive Anti-Money Laundering (AML) / Combating Financing of Terrorism (CFT) programme in line with the regulatory requirements, covering systems and controls, training of staff and management oversight and ensure its implementation
   • Facilitate a robust controls environment for detection and reporting of suspicious activities in line with applicable laws
   • Ensure that relevant staff are appropriately trained on KYC / AML norms and procedures including identification and acceptance of customers, monitoring their day-to-day financial dealings and report any suspicious dealing to appropriate authorities
   • Follow the KYC norms laid down by FIU-IND and the concerned Regulators of the reporting entity
   • Develop a comprehensive system with defined rules to identify suspicious transactions and report them to FIU-IND without disclosing (“tipping off”) the client
   • Periodically review the policy and approval of the Board.

4. Applicability

   This policy is applicable to all the clients of BBSPL. In case BBSPL takes up any other business or activity, the same shall be included in the Policy automatically and the provisions of the policy made applicable to the said business/ activity unless specific business wise provisions are included in the policy by way of amendments’ captures the details of the AML/ CFT framework including customer acceptance, customer identification, transaction monitoring, roles and responsibilities of Principal Officer, training and reporting requirements. AML/CFT Anti Money Laundering (AML) Standards/ Combating the Financing of Terrorism (CFT) / Obligations of Securities Market Intermediaries under the Prevention of Money Laundering Act (PMLA), 2002 and Rules framed there under, 2010. Securities and Exchange Board of India (SEBI) Master Circular - SEBI/ HO/ MIRSD/ DOP/ CIR/ P/ 2019/113 dated October 15, 2019.

5. Governance Structure

   The Board of Directors and Senior Management appointed by the Board will monitor compliance with KYC/AML/CFT guidelines across all functions / business units.

   1. Principal Officer:

      1. BBSPL has appointed Mr. Akshay Narkar as a Principal Officer for proper discharge of legal obligations and report suspicious transactions to authorities. He acts as a central reference point in framing procedures for reporting of suspicious transactions and shall play an active role in the identification and assessment of potentially suspicious transactions.
      2. Any change in name, designation and addresses including email addresses of the Principal Officer shall be intimated to the office of the Director –FIU.
      3. The Principal Officer facilitates and monitors compliance with regulatory guidelines with respect to customer acceptance, customer identification, and transaction monitoring and risk management.
      4. The Principal Officer ensures that the suspicious transactions reporting are done in a timely manner and accurately to the regulator.
      5. The Principal Officer along with Compliance Team also ensures appropriate dissemination of regulatory updates, pertaining to KYC/AML/CFT, to business units and guide these business units on compliance requirements.
      6. The Principal Officer also identifies emerging risk areas of non-compliance with PMLA guidelines.

   2. Designated Director:

      1. BBSPL has appointed Mr. Suresh Kumar Darak as a Designated Director.
      2. The Designated Director is responsible to ensure overall compliance with the obligations imposed under chapter IV of the PMLA Act & Rules.

   3. Internal Auditor:

      The internal auditor shall inter alia; oversee the implementation of the KYC/AML/CFT framework and compliance of the guidelines issued by the respective regulators

6. Client Due Diligence (CDD)

   The CDD measures comprise the following –

   1. Obtaining sufficient information in order to identify persons who beneficially own or control the securities account. Whenever it is apparent that the securities acquired or maintained through an account are beneficially owned by a party other than the client, that party should be identified using client identification and verification procedures. The beneficial owner is the natural person or persons who ultimately own, control or influence a client and/or persons on whose behalf a transaction is being conducted or who gets the benefit of the transaction. It also includes those persons who exercise ultimate effective control over a legal person or arrangement.
   2. Verifying the client’s identity using reliable, independent source documents, data or information where ever available;
   3. Making all efforts to verify the KYC documents from the issuing authority.
   4. Making an effort to obtain from the clients the details of beneficial ownership and control, i.e. determine which individual(s) ultimately own(s) or control(s) the client and/or the person on whose behalf a transaction is being conducted;

   Following are the requirements for clients other than individuals:

   1. For clients other than individuals or trusts: The general Rule when the client is a person other than an individual or trust, viz., company, partnership or unincorporated association/body of individuals, identify the beneficial owners of the client and take reasonable measures to verify the identity of such persons, through the following information:

      1. The identity of the natural person, who, whether acting alone or together, or through one or more juridical person, exercises control through ownership or who ultimately has a controlling ownership interest.

