PMLA (Anti Money Laundering) Policy

This policy is framed and adopted as a requirement by SEBI under the Prevention of Money Laundering Act, 2002 (“PMLA”). The policy provides a framework with respect to anti money laundering measures to be taken by Worthos Technologies Private Limited, as a SEBI registered Investment Adviser.

• To prevent Worthos Technologies Private Limited from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.
• Awareness and clarity on KYC standards and AML measures.
• To have a proper Client Due Diligence (CDD) process before registering clients.
• To monitor and report suspicious transactions.
• To monitor and maintain records of all cash transactions done by a client with a value of more than Rs. 10 lacs.

As part of the Client Due Diligence process, Worthos Technologies Private Limited will:

• Maintain a record of Know Your Customer (KYC) documents, including valid identity proof and address proof, obtained from every client at the time of onboarding.
• Speak with clients before proceeding with any research services in order to verify their genuineness.
• Maintain records between the client and Worthos Technologies Private Limited in proper order.

• No account shall be opened in a fictitious name or on an anonymous basis.
• No account will be opened if the fee for services is offered by the client in cash.
• No account is opened where Worthos Technologies Private Limited is unable to apply appropriate CDD measures or KYC policies. This includes cases where information is suspected to be non-genuine or the client does not cooperate in providing full and complete information.

It will be ensured that the identity of the client does not match any person with a known criminal background, any person otherwise banned, or any individual or entity subject to sanctions such as asset or account freezing and denial of financial services under United Nations Security Council resolutions. The applicable list can be accessed on the United Nations website.

Each client shall be classified as low, medium or high risk based on factors including location, the nature of business activity and trading turnover, and the manner of payment for transactions.

Clients of Special Category require a higher degree of due diligence and regular KYC profile updates. These include:

• Non-resident clients.
• High net-worth clients.
• Trusts, charities, Non-Governmental Organizations (NGOs) and organizations receiving donations.
• Companies having close family shareholdings or beneficial ownership.
• Politically Exposed Persons (PEP).
• Companies offering foreign exchange offerings.
• Clients in high-risk countries where the existence or effectiveness of money-laundering controls is suspect.
• Non-face-to-face clients.
• Clients with a dubious reputation according to publicly available information.

Worthos Technologies Private Limited will take appropriate steps to recognize suspicious transactions based on circumstances including:

• Clients whose identity verification is difficult or who are not ready to cooperate.
• The source of a client’s funds is unclear or inconsistent with the client’s apparent standing or business activity.
• Substantial increases in business without apparent cause.
• Clients based in high-risk jurisdictions.
• Clients transferring large sums to or from overseas locations with instructions for payment in cash.
• Attempted transfer of investment proceeds to apparently unrelated third parties.
• Unusual transactions by Clients of Special Category and businesses undertaken by offshore banks or financial services, including businesses reported as export-import of small items.

For any suspicious transaction, Worthos Technologies Private Limited will prepare a report referring to the client, transaction and nature or reason for suspicion and submit it to the Director, Financial Intelligence Unit-India.

If a transaction is abandoned or aborted when a client is asked for details or documents, the attempted transaction will be reported in a Suspicious Transaction Report even if it was not completed, irrespective of its amount.

• Special attention shall be paid to complex, unusually large transactions or patterns that appear to have no economic purpose.
• Internal threshold limits shall be defined for each class of client account, with special attention paid to transactions exceeding those limits.
• The background, documents, office records, memorandums, clarifications and purpose relating to such transactions shall be examined carefully and findings recorded in writing.
• Findings, records and related documents shall be made available to auditors and to SEBI, stock exchanges, FIU-IND and other relevant authorities during audit, inspection or whenever required.
• These records shall be preserved for five years from the date of the transaction with the client.

The following transactions shall be monitored at all times:

• All cash transactions valued above ten lakh rupees or their equivalent in foreign currency.
• All series of integrally connected cash transactions individually valued below ten lakh rupees or their equivalent in foreign currency where the series occurs within one month and the aggregate exceeds ten lakh rupees or its equivalent in foreign currency.
• All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine, or where forgery of a valuable security or document has facilitated the transaction.
• All suspicious transactions, whether or not made in cash, including cheques, pay orders, travellers cheques, demand drafts, loans and advances, money transfers or remittances for clients or non-clients in India or abroad, third-party beneficiaries, and credits or debits in non-monetary accounts such as demat accounts.

Existing accounts shall be reviewed periodically to ensure that none is linked to an entity or individual included in a Security Council Committee list. Any resemblance shall be reported to SEBI and FIU-IND.

For suspicious transactions, Worthos Technologies Private Limited will comply with the record-keeping requirements under the SEBI (Investment Advisers) Regulations, 2013, PMLA and other relevant legislation. Records shall be sufficient to permit a trail of individual transactions, including amounts and currencies, and to provide evidence for prosecution of criminal behaviour if required.

For a satisfactory audit trail, account information shall identify the beneficial owner and, for selected transactions, the origin and destination of funds, the form in which funds were offered or withdrawn, the identity of the person undertaking the transaction, and the form of instruction and authority.

Transaction records shall be preserved and suspicious transactions reported to the Director, FIU-IND. Information relating to attempted or executed transactions reported to FIU-IND shall be kept for five years from the transaction date. Records concerning ongoing investigations or reported suspicious transactions shall be retained until the case is confirmed closed.

• The nature of the transaction.
• The amount of the transaction and the currency in which it is denominated.
• The date on which the transaction was conducted.
• The parties to the transaction.

Under the PML Rules, Worthos Technologies Private Limited will report information relating to cash and suspicious transactions to:

To discharge legal obligations, report suspicious transactions and supervise compliance, the Principal Officer and Designated Director act as central reference points for identifying and assessing potentially suspicious transactions and facilitating reports to FIU.

• Have access at all times to customer identification data and other CDD information.
• Have complete independence and authority to access relevant information.
• Ensure that the PMLA Policy framework is implemented effectively.
• Ensure data generated on FIU concerning suspicious transactions is regularly and promptly downloaded, analysed and reported directly to FIU-IND.
• Ensure records and information relating to clients and transactions are available to competent authorities on a timely basis.
• Ensure a prompt response to requests for information, including KYC information and records, from regulators, FIU-IND and other statutory authorities.
• Ensure all concerned staff are regularly updated about changes, additions and modifications to PMLA provisions.

• Ensure that all records described in this Policy are maintained.
• Where the Designated Director fails to perform these duties, the person shall be penalised and appropriate action may be taken.

Worthos Technologies Private Limited will:

• Maintain adequate screening procedures to ensure high standards when hiring employees.
• Maintain an ongoing employee training programme so staff are adequately trained in Anti-Money Laundering standards and Combating the Financing of Terrorism procedures.

The policy shall be reviewed from time to time, and required changes will be implemented in accordance with applicable rules, laws, acts and regulations.