Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policy

Money Bells Global Research Services Private Limited ('the Company') is committed to absolute compliance with the Prevention of Money Laundering Act, 2002 (PMLA), the Prevention of Money Laundering (Maintenance of Records) Rules, 2005, and the consolidated guidelines issued under the SEBI AML/CFT Master Circular dated June 06, 2024 (and operational guidelines including the latest circular dated February 06, 2026) and the Financial Intelligence Unit – India (FIU-IND). While the Company operates exclusively as a SEBI-registered Research Analyst (Reg No. INH100009901) and does not handle client funds, execute securities trades, or manage investment accounts, compliance is mandatory to ensure absolute ethical transparency, market integrity, and investor safety. The policy aims to safeguard the integrity of the securities market, promote investor confidence, establish a robust internal control framework to prevent money laundering or terrorist financing, and facilitate timely reporting of suspicious transactions to FIU-IND.

This policy applies to all directors, partners, research analysts, associates, onboarding officers, and stakeholders of Money Bells. The Board of Directors has designated Mr. Sagar Goel, SEBI Registered Research Analyst, as the Principal Officer (PO) and Designated Director for AML/CFT compliance. Mr. Sagar Goel serves as the central point of contact for SEBI and FIU-IND, responsible for: (a) Overseeing the implementation and effectiveness of AML/CFT internal controls, (b) Monitoring transaction fee patterns and performing regular risk assessments, (c) Assessing internal reports of suspicious activity and ensuring timely submissions of Suspicious Transaction Reports (STRs) to FIU-IND on the FINnet 2.0 portal, (d) Disseminating policy updates, SEBI circular amendments, and regulatory modifications to all employees, and (e) Hosting mandatory annual compliance training and refresher sessions for onboarding and research teams.

Money Bells enforces strict criteria for client onboarding to prevent illicit elements from utilizing its premium research advisory services: (a) No advisory relationship or service agreement shall be established in fictitious, anonymous, or benami names. (b) All prospective clients must successfully pass a standard compliance screening against SEBI debarred lists, FATF high-risk jurisdiction and non-cooperative territory blacklists, and United Nations Sanctions Lists (including UNSC Resolution 1267/1989 and 1988 search indexes). (c) No services shall be rendered if the Company is unable to complete basic due diligence or if the client background represents an unacceptable regulatory risk. (d) All client identity verifications must be successfully completed and approved prior to the activation of research subscriptions or advisory deliveries.

Before rendering services, the onboarding desk must execute standard Customer Due Diligence (CDD) procedures: (a) Obtain and verify official valid documents (OVD) including PAN Card (which must be verified in real-time via the income tax database), Aadhaar Card, or corporate incorporation charters. (b) Establish client risk-profiling (categorizing relationships into Low, Medium, or High Risk) based on geographical location, corporate structure, and payment sources. (c) In accordance with latest PMLA amendments, identify and verify the identity of the natural persons holding beneficial ownership (controlling interest of 10% or more for companies, partnerships, or trusts). (d) Immediately reject onboarding if any document appears incomplete, forged, or altered. (e) Maintain all client identification data, KYC verification history, and research agreement records for a minimum of 10 years (or longer in case of active regulatory inquiry) in compliance with SEBI master guidelines.

As a SEBI-registered Research Analyst, Money Bells does not handle client assets or execute brokerage trades. The only financial transactions processed by the Company are the collection of research service and advisory fees. (a) Cash payments are strictly and unconditionally prohibited. (b) All subscription fees must be collected exclusively through digital banking channels, standard wire transfers (NEFT/RTGS/IMPS), or SEBI-compliant payment gateways under the client's own name. (c) Onboarding and finance teams must monitor all transaction fee inputs. (d) Any third-party payment sources, split-payment layering patterns, multiple micro-transfers originating from different accounts, or foreign currency remittances from high-risk locations must be immediately reported to Principal Officer Mr. Sagar Goel for compliance auditing.

Employees are legally mandated to report any unusual activity to the Principal Officer. (a) Under PMLA guidelines, Suspicious Transaction Reports (STRs) must be filed with FIU-IND within 7 days of identifying suspicious activity. (b) Address for regulatory communication: Director, FIU-IND, 6th Floor, Hotel Samrat, Chanakyapuri, New Delhi-110021. (c) Anti-Tipping-Off Provision: Section 54 of the PMLA strictly prohibits disclosing or tipping-off clients that their account, payment, or research subscription is under investigation or that an STR is being prepared or filed with FIU-IND. Any tipping-off violation represents a statutory punishable offense. (d) Regular refresher training sessions shall be conducted annually during the first week of April to keep onboarding, marketing, and research teams aligned on identifying red flags, high-risk entities, and reporting protocols.