AML Policy

🛡️ Anti-Money Laundering (AML) Policy

For: Investogainer Research
SEBI Registered Research Analyst
Registration No.: INH000012856 | BSE Enlistment No.: 5845

1. Policy Objective

This AML Policy is framed as per the Prevention of Money Laundering Act, 2002 (PMLA) and relevant SEBI circulars, to detect and report any suspicious activities and ensure that Investogainer Research does not become a conduit for money laundering or terrorist financing.

2. Applicability

This policy applies to:

The Proprietor (Mr. Deepak Raj Pal)
All employees and associates of Investogainer Research
All clients availing research services

3. Know Your Client (KYC) & Client Due Diligence (CDD)

We adhere to SEBI’s KYC framework:

Mandatory PAN, Aadhaar, and Bank verification
Risk-based classification: Low, Medium, High Risk clients
No service provided without successful KYC
Enhanced Due Diligence (EDD) for high-risk clients, politically exposed persons (PEPs), or unusual payment patterns

4. Client Acceptance Policy

No anonymous or fictitious accounts
No acceptance of third-party or cash payments
Refusal to onboard clients with doubtful background or links to criminal activity

5. Monitoring of Transactions

Although Investogainer Research is a Research Analyst (non-fund handling entity):

All incoming payments are monitored for abnormality
We ensure all client payments are from KYC-verified bank accounts
Any suspicious transactions are escalated for review

6. Record Keeping

As per SEBI & PMLA guidelines:

Maintain KYC records, invoices, and correspondence for at least 5 years
Maintain internal records of suspicious or attempted suspicious transactions

7. Reporting Obligations

In case of detection of suspicious transactions, reports will be filed with the Financial Intelligence Unit – India (FIU-IND) as required under PMLA
Suspicious Transaction Report (STR) shall be filed within 7 working days of identification

8. Employee Awareness & Training

Internal AML training sessions will be conducted periodically
Employees are instructed to immediately report any red flags to the Principal Officer

9. Principal Officer Details

Name: Mr. Deepak Raj Pal
Designation: Proprietor & Principal Officer
Email: info@investogainerresearch.com
Phone: 9009099805, 9098804206

10. Confidentiality

All client data and transaction details shall be treated with utmost confidentiality, except when disclosure is required under the law.

11. Grievance Redressal

📧 Email: info@investogainerresearch.com
📞 9009099805 | 9098804206
Clients may also escalate unresolved complaints through SEBI SCORES portal (https://scores.gov.in)

Warning-

Disclaimer– Registration granted by SEBI, membership of a SEBI recognized supervisory body (BSE) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Disclosure– Investments in securities market are subject to market risks, read all the related documents carefully before investing.