PMLA Policy

Introduction

This Policy has been formulated and adopted in compliance with the requirements prescribed by the Securities and Exchange Board of India (SEBI) under the Prevention of Money Laundering Act, 2002 ("PMLA"). The purpose of this Policy is to establish a comprehensive framework for anti-money laundering measures to be followed by Nameeta Priyadarshnee Panda, Proprietor of Research Bull, a SEBI-Registered Research Analyst bearing Registration No. INH000027760.

Objective of the PMLA Policy

• To ensure that the services offered are not misused, knowingly or unknowingly, for money laundering or terrorist financing activities.
• To create awareness regarding Know Your Client (KYC) standards and Anti-Money Laundering (AML) measures.
• To implement an effective Client Due Diligence (CDD) mechanism prior to onboarding clients.
• To identify, monitor and report suspicious transactions or activities.
• To maintain records of all cash transactions exceeding ₹10 lakh or its equivalent value.

Client Due Diligence (CDD) process

As part of the CDD process, Research Bull shall: obtain and maintain records of valid KYC documents (identity and address proof) from all clients at the time of onboarding; conduct direct communication with clients to verify their identity and authenticity before providing services; and ensure that all client-related records and documentation are maintained in an organised and secure manner.

Policy for acceptance of clients

• No account shall be opened under fictitious or anonymous names.
• No account shall be opened where payment for services is offered in cash.
• No account shall be opened where appropriate CDD or KYC verification cannot be completed satisfactorily, including cases of non-cooperation or where the information provided appears false, incomplete or unreliable.
• The identity of clients shall be screened to ensure they are not associated with criminal activities, banned entities, or individuals/entities listed under sanctions issued pursuant to United Nations Security Council Resolutions (UNSCRs). The relevant sanctions list may be accessed at un.org/sc/committees/1267/consolist.shtml.
• Clients shall be categorised as Low Risk, Medium Risk or High Risk based on factors such as client location and correspondence details; nature of business activity and transaction profile; and mode and pattern of payment.

Clients of Special Category (CSC)

Treated as higher-risk and subject to enhanced due diligence:

• Non-resident clients
• High-net-worth individuals
• Trusts, charities, NGOs and organisations receiving donations
• Companies with close family shareholding or beneficial-ownership concerns
• Politically Exposed Persons (PEPs)
• Companies involved in foreign-exchange-related activities
• Clients based in high-risk jurisdictions
• Non-face-to-face clients
• Clients with an adverse or suspicious public reputation

Suspicious transactions

Research Bull shall take reasonable measures to identify and monitor suspicious transactions, including:

• Difficulty verifying client identity or client unwillingness to cooperate
• Unclear or inconsistent source of funds
• Sudden, unexplained increase in activity or volume
• Transactions involving clients in high-risk jurisdictions
• Large fund transfers to/from overseas with cash-payment instructions
• Transfer of investment proceeds to unrelated third parties without justification
• Unusual transactions involving CSC clients or offshore entities

Where a transaction appears suspicious, a report containing details of the client, the transaction and the reasons for suspicion shall be prepared and submitted to the Director, Financial Intelligence Unit – India (FIU-IND). Where a transaction is abandoned or discontinued after requests for additional information, such attempted transactions shall also be reported through Suspicious Transaction Reports (STRs), irrespective of amount.

Monitoring of transactions

Special attention shall be given to complex, unusually large or irregular transactions lacking an apparent economic or lawful purpose. Internal threshold limits shall be established for different client categories, with transactions exceeding thresholds reviewed carefully. Background documents, explanations and clarifications shall be examined and documented, and made available to auditors, SEBI, FIU-IND, stock exchanges or other competent authorities when required. Transaction records shall be preserved for a minimum of five years from the date of the transaction.

Transactions specifically monitored include:

• Cash transactions exceeding ₹10 lakh (or foreign-currency equivalent)
• Multiple connected cash transactions individually below ₹10 lakh but collectively exceeding ₹10 lakh within a month
• Transactions involving forged or counterfeit currency or documents
• Suspicious transactions involving cash, cheques, demand drafts, pay orders, remittances, money transfers, loans, advances, or debits/credits in monetary or non-monetary accounts including demat accounts

Periodic reviews shall ensure no existing client appears on sanctions or prohibited lists issued by the Security Council Committee; any match shall be reported to SEBI and FIU-IND.

Record keeping and retention

Research Bull shall comply with all record-maintenance requirements under the SEBI (Research Analyst) Regulations, 2014, the PMLA and applicable laws; maintain records sufficient to permit reconstruction of individual transactions (including amounts and currency); and preserve records necessary to identify and trace the financial profile of clients involved in suspicious activities.

Details retained, wherever applicable: identity of the beneficial owner; source and destination of funds; nature and mode of transaction; identity of persons conducting the transaction; and supporting instruments such as cheques, drafts or transfer instructions.

Records relating to suspicious transactions reported to FIU-IND shall be maintained for a minimum of five years from the date of the transaction; in cases involving ongoing investigations, until confirmation of closure.

Information to be maintained

For all reportable transactions: nature and type of transaction; amount and currency involved; date of the transaction; and parties involved.

Reporting to FIU-IND

In accordance with the PMLA Rules, Research Bull shall report information relating to suspicious and cash transactions to:

Principal Officer and Designated Director

Name

Ms. Nameeta Priyadarshnee Panda

Designation

Compliance Officer

Email

connect@researchbull.in

Phone

+91 87967 24796

SEBI Registration No.

INH000027760

SEBI Registration Date

Jun 03, 2026 · Validity Perpetual

BSE Enlistment No.

[PLACEHOLDER]

Rights, obligations and responsibilities of the Principal Officer

The Principal Officer shall:

• Have access at all times to customer identification data and other CDD information.
• Have complete independence and authority to access information.
• Ensure the PMLA Policy framework is implemented effectively.
• Ensure data on suspicious transactions is regularly and promptly downloaded from FIU to analyse, identify and report suspicious transactions to FIU-IND directly.
• Ensure records and information on all clients and transactions are available on a timely basis to the competent authority.
• Ensure prompt response to any request for information, including KYC records, from regulators, FIU-IND and other statutory authorities.
• Ensure concerned staff are regularly updated on changes to PMLA provisions.

Rights, obligations and responsibilities of the Designated Director

The Designated Director shall ensure that all records are maintained as per this Policy. Where the Designated Director fails to perform these duties, he/she shall be penalised, and appropriate action may be taken.

Employee hiring / training / investor education

Research Bull will have adequate screening procedures to ensure high standards when hiring employees, and an ongoing employee-training programme so staff are adequately trained in AML and Combating the Financing of Terrorism (CFT) procedures.

Review of policy

The Policy shall be reviewed from time to time, and any required changes implemented as per applicable rules, laws, acts and regulations.

Disclaimer: This PMLA Policy is in line with applicable SEBI regulations and Indian laws, including the Prevention of Money Laundering Act, 2002. The Policy is subject to change as per regulatory requirements.