PMLA Policy

This policy has been formulated and adopted in accordance with the requirements prescribed by SEBI under the Prevention of Money Laundering Act, 2002 (“PMLA”). It establishes the anti-money laundering framework to be followed by Simran Sunil Patil Proprietor of Option Grow, a SEBI-registered Research Analyst holding registration number INH000030409.

The objectives of this policy are outlined below:

• To ensure that Simran Sunil Patil Proprietor of Option Grow is not misused, knowingly or unknowingly, for money laundering or financing of unlawful activities.
• To promote understanding and awareness regarding 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.

As part of the CDD framework, Simran Sunil Patil Proprietor of Option Grow shall:

• Preserve records of KYC documents such as valid proof of identity and address obtained from clients during onboarding.
• Interact directly with clients to confirm authenticity before initiating research services.
• Ensure that all records and communications between the Research Analyst and clients are properly maintained and organized.

Simran Sunil Patil Proprietor of Option Grow shall ensure the following:

• 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 or KYC measures cannot be completed, including situations involving doubtful information or lack of client cooperation.
• Client identities shall be verified against sanctions lists, criminal databases, and entities restricted under United Nations Security Council Resolutions (UNSCRs).
• Clients will be categorized into low, medium, or high-risk profiles after evaluating factors such as location, nature of business, transaction patterns, and payment methods.
• Certain categories of clients shall be treated as Clients of Special Category (CSC) and subjected to enhanced due diligence, including:
• Non-resident individuals
• High net-worth individuals
• Trusts, charities, NGOs, and donation-receiving entities
• Companies with closely held ownership structures
• Politically Exposed Persons (PEPs)
• Foreign exchange-related businesses
• Clients from high-risk jurisdictions
• Non-face-to-face clients
• Clients with adverse public reputation or questionable background information.

Simran Sunil Patil Proprietor of Option Grow shall implement adequate measures to identify suspicious transactions, including situations such as:

• Difficulty in verifying client identity or unwillingness of clients to cooperate.
• Unclear source of funds or transactions inconsistent with the client’s profile or business activity.
• Unexplained increase in transaction volume or business activity.
• Transactions involving clients from high-risk jurisdictions.
• Large overseas fund transfers involving cash payment instructions.
• Requests to transfer investment proceeds to unrelated third parties.
• Unusual activities involving CSCs or offshore banking and financial service 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 or documentation.

Transactions shall be monitored in the following manner:

• Particular attention shall be given to complex or unusually large transactions lacking clear economic purpose.
• Internal threshold limits shall be defined for different categories of client accounts, and transactions exceeding such limits shall receive enhanced scrutiny.
• Background records, supporting documents, explanations, and findings related to such transactions shall be documented in writing.
• Such records shall remain accessible for audits, inspections, or review by SEBI, stock exchanges, FIU-IND, auditors, or other competent authorities.
• All records shall be retained for at least five years from the date of the transaction.

The following categories of transactions shall be continuously monitored:

• Cash transactions exceeding ₹10 lakh or equivalent foreign currency.
• Multiple linked cash transactions below ₹10 lakh that collectively exceed ₹10 lakh within a month.
• Transactions involving counterfeit currency, forged instruments, or fraudulent documentation.
• Suspicious transactions conducted through cash, cheques, demand drafts, remittances, transfers, loans, or non-monetary accounts such as demat accounts.

Periodic reviews shall also be conducted to ensure that no existing account belongs to or is associated with any prohibited individual or entity listed by the Security Council Committee.

In relation to suspicious transactions, Simran Sunil Patil Proprietor of Option Grow shall:

• comply with the record maintenance requirements prescribed under the SEBI (Research Analyst) Regulations, 2014, the Prevention of Money Laundering Act, 2002, and other applicable laws.
• maintain adequate records that enable reconstruction and tracking of individual transactions, including details such as transaction amounts and currency involved, wherever applicable, so that such information may be used as evidence in the event of any criminal investigation or prosecution.
• preserve sufficient information relating to client accounts to create a reliable audit trail, enabling investigating authorities to trace and reconstruct the financial profile of any account suspected to be connected with money laundering, terrorist financing, or unlawful activities. Such records shall include:
• details of the beneficial owner of the account; and
• information relating to selected transactions, including the source of funds, mode of deposit or withdrawal such as cheques or demand drafts, identity of the person carrying out the transaction, destination of funds, and instructions or authority governing the transaction.

Records of all transactions shall be securely maintained, and transactions identified as suspicious shall be reported to the Director, FIU-IND.

Information relating to transactions reported to FIU-IND, whether completed or merely attempted, shall be retained for a minimum period of five years from the date of the transaction. In cases where records are connected to pending investigations or suspicious transaction reports, such records shall continue to be preserved until confirmation of closure of the matter is received.

The following details relating to all transactions referred to under Clause V of this Policy shall be recorded and maintained:

• nature and type of the transaction;
• value of the transaction and the currency in which it was conducted;
• date on which the transaction took place; and
• particulars of the parties involved in the transaction.

In accordance with the provisions of the PML Rules, Simran Sunil Patil Proprietor of Option Grow shall report information concerning suspicious and cash transactions to the Financial Intelligence Unit – India (FIU-IND) at the following address:

Director, FIU-IND

Financial Intelligence Unit – India

6th Floor, Hotel Samrat

Chanakyapuri, New Delhi – 110021

Website: https://fiuindia.gov.in

For ensuring effective compliance with legal and regulatory obligations under the PMLA framework, including identification and reporting of suspicious transactions, the following person shall act as the “Principal Officer” and “Designated Director.” The officer shall serve as the central point for assessment, monitoring, and reporting of suspicious activities to FIU-IND:

Name

Simran Sunil Patil

Designation

Proprietor

Email ID

connect@optiongrow.com

Phone Number

+91 7400471790

SEBI Registration No.

INH000030409

BSE Enlistment No.

7557

The Principal Officer shall:

• have unrestricted access to customer identification records and other Client Due Diligence (CDD) information at all times.
• function independently with adequate authority for carrying out duties under the PMLA framework.
• ensure proper implementation and effective functioning of the PMLA Policy.
• regularly review and analyse information generated relating to suspicious transactions and ensure timely reporting of such transactions directly to FIU-IND.
• ensure that all records and client-related information are readily available to competent authorities whenever required.
• ensure prompt compliance with requests for KYC records or transaction-related information received from regulators, FIU-IND, or other statutory authorities.
• ensure that all relevant employees are periodically informed and trained regarding amendments, updates, and changes in PMLA provisions and compliance requirements.

The Designated Director shall be responsible for ensuring that all records and documents required under this Policy are properly maintained and preserved. Failure to discharge such responsibilities may result in penalties or other actions as may be applicable under law.

Simran Sunil Patil Proprietor of Option Grow shall:

• establish appropriate screening and verification procedures to maintain high standards while recruiting employees.
• conduct continuous employee training programmes to ensure that staff members remain adequately informed about Anti-Money Laundering (AML) requirements and Combating Financing of Terrorism (CFT) procedures.

This Policy shall be reviewed periodically, and any amendments or modifications considered necessary shall be implemented in accordance with applicable laws, rules, regulations, and regulatory guidelines.

This PMLA Policy has been drafted in accordance with applicable SEBI regulations and Indian legal provisions, including the Prevention of Money Laundering Act, 2002. The contents of this Policy may be revised or updated from time to time in line with regulatory changes and statutory requirements.