         Explanation: Controlling ownership interest means ownership of/entitlement to/ exercises control over:

         1. More than 25% of shares or capital or profits of the juridical person, where the juridical person is a company;
         2. More than 15% of the capital or profits of the juridical person, where the juridical person is a partnership; or
         3. More than 15% of the property or capital or profits of the juridical person, where the juridical person is an unincorporated association or body of individuals.
      2. In cases where there exists doubt under clause (a) above as to whether the person with the controlling ownership interest is the beneficial owner or where no natural person exerts control through ownership interests, the identity of the natural person exercising control over the juridical person through other means would be considered.

         Explanation: Control through other means can be exercised through voting rights, agreement, arrangements or in any other manner

      3. Where no natural person is identified under clauses (a) or (b) above, the identity of the relevant natural person who holds the position of senior managing official.
   2. For client which is a trust: Where the client is a private trust, identify the beneficiaries of the trust and take reasonable measures to verify the identity of such persons with beneficial ownership of 15% or more and any other natural person exercising ultimate effective control over the trust through a chain of control or ownership. In case of a public trust, the identity of the settler of the trust, the trustee, the protector shall be established
   3. Exemption in case of listed companies: Where the client or the owner of the controlling interest is a company listed on a stock exchange, or is a majority owned subsidiary of such a company, it is not necessary to identify and verify the identity of any shareholder or beneficial owner of such companies.
   4. Applicability for foreign investors: Dealing with foreign investors’ based on the clarifications issued vide SEBI circulars CIR/MIRSD/11/2012 dated September 5, 2012 and CIR/ MIRSD/ 07/ 2013 dated September 12, 2013, for the purpose of identification of beneficial ownership. Eligible FPI's classified as Category I,II, and III (as specified in CIR/ MIRSD/ 07/ 2013 dated September 12, 2013) shall abide by KYC guidelines stipulated by SEBI from time to time.

   For the purpose of client identification the following will be considered:

   1. Verify the identity of the ultimate beneficial owner of the client and/or the person on whose behalf a transaction is being conducted;
   2. Understand the ownership and control structure of the client;
   3. Conduct on-going due diligence based on available facts disclosed by the clients and scrutiny of the transactions and account throughout the course of the business relationship to ensure that the transactions are consistent with BBSPL’s knowledge of the client, its business and risk profile, taking into account where necessary, the client’s source of funds.
   4. Periodically (once in 2 years) request clients and collect from them updated information about beneficial owners under the CDD process. In case the client does not submit the said updated information, the BBSPL shall use the available information for CDD process

7. Customer Acceptance and Monitoring

   In order to ensure that the guidelines are complied, BBSPL will ensure client profiling and monitoring system, at the time of on-boarding process, monitoring of trading pattern of the clients, depository transactions and other financial transactions maintained with BBSPL are followed.

   1. Client Identification:

      Customer identification means undertaking due diligence of the prospective client before commencing an account-based relationship. This includes identifying the customer and its/his/her address on the basis of one of the Officially Valid Documents (OVDs). Following procedure shall be followed for client identification/registration:

      1. The customers may approach BBSPL to avail the services offered.
      2. In case of a new customer whose KYC details are not available in the KRA system, BBSPL shall execute a fresh KYC with the customer, obtain copies all the relevant documents ( such as PAN, Proof of Residence, Proof of Identify, Income Details, etc), verify the same with original, carry out in-person verification in case of Individual and HUF clients. Verify the PAN with Income-tax Website.
      3. Once a new customer’s KYC details and documents are obtained and verified, the same will be updated on KRA and the Central KYC (CKYC).
      4. In case the client KYC is available in the KRA system, his/her KYC details and documents will be fetched from KRA and provided to client for confirmation. In case of any discrepancy in the information fetched from KRA, client will have option to provide revised details along with revised valid proofs . BBSPL will verify valid proofs provided by clients and update KRA records.
      5. The PAN and Name of the new client will be screened against various database viz: UNSC, OFAC, SEBI, Watchout investors, PEP list, RBI Defaulter's List and other list as applicable/ notified from time to time. The screening shall be done for all clients at least once in a quarter.

