Anti-Money Laundering (AML) & CFT Policy

YourStock Research | SEBI Reg. Research Analyst: INH000010803

1. Introduction and Objective

YourStock Research is committed to the highest standards of compliance as per the Prevention of

Money Laundering Act, 2002 (PMLA) and the SEBI Master Circular on AML/CFT

(SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78).

Our objective is to prevent our research services from being used for money laundering or terrorist

financing. Although we do not handle client funds or execute trades, we maintain strict vigilance

over fee-based relationships.

2. Principal Officer and Compliance

 Principal Officer & Proprietor: Suhail Ahmed

 Contact: +91 9345252675 | yourstock.in@gmail.com

 Responsibility: Overseeing the effective implementation of AML/CFT measures, monitoring

suspicious transactions, and reporting to the Financial Intelligence Unit (FIU-IND) where

necessary.

3. Client Due Diligence (CDD) & KYC Procedures

 We follow a strict Know Your Client (KYC) process before onboarding any fee-paying client:

 Verification: Identity and address are verified using PAN and KRA (KYC Registration Agency)

records.

 Sanctions Screening: No services are provided to individuals or entities listed in the UN

Security Council or Indian government’s sanctioned lists (UAPA/WMD Act).

 Risk Categorization: Clients are categorized into Low, Medium, or High risk based on their

profile, occupation, and nature of services opted for (e.g., High-risk for frequent

algo/derivative strategy users).

 Beneficial Ownership: We identify the “Ultimate Beneficial Owner” for any non-individual

clients as per PMLA guidelines.

4. Payment Policy (Strictly Digital)

 No Cash Policy: We strictly prohibit the acceptance of fees in cash.

 Digital Only: All payments must be made through identifiable banking channels

(NEFT/RTGS/IMPS/UPI) or crossed cheques.

 Third-Party Payments: We do not accept payments from bank accounts other than those

belonging to the registered client.

5. Suspicious Transaction Reporting (STR)

We monitor client interactions and payment patterns for signs of suspicious activity. This includes:

 Clients providing false or inconsistent information.

 Unusual payment patterns or rapid cancellations and refund requests.

 Any activity that has no apparent economic or legitimate purpose.

 Note: In line with the “Non-Tipping Off” rule, we do not disclose to the client if an STR has

been filed with FIU-IND.6. Record Keeping and Retention

In compliance with SEBI RA Regulations 2014 and PMLA Rules:

 Retention Period: All KYC documents, transaction records, and correspondence are

maintained for a minimum of 5 years from the date of cessation of the relationship.

 Audit Trail: Digital logs of all research recommendations and client communication are

preserved securely.

7. Training and Review

Staffs are trained annually on the latest AML/CFT trends.

This policy is reviewed annually and updated to align with the latest SEBI circulars.

For any questions or concerns, please contact us at care@yourstock.in.