AML Policy

Anti-Money Laundering (AML) Policy

Introduction

Commodity Samachar Securities Private Limited (CSSPL)
SEBI Research Analyst Registration: INH000017781
Registered/Correspondence Address:
27 by 1 B, Office No. 311, Building, Suratwala Mark Plazzo,
Infotech Park, Hinjawadi, Haveli, Pune, Maharashtra – 411057
Official Email: ankit@commoditysamachar.com

Validity: Jul 22, 2024 – Perpetual.

Purpose & Scope

Commodity Samachar Securities Private Limited (“CSSPL”, “the Company”) is committed to full compliance with the Prevention of Money-Laundering Act, 2002 (PMLA), PML Rules, 2005, and applicable SEBI AML/CFT directions and master circulars relevant to Research Analysts (RAs).

This Policy establishes a risk-based framework to prevent misuse of CSSPL’s research services and payment channels for money laundering, terrorism financing, sanctions evasion, fraud, or other unlawful activity.

Note:
While Research Analysts do not handle client trading accounts, CSSPL voluntarily applies robust AML/CFT standards to client onboarding, payments, refunds, vendor relationships, and business counterparties.

Governance & Roles

Board Oversight

  • The Board approves this Policy and reviews AML/CFT effectiveness annually.

Designated Director (PML Rules)

  • Mr. Ankit Kapoor

Principal Officer (PML Rules) & Compliance Officer (SEBI)


  • Mr. Ankit Kapoor
    Responsible for AML/CFT implementation, risk assessment, monitoring, internal reporting, and timely submission of suspicious transaction reports (STRs) to FIU-IND via FINGate 2.0.
    The Company is in the process of obtaining FIU registration.


Lines of Defence

  1. Business teams perform CDD and first-level monitoring.

  2. Compliance independently oversees, tests, and reports.

  3. Internal/independent review provides periodic assurance.

Risk-Based Approach (RBA)

Enterprise-Wide Risk Assessment (EWRA)

Conducted annually covering:

  • Client types

  • Geographies

  • Delivery channels (online subscriptions)

  • Products (research reports/advisories)

  • Payment methods

  • Third parties

  • Technology risks

Risk Categorization

Clients/partners/counterparties are classified Low/Medium/High risk based on:

  • PEP status

  • High-risk jurisdictions

  • Complex ownership structures

  • Unusual payment patterns

Enhanced Due Diligence (EDD)

Applied to:

  • High-risk cases

  • PEPs

  • Adverse media alerts

  • Sanctions proximity

Requires Principal Officer approval.

Customer Acceptance & CDD/KYC

When CDD is Performed

Before onboarding subscribers to paid plans, signing T&C/MITC, institutional access, or entering material vendor/outsourcing arrangements involving client money or data.

Minimum KYC (Natural Persons)

  • Full name, DOB, nationality, residence status

  • Government ID (PAN for Indian residents; passport/OCI for NRIs & foreign nationals)

  • Address proof & recent photograph

  • Contact details (email, mobile)

  • Occupation/source of funds declaration

  • Payment instrument ownership confirmation (only in client’s own name)

Non-Individuals

  • Incorporation/registration certificate, PAN, constitutional documents

  • Beneficial Ownership identification (≥10% ownership or control)

  • Signatory list + KYC of authorized persons

  • GSTIN (if applicable)

Additional Rules

  • No cash acceptance

  • No third-party payments; refunds only to original source

  • EDD for non-face-to-face onboarding (e-KYC, penny-drop, liveness/OTP checks)

  • Sanctions screening at onboarding + periodic

  • PEPs: management approval + EDD + monitoring

Ongoing Monitoring

Automated/manual review of:

  • Mismatches between profile and payment behaviour

  • Frequent upgrades/cancellations with refunds

  • Payments from VPN/TOR/high-risk jurisdictions

  • Use of company cards by unrelated persons

  • Unusual affiliate/referrer fee routing

Trigger-based KYC refresh for material changes.
Periodic screening for all active clients and third parties.

Red Flags (Illustrative)

  • Identity inconsistencies or reluctance to provide KYC

  • Payment instrument not in subscriber’s name; frequent refunds

  • Subscriptions from sanctioned regions

  • Attempts to use crypto, cash proxies, or unregulated wallets

  • Urgent/pressured onboarding

  • Adverse media related to financial crime/terrorism/market abuse

Record Keeping & Data Protection

  • Retention: 5 years from end of relationship/transaction

  • Confidentiality: STR/AML records confidential

  • Data Security: Secure storage with access control & audit trails

Regulatory Reporting

  • Principal Officer evaluates alerts

  • CSSPL cooperates with SEBI, FIU-IND, LEAs (no tipping off)

  • CTRs not applicable (cash prohibited)

  • Any incidents escalated & reported if required

Employee & Partner Controls

  • Mandatory AML/CFT induction & annual training

  • Outsourcing partners/affiliates must comply with AML clauses

  • Employee due diligence & acknowledgment of responsibilities

Internal Controls, Testing & Audit

  • Documented SOPs for onboarding, screening, escalation, STR filing, refunds

  • Independent testing annually (internal/external)

  • Issues escalated with timelines

Disciplinary Measures & Non-Retaliation

  • Breaches may lead to disciplinary action/termination

  • Good-faith reporting is protected; retaliation prohibited

Policy Ownership, Review & Versioning

Owner:
Principal Officer & Compliance Officer – Mr. Ankit Kapoor

Review Cycle:
Annually or upon regulatory/business changes

Effective Date:
01 October 2025

For Commodity Samachar Securities Private Limited

Mr. Ankit Kapoor
DIN: 10626748
Director & Compliance Officer

Ms. Chandni Kapoor
Director
DIN: 07624708