Anti-Money Laundering (AML) Policy

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.

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

• 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

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

• Investogainer Research is a Research Analyst (non-fund handling entity)
• All incoming payments are monitored for abnormality
• All client payments verified from KYC-verified bank accounts only
• Any suspicious transactions are escalated for review immediately

• KYC records, invoices, and correspondence maintained for at least 5 years
• Internal records maintained of suspicious or attempted suspicious transactions

• Suspicious transactions reported to Financial Intelligence Unit – India (FIU-IND) as required under PMLA
• Suspicious Transaction Report (STR) filed within 7 working days of identification

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

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