PMLA policy

I. Purpose of the PMLA Policy

• To ensure the Company is not misused, knowingly or unknowingly, for money laundering or financing of unlawful activities.
• To promote understanding of Know Your Customer (KYC) norms and Anti-Money Laundering (AML) practices.
• To establish a comprehensive Client Due Diligence (CDD) procedure before onboarding clients.
• To identify and report suspicious or unusual transactions.
• To maintain and monitor records of all cash transactions exceeding ₹10 lakh.

II. Client Due Diligence (CDD) procedure

• Preserve records of KYC documents such as valid proof of identity and address obtained during onboarding.
• Interact directly with clients to confirm authenticity before initiating services.
• Ensure all records and communications are properly maintained and organised.

III. Client acceptance guidelines

• Accounts will not be opened using fictitious identities or anonymous details.
• Clients offering service fees in cash shall not be accepted.
• Accounts shall not be opened where proper CDD/KYC cannot be completed, including doubtful information or lack of cooperation.
• Client identities shall be verified against sanctions lists, criminal databases and entities restricted under UN Security Council Resolutions (UNSCRs).
• Clients are categorised into low, medium or high-risk profiles based on location, nature of business, transaction patterns and payment methods.
• Clients of Special Category (CSC) are subject to enhanced due diligence, including non-residents, high-net-worth individuals, trusts/charities/NGOs, closely-held companies, Politically Exposed Persons (PEPs), foreign-exchange businesses, clients from high-risk jurisdictions, non-face-to-face clients, and clients with adverse reputation.

IV. Suspicious transactions

The Company shall implement adequate measures to identify suspicious transactions, including: difficulty in verifying client identity or unwillingness to cooperate; unclear source of funds; transactions inconsistent with the client's profile; unexplained increases in transaction volume; transactions involving high-risk jurisdictions; large overseas transfers with cash-payment instructions; requests to transfer proceeds to unrelated third parties; and unusual activity involving CSCs or offshore entities.

Where suspicious activity is detected, a report containing details of the client, transaction and reasons for suspicion shall be submitted to the Director, Financial Intelligence Unit-India (FIU-IND). Even abandoned or incomplete suspicious transactions shall be reported where clients refuse to provide required information.

V. Transaction monitoring

• Particular attention to complex or unusually large transactions lacking clear economic purpose.
• Internal threshold limits per client category; transactions exceeding limits receive enhanced scrutiny.
• Background records, supporting documents, explanations and findings documented in writing, and retained for at least five years and accessible to SEBI, exchanges, FIU-IND, auditors or other authorities.
• Continuous monitoring of: cash transactions exceeding ₹10 lakh; multiple linked cash transactions below ₹10 lakh collectively exceeding ₹10 lakh within a month; counterfeit currency/forged instruments; and suspicious transactions through any mode.
• Periodic reviews to ensure no account is associated with any prohibited individual or entity listed by the Security Council Committee.

VI–VII. Maintenance and preservation of records

The Company shall comply with the record-maintenance requirements under the SEBI (Research Analyst) Regulations, 2014, the PMLA, 2002 and other applicable laws; maintain records that enable reconstruction of individual transactions; and preserve information to create a reliable audit trail (including beneficial-owner details, source of funds, mode of deposit/withdrawal, identity of the person transacting, destination of funds, and governing instructions).

Information relating to transactions reported to FIU-IND — whether completed or attempted — shall be retained for a minimum of five years from the date of the transaction, and longer where connected to pending investigations. Recorded details include the nature and type of transaction, its value and currency, the date, and the particulars of the parties involved.

VIII. Reporting to FIU-IND

Suspicious and cash transactions shall be reported to: Director, FIU-IND, Financial Intelligence Unit – India, 6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110021. Website: fiuindia.gov.in.

IX–XI. Principal Officer and Designated Director

Name

Mr. Mohammad Farid Firoz Khan

Designation

Compliance Officer (Principal Officer & Designated Director)

Email

connect@fivepointresearch.com

Phone

+91 73491 58852

SEBI Reg. No.

INH000000000

The Principal Officer shall have unrestricted access to CDD information; function independently with adequate authority; ensure proper implementation of this policy; review and report suspicious transactions to FIU-IND; ensure records are available to competent authorities; ensure prompt compliance with information requests; and ensure relevant employees are trained on PMLA changes. The Designated Director is responsible for ensuring all required records and documents are properly maintained and preserved.

XII–XIII. Employee training and review

The Company shall establish appropriate screening and verification procedures while recruiting employees, and conduct continuous training on AML and Combating Financing of Terrorism (CFT) procedures. This Policy shall be reviewed periodically and amended in line with applicable laws and regulatory guidelines.

Disclaimer: This PMLA Policy has been drafted in accordance with applicable SEBI regulations and Indian legal provisions, including the PMLA, 2002. Its contents may be revised from time to time in line with regulatory changes.