AML Final

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ANTI MONEY LAUNDERING POLICY

Background
Pursuant to the recommendations made by the Financial Action Task Force on anti-money laundering standards, SEBI had issued the Guidelines on Anti Money Laundering Standard vide their notification no. ISD/CIR/RR/AML/1/06 dated 18 January 2006 and vide letter ISD/CIR/RR/AML/2/06 dated 20 March 2006 had issued the obligations of the intermediaries registered under Section 12 of SEBI Act, 1992. As per the SEBI Guidelines, all intermediaries have been advised to ensure that policy frameworks are implemented as per Guidelines on Anti Money Laundering Standards notified by SEBI.
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Objective
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Money laundering has now become one of the major concerns of international financial community. Money Laundering is not just an attempt to disguise money derived from illegal activities. Rather, money laundering is involvement in any transaction or series of transactions that seek to conceal or disguise the nature or source of proceeds derived from illegal activities, including drug trafficking, terrorism, organized crime, fraud and many other crimes. ? Know Your Customer (KYC) is the guiding principle behind the Anti-Money Laundering (AML) measures. It incorporates the Know Your Customer Standards & Anti Money Laundering Measures, hereinafter to be referred as KYC Standards and AML Measures . The objective of is to have in place adequate policies, practices and procedures that promote high ethical and professional standards and prevent the Company from being used, intentionally or unintentionally, by criminal elements . KYC Standards and AML Measures would enable the Company to know/ understand its customers, the beneficial owners in case of non-individual entities, the principals behind customers who are acting as agents and their financial dealings better which in turn will help the Company to manage its risks prudently.

OUR POLICY
Indbank Merchant Banking Services Limited (IBMBS) has framed a comprehensive Anti Money Laundering Policy. The policy sets out and establishes governing principles, broad guidelines and standards adopted IBMBS to protect it from being used by any person(s) / institution(s) for money laundering purposes.

IMPLEMENTATION OF THE POLICY


Acceptance of Clients No account is opened in a fictitious / benami name or on an anonymous basis No account would be opened without client classification with regard to Risk Perception No account should be opened if appropriate due diligence measures cannot be applied to a customer for want of verifiable documents on account of non co-operation of the customer or non-reliability of the data/information furnished to IBMBS b. Client Identification Procedure To achieve the objectives of the KYC framework i.e. to ensure appropriate customer identification and to monitor transaction of suspicious nature. Certified copies of the following documents needs to be collected as part of client identification procedure 1. Individuals a. PAN b. Identity Proof Voters Identity Card / Passport/ Ration Card or any Government/PSU/Bank issued photo identity card or any other document prescribed by regulatory authorities c. Address Proof - Voters Identity Card / Passport/ Ration Card / Bank Statement / latest electricity / telephone bill in the name of the client or any Government/PSU/Bank issued document prescribed by regulatory authorities a. 1. 2. 3.

2. Corporates a. Copy of Registration / Incorporation Certificate b. Copy of Memorandum & Articles of Association c. Copy of the PAN Card and DIN d. Copy of the latest audited financial statements e. Copy of the latest networth certificate f. Copy of the latest income tax return g. Copy of the Board Resolution for appointment of the Authorised person who will operate the account h. Copies of the Identity Proof and Address Proof of the authorized person. 3. Partnership Firm a. Registration Certificate b. Partnership Deed c. PAN Card of the partners d. Authorisation letter for the Authorised person who will operate the account e. Copies of the Identity Proof and Address Proof of the authorized person. f. Copy of the latest financial statements / returns of the firm 4. Trust a. Registration Certificate b. Trust Deed c. PAN Card d. Authorization letter for the Authorized person who will operate the account e. Copies of the Identity Proof and Address Proof of the authorized person. 5. Unincorporated Association or a body of individuals a. Resolution of the managing body of such association or body of individuals b. PoA in favour of person authorized to transact c. Copies of the Identity Proof and Address Proof of the authorized person d. Any other document deemed required by IBMBS to establish the credentials of the association 6. NRI Accounts Repatriable / Non - Repatriable a. Copy of the PIS permission issued by bank b. Copy of the passport c. Copy of the PAN Card d. Proof of the overseas address and Indian address e. Copy of bank statement. f. If the account is handled through a mandate holder, copy of the valid PoA / mandate c. Risk Profiling of Customers Based on risk perception, customers are categorized into three levels J Low Risk Customers J Medium Risk Customers J High Risk Customers d. Suspicious Transactions Suspicious transactions means a transaction which gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime and or which appears to be made in circumstance of unusual or unjustified complexity e. High Value Transactions Transactions which may be classified as High Value are J Under DP single transaction involving more than 2500 shares by quantity / Rs. 10.00 lacs in value J Under stock broking single transaction of value of Rs. 10.00 lacs and above J Transactions in penny / illiquid stocks if value of transaction is above Rs. 5.00 lacs or if the shares total to 1000 and above DESIGNATED PRINCIPAL OFFICER In case of any further information / clarification, the Principal Officer may be contacted

Mr. P MUGUNDAN
Executive Vice President & Company Secretary

Indbank Merchant Banking Services Limited


I Floor, Khiviraj Complex I, No. 480 Anna Salai, Nandanam, CHENNAI 600 036 Phone: 044- 24313087 / 24313094-97, Fax: 044-24313093 e-mail: mugundan@indbankonline.com

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