      It will be ensured that an account is not opened where appropriate CDD/KYC measures cannot be applied. This shall apply in cases where it is not possible to ascertain the identity of the client, or the information provided is suspected to be non - genuine, or there is perceived non - co-operation of the client in providing full and complete information.

      Following information/OVDs shall be excepted from the Individual customer in order to carry out his/her KYC unless KYC details are available with KRA or CKYC:

      1. Photo of the original PAN Card (This will be a mandatory document for the purpose of Proof of Identity (POI))
      2. Photo of the valid Original Address Proof (POA). (Any one of Passport, Aadhaar Card, Driving License [except issued by Govt. of NCT] or Voter ID); Bank statement or Passbook/ Demat account statement/ Telephone bill (Not older than 3 months from account opening) or any other document permitted by FIU/SEBI.
      3. Personal Details (Mobile Number, E-mail Address, Address etc.)
      4. Bank Details
      5. Other Details (Occupation, Income Range, Tax Residency Declaration, PEP Declaration etc.)
      6. IPV for In-person verification
      7. Residential Status
      8. Photo
      9. Additional documents may be sought from client for enhanced due diligence*: (Any one of the below) –
         1. Copy of ITR Acknowledgement(Latest assessment year)
         2. Copy of Annual Accounts
         3. In case of salary income - Salary Slip(Last 3 months), Copy of Form 16 (Latest assessment year)
         4. Net worth certificate (latest financial year)
         5. Copy of depository participant account holding statement ( Last 3 months)
         6. Bank account statement for last 6 months
         7. Self-declaration by customer while on-boarding

         * any one of the above listed documents would be mandatory in case client opts for trading in derivatives segment, which is as per SEBI requirement to determine client acceptance for trading in derivatives segment. These documents will also be taken from the client as part of enhanced due diligence

         The customer information will be verified in order to carry out due diligence at the time of on-boarding to establish his/her identity. The verification process shall include the following:

         1. Verifying the PAN with Income Tax Database
         2. Matching the name of customer with his/her PAN.
         3. Matching the address mentioned in the OVD document with the address provided by the customer.
         4. Verifying if the bank account mentioned, belongs to the respective client
         5. Verifying the Photo of the customer with the photo on the Pan card.
         6. Verifying the DOB and father’s name with the PAN card.

   2. Customer Acceptance

      At the time of on-boarding, the PAN and Name of the new client will be screened against various database viz: UNSC, OFAC, SEBI, Watchout investors, PEP list, RBI Defaulter's List and other list as applicable/ notified from time to time.

      1. If there is a PAN match, then account of such individual will be opened (category Y) and the same shall be verified by EOD and moved to Category R.
      2. Apart from debarment if any other regulatory action is observed against the concerned individual then the account will be opened and moved to EOD verification (category Y)
      3. For other individuals with no PAN match, BBSPL shall start with onboarding process (category G)
      4. In case of exact or near Name match, BBSPL shall open the account and move to EOD verification (category Y)
      5. For other individuals with no Name match, BBSPL shall start the on-boarding process (category G)
      6. On a time to time basis any client in category Y is identified/matched with the PAN /Name in the above sanction list, the client shall be marked for monitoring/deactivation.

      On a time to time basis, BBSPL shall perform EOD verification to identify any changes in customer acceptance. Existing database of Investment Ready clients (Category Y and G) as well as previously debarred customers (category R) will be scanned for change in status.

      1. Category Y clients will be revisited on the basis of risk parameters to check if they can be converted into exact match with the help of any additional information viz as Order details, Date of Birth, City, Pin code or any identification number and take suitable remedial action
      2. Category R clients will be rechecked to confirm if the debarment status still continues
      3. Category G clients will be rescanned for any new regulatory action

   3. Risk Profiling:

      1. The clients shall be categorized as high, medium and low risk depending on risk perception and due diligence on customers shall be based on the risk profile of the customer. The risk profiling of customer shall be done depending on the nature of business activity, source of funds, financial status, and such other factors as per regulatory guidelines
      2. Identify clients whose location cannot be ascertained (registered office address, correspondence addresses and other addresses if applicable)
      3. Identify clients whose Nature of business activity cannot be ascertained
      4. Identify clients whose Trading turnover does not commensurate with the financial details/income details provided by them
      5. Identify clients who try to make the payments from accounts other than their own
      6. Client with PEP (Politically Exposed Persons) Status

      BBSPL has plans to have the categorisation based on following customer profile:

      Risk Category	Customer Profile	Periodicity of review, once in
      High	Customers requiring very high level of monitoring, e.g., those involved in cash intensive business, Politically Exposed Persons (PEPs) or persons of foreign origin.	1 year
      Medium	Customers who are likely to pose a higher than average risk will be categorised as medium risk depending on the background, country of origin, sources of funds, customer profile, etc.	5 year
      Low	Individuals (other than High Net Worth) and entities, whose identity and source of income can be easily identified, and customers in whose accounts the transactions confirm to the known profile.	5 year

      If the proposed customer’s PAN details match with the available data in the risk profiling categories mentioned above, the actions will be taken according to the parameters mentioned above. In case of Name match for a prospective customer, further due diligence would be initiated before on-boarding to conclude if it’s a genuine match. Same rules will be followed if an existing client falls in any of the risk categories.

      Additionally, Clients of Special Category shall be categorized as High Risk Clients and their financial details and nature of business would be updated on a periodical basis. Ongoing due diligence would be carried out for the clients based on their risk profiling.

      Clients of Special Category (CSC) as defined for this policy -

      1. Non-Resident clients
      2. High net-worth clients,
      3. Trust, Charities, Non-Governmental Organizations (NGOs) and organizations receiving donations.
      4. Companies having close family shareholdings or beneficial ownership
      5. Politically Exposed Persons (PEP) Politically exposed persons are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g., Heads of States or of Governments, senior politicians, senior government/judicial/military officers, senior executives of state-owned corporations, important political party officials, etc. The additional norms applicable to PEP should also be applied to the accounts of the family members or close relatives of PEPs.
      6. Companies offering substantial foreign exchange offerings.
      7. Clients in high risk countries where existence / effectiveness of money laundering controls is suspect, where there is unusual banking secrecy, countries active in narcotics production, countries where corruption (as per Transparency International Corruption Perception Index) is highly prevalent, countries against which government sanctions are applied, countries reputed to be any of the following –Havens / sponsors of international terrorism, offshore financial centres, tax havens, countries where fraud is highly prevalent.
      8. Clients with dubious reputation as per public information available etc.

      Dormant/Inactive Account

      BBSPL will classify accounts as dormant / inactive as in case the client does not trade during the financial year as per Dormant Account policy

8. Maintenance and Preservation of Records

   Record Keeping / Information to be Obtained / Retention of Records

   Steps will be taken to comply with the record preservation and maintenance requirements as per regulatory guidelines. The following information as regards to the accounts of the customers is retained in order to maintain satisfactory audit trail:

   1. The beneficial owner of the account
   2. The identification documents of the clients
   3. The volume of the funds flowing through the account
   4. Communication with the clients regarding their transactions and identification
   5. Ledger details of the clients
   6. Any other documents/files as mandated by the regulators from time to time

   The original documents shall be stored in both physical and tamper proof electronic mode in a manner which can be retrieved as required time to time. The documents are maintained for a minimum period of 8 years from closure of account (as specified by SEBI) or more in case specified by other regulators. In the case of ongoing investigation, the documents should be maintained till it is confirmed that the case under investigation is closed. Proper back-up of the electronic data shall also be preserved.

   Records of information reported to the Director, Financial Intelligence Unit –India (FIU – IND):

   BBSPL shall maintain and preserve the records of information related to transactions, whether attempted or executed, which are reported to the Director, FIU – IND, as required under Rules 7 and 8 of the PMLA Rules which lays down the procedure and manner of furnishing information and specifies the time limits of various kinds of reports to be submitted to Director, FIU-IND, for a period of five years from the date of the transaction between the customer and BBSPL.

9. Monitoring Of Transactions and Reporting of Suspicious Transactions

   Transaction monitoring is an essential and critical aspect of the PMLA regulations and is required in order to monitor and report potential money laundering and terrorist financing exposure. It involves identifying and reviewing unusual or unrelated or suspicious transactions on an ongoing basis based on risk categorization of customers. All the transactions will be monitored to ensure that they are consistent with customer’s profile and source of funds. For the purpose of suspicious transactions reporting, ‘transactions integrally connected’, ‘transactions remotely connected or related’ should also be added. A record of all transactions would be preserved and maintained in line with regulatory requirements and reported to the Director, FIU-IND were suspicious.

   In addition to the above mentioned, this policy seeks to establish the following aspects of transaction monitoring:

   1. Adopt a continuous approach towards due diligence for monitoring customer for:

      1. Large and complex transactions and those with unusual patterns, which have no apparent economic rationale or legitimate purpose
      2. Transactions which exceed the thresholds prescribed for specific categories of accounts
   2. Develop systems for periodical review of risk categorization of customers and the need for applying due diligence measures. Such reviews will be conducted on an annual basis
   3. Develop appropriate procedures for reporting suspicious transactions. The procedures to incorporate the list of circumstances as a guidance to identify suspicious transactions in line with the regulatory guidelines.
   4. Develop mechanism to report suspicious transactions to the Principal Officer. After due review, Principal Officer will report such instances to the Board of Directors and relevant regulatory authorities.

   Depository Alerts

   The alerts sent by depositories and stock exchanges shall be treated as red flag alerts and taken up for further scrutiny. BBSPL shall scrutinizes every alert based on parameters defined and the data of client profile available and decides whether the same is suspicious or not.

   Internal alerts

   Internal alerts shall also be generated based on the various criteria mentioned below and the same is scrutinized to determine if they are suspicious. Complex and unusually large transactions shall also be monitored and analysed. The alerts will be reviewed by designated officials based on nature of the transaction. Based on the review by Principal Officer, who will be final authority, shall decide on reporting to Board of Directors, regulatory authorities and external stake holders. Principal Officer shall have full access to all the data and information related to the matter

   From the date of generation of an alert, BBSPL will make all efforts to determine if it’s suspicious or not. BBSPL will ensure that the suspicious transactions shall be reported within 7 days from the date of determining that the same is suspicious and records of all the alerts with observations are preserved for at least 5 years or any period as decided by FIU (IND) from time to time.

   For identification of suspicious transactions, the activities in clients’ accounts shall be regularly monitored. An illustrative list of circumstances which may be in the nature of suspicious transactions is given below:

   • Substantial increase in activity without any apparent cause
   • Transactions with no apparent economic or business rationale
   • Sudden activity in dormant accounts;
   • Source of funds are doubtful or inconsistency in payment pattern;
   • Transfer of investment proceeds to apparently unrelated third parties;
   • Multiple transactions of value just below the threshold limit so as to avoid possible reporting;
   • Unusual transactions by CSCs;
   • Large deals at prices away from the market.
   • Trading activity in accounts of high risk clients based on their profile, business pattern and industry segment

   Attempted, abandoned or aborted transactions by clients on being asked to give some details or to provide documents that give rise to suspicion. If not clarified is also a suspicious transaction and must be reported.

   BBSPL shall ensure that there is continuity in dealing with the client as normal until told otherwise and the client should not be informed of the report/suspicion.

   In exceptional circumstances, in order to control business and financial risk, BBSPL may decide that the client should not be permitted to continue to operate the account, and transactions may be suspended.

10. Combating Financing of Terrorism

    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 declared by SEBI or as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs) can be accessed at its website shall be maintained and continuously updated by BBSPL.

    BBSPL will 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 the accounts bearing any resemblance with any of the individuals / entities in the list will be furnished to SEBI and FIU-IND.

    Freezing of Assets under Section 51 A of the Unlawful Activities Prevention Act (UAPA), 1967

    The Unlawful Activities (Prevention) Act, 1967 (UAPA) has been amended by the Unlawful Activities (Prevention) Amendment Act, 2008. Government has issued an Order dated August 27, 2009 detailing the procedure for implementation of Section 51A of the Unlawful Activities (Prevention) Act, 1967 for prevention of, and for coping with terrorist activities. In terms of Section 51A, 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 and 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.

    BBSPL will adopt the below approach to follow the procedure laid down in the Order and ensure meticulous compliance to the Order:

    1. On receipt of list of individuals and entities subject to UN Sanctions from SEBI, procedure prescribed in Section 51 A of Unlawful Activities Prevention Act (UAPA), 1967 with respect to freezing / unfreezing of financial assets, would be implemented expeditiously for prevention of and coping with terrorism finance.
    2. Updated designated lists will be maintained in electronic form and a check will be run on the given parameters on a regular basis to verify whether individuals or entities listed in the schedule to the Order (referred to as designated individuals/entities) are holding any funds, financial assets or economic resources with them.
    3. In case, the particulars of any of its customer match with the particulars of designated individuals/entities, BBSPL will report immediately, not later than 24 hours from the time of finding out such customer, full particulars of the funds, financial assets or economic resources or related services held in the form of securities held by such customer on its books to the Joint Secretary (CTCR Division), Ministry of Home Affairs, at Fax No.011-23092569 and also convey over telephone on 011-23092736. The particulars apart from being sent by post should necessarily be conveyed through e-mail at jsctcr-mha@nic.in.
    4. A copy of the communication mentioned in (3) will be sent/reported online or through e-mail (sebi_uapa@sebi.gov.in) to the UAPA nodal officer of SEBI, Officer on Special Duty, Integrated Surveillance Department, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, “G” Block, Bandra Kurla Complex, Bandra (E), Mumbai 400 051 as well as the UAPA nodal officer of the State/UT where the account is held and FIU-IND.
    5. In case, the match of any of its customer with the particulars of designated individuals/entities is beyond doubt, BBSPL would prevent designated persons from conducting financial transactions, under intimation to Joint Secretary (CTCR Division), Ministry of Home Affairs, at Fax No. 011-23092569 and also convey over telephone on 011-23092736. The particulars apart from being sent by post should necessarily be conveyed through e-mail at jsctcrmha@nic.in.

    BBSPL will file a Suspicious Transaction Report (STR) with FIU-IND covering all transactions in the accounts covered by paragraph above, carried through or attempted, as per the prescribed format.

11. Reporting to Financial Intelligence Unit-India

    BBSPL has registered itself with FIU-IND in its FIN-NET utility for the purpose of reporting Suspicious Transactions and has obtained a FIUREID number, which would be used as a reference id for uploading the STRs. In terms of the PMLA Rules, BBSPL is required to report information relating to suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address:

    Director,
    FIU-IND, Financial Intelligence Unit-India,
    6th Floor, Hotel Samrat,
    Chanakyapuri,
    New Delhi-110021.
    Website: http://fiuindia.gov.in

12. Designation of an officer for reporting of Suspicious Transactions

    The board of BBSPL has appointed Mr. Akshay Narkar as a ‘Principal Officer’ and in case of any change, the same along with the newly appointed ‘Principal Officer’ has been approved by the board.

    The name of the Principal Officer shall be intimated to the Director-FIU. He will act as a central reference point in facilitating onward reporting of suspicious transactions and for playing an active role in the identification and assessment of potentially suspicious transactions.

    Further to the existing requirement of designation of a Principal Officer, the PMLA Regulations also require the appointment of a Designated Director to manage and monitor compliances to address concerns of money laundering and suspicious transactions undertaken by clients. The name of such designated director and changes in his/her appointment by the board of directors shall be conveyed the Director-FIU.

13. Employees Hiring/ Employees Training / Investors’ Education

    Hiring of Employees

    BBSPL has adopted adequate screening procedures to ensure high standards when hiring employees. Screening of all the employees is carried out to ensure that their name/Pan does not match with any barred, notified entity, having criminal records or barred by the regulators. It identifies the key positions within the organizations and ensures that the employees taking up such key positions are suitable and competent to perform their duties. Further, no candidate is selected who has ever been convicted of offence under Money Laundering Act or any other civil or criminal Act.

    Employees’ Training

    All employees shall be given initial training on PMLA guidelines at the time of induction for new joiners. Copy of AML policy is handed over to the employees for their information so that they can upgrade their knowledge on regulatory guidelines. Records of these training will be stored. Training requirements shall have specific focuses for frontline staff, back office staff, compliance staff, risk management staff and staff dealing with clients.

    Investors’ Education

    Implementation of KYC procedures requires BBSPL to demand certain information from customer which may be of personal nature or which has hitherto never been called for. This sometimes leads to a lot of questioning by the customer as to the motive and purpose of collecting such information. The employees of BBSPL shall be trained to explain to the customers the regulatory requirements and benefits of adhering to the KYC guidelines and seek cooperation of the customer. Further, BBSPL shall prepare specific communication so as to educate the customer of the objectives of Client Due Diligence.

    In case of any further queries or assistance please feel free to contact to Customer Care Team or mail on connect@bondbazaar.com