PMLA Policy

Objectives

• To prevent Trade Nova Technologies Private Limited from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.
• To create awareness and provide clarity on KYC standards and AML measures.
• To maintain a proper Client Due Diligence (CDD) process before registering clients.
• To monitor and report suspicious transactions.
• To maintain records of all cash transactions of value exceeding Rs. 10 lakhs.

Client Due Diligence (CDD) Process

• Maintain records of Know Your Customer (KYC) documents — valid identity proof and address proof — from all clients at onboarding.
• Verify genuineness of clients through direct communication before commencing advisory services.
• Maintain all records between the client and Trade Nova Technologies Private Limited in proper order.

Policy for Acceptance of Clients

• No account shall be opened in fictitious or anonymous name.
• No account will be opened if the service fee is offered in cash.
• No account shall be opened where adequate CDD/KYC cannot be applied.
• Client identity shall be verified against lists of known criminal backgrounds or sanctioned entities as maintained by UN Security Council Committees.
• Clients are classified into low, medium, or high-risk categories based on location, nature of business, trading turnover, and payment manner.

Clients of Special Category (CSC)

The following categories require higher due diligence:

• Non-resident clients
• High net-worth clients
• Trusts, Charities, NGOs, and donation-receiving organizations
• Companies with close family shareholdings or beneficial ownership
• Politically Exposed Persons (PEP)
• Non-face-to-face clients
• Clients with dubious public reputation

Suspicious Transactions

Trade Nova Technologies Private Limited will identify and report suspicious transactions in the following circumstances:

• Clients whose identity verification is difficult or who are uncooperative.
• Source of funds is unclear or inconsistent with client standing.
• Substantial unexplained increases in business activity.
• Clients based in high-risk jurisdictions.
• Large transfers to/from overseas locations with instructions for cash payment.
• Attempted transfer of investment proceeds to unrelated third parties.

Suspicious Transaction Reports (STRs) will be submitted to the Director, Financial Intelligence Unit – India, including for attempted transactions abandoned by clients upon being asked for details or documents.

Monitoring of Transactions

• Special attention shall be paid to all complex, unusually large transactions or patterns with no apparent economic purpose.
• Internal threshold limits for each class of client accounts shall be defined, with special attention to transactions exceeding these limits.