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Anti-Money Laundering (AML) Policy


Objective

This Anti-Money Laundering (AML) Policy has been framed in accordance with the provisions of the Prevention of Money Laundering Act, 2002 (PMLA), the Rules notified thereunder, and SEBI circulars on Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).
The objective of this policy is to ensure that AxeCap (Truestock Universe Private Limited), being a SEBI-registered Research Analyst (RA), maintains robust systems and controls to prevent being used, intentionally or unintentionally, for money laundering or terrorist financing activities.


This policy aims to:

  • Ensure compliance with PMLA and SEBI’s AML/CFT framework.
  • Establish internal controls to detect and report suspicious activities.
  • Create awareness among employees and maintain a culture of compliance.

Applicability

This policy applies to all directors, officers, employees, and representatives of Truestock Universe Private Limited, who are involved in client onboarding, communication, record keeping, or compliance-related functions.
As a Research Analyst, we does not handle client funds or securities. It provides onlynon-discretionary research and investment recommendations. Execution of trades and fund transfers are done solely by clients through their brokers or intermediaries. Accordingly, the AML compliance obligations are limited to the client identification and reporting functions applicable to a Research Analyst.


Key Definitions

Money Laundering: As per Section 3 of PMLA, money laundering involves directly or indirectly attempting to indulge or knowingly assisting in any process connected with proceeds of crime and projecting them as untainted property.
Suspicious Transaction: A transaction, whether or not made in cash, which:

  • Appears to involve proceeds of crime;
  • Has no apparent economic rationale or bona fide purpose;
  • Appears unusually complex; or
  • Involves funds suspected of being linked to terrorist activities.
Financial Intelligence Unit – India (FIU-IND): The national agency responsible for receiving, analyzing, and disseminating information relating to suspicious financial transactions.


Scope of the Policy

Given the limited nature of services, this policy primarily focuses on:

  1. Client identification and verification (basic KYC checks).
  2. Monitoring of payment transactions (research subscription or fee payments).
  3. Record maintenance and reporting of suspicious activity (if any).
  4. Staff awareness and compliance oversight.

Client Due Diligence (CDD) Process

Before onboarding:

  • Identify client type (individual, corporate, FII, mutual fund, PMS, etc.)
  • Collect all registration documents (ID, photo, proof of address, PAN) and verify against originals
  • Obtain bank statements to determine transaction payment methods
  • Ensure physical presence of client for registration
  • Collect antecedent details, occupation, and income sources
  • Classify clients into low, medium, high risk, including Clients of Special Category (CSC)
  • Obtain financial statements for last two years, certified by Chartered Accountants
  • Ensure complete KYC; incomplete forms are not accepted
  • Refuse clients who cannot provide adequate information or are suspicious
  • Apply risk-based approach and enhanced due diligence for higher risk clients
  • Implement verification if client acts on behalf of another person, specifying limits and authorities
  • Ensure no client matches individuals/entities with criminal background or banned status

Clients of Special Category (CSC)
1. Policy for Acceptance of Clients
  • No client shall be accepted without basic KYC verification (PAN).
  • No client shall be onboarded anonymously or under a fictitious name.
  • The client must be registered with KRA (KYC Registration Agency).
  • Clients shall not be accepted if listed on SEBI debarred entities, or any other regulatory ban lists.
    Links for verification:

2. Procedure for Identifying Clients

Since Research Analysts are not required to perform full-fledged KYC verification like intermediaries handling funds, we shall:

  • Collect and verify the PAN of the client.
  • Ensure that onboarding is completed only after satisfactory verification.
  • Refuse services if the client fails to provide adequate identification evidence.

3. Beneficial Ownership and Control

As we does not execute or manage client accounts, it does not access transactional or beneficial ownership data. Responsibility for identifying beneficial owners lies with the broker or intermediary managing the client’s securities or funds.


Maintenance of Records
  • Client identification records and transaction details (fee receipts, communications, KYC verification, etc.) shall be maintained for a minimum of 10 years.
  • In case of ongoing investigation or regulatory inquiry, records shall be preserved until resolution.

Transaction Monitoring and Reporting
  • We does not handle client investments or securities. The only transactions are service fee receipts.
  • Hence, AML monitoring will focus on:
    • Ensuring that all fee payments are made through banking channels only.
    • No cash payments shall be accepted.
    • Unusual or large one-time payments inconsistent with the client’s profile shall be reviewed and, if suspicious, reported to the Principal Officer.

Suspicious Transaction Reports (STR)

Any suspicious or unusual payment activity will be promptly escalated to the Compliance Officer / Principal Officer for review. If necessary, an STR shall be filed with FIU-IND in accordance with PMLA provisions.
Any suspicious transactions will be immediately notified to the Compliance Officer. The notifications may be done in the form of a detailed report with specific references to the clients, transactions and the nature/reason of suspicion. The compliance staff members will have timely access to customer identification data and other CDD information, transaction records and other relevant information.
Compliance Officer will carefully go through all the reporting requirements and formats as per the provision of PMLA

  1. The Principal Officer will be responsible for timely submission of CTR and STR to FIU-IND
  2. Utmost confidentially will be maintained in filling of CTR and STR to FIU- IND.
  3. The reports will be transmitted by speed/registered post/fax at the notified address.
  4. No nil reporting will be made to FIU-IND in case there are no cash/suspicious transaction to be reported.

Reporting to Financial Intelligence Unit–India

Compliance department should randomly review transactions to detect suspicious activity
In terms to the PMLA rules, Principal Officer is required to report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address:
Director,
FIU-IND, Financial Intelligence Unit-India,
6th Floor, Hotel Samrat, Chankyapuri, New Delhi – 110 021.
Website: http://fiuindia.gov.in


Employee Training and Awareness
  • Annual AML awareness sessions will be conducted to educate staff on PMLA provisions, red flags, and internal reporting mechanisms.
  • Copies of this policy shall be circulated among all relevant staff members.
  • Employees shall report any suspicious activity immediately to the Principal Officer.

Internal Audit and Review
  • An independent audit of compliance shall be carried out annually by an external professional as permitted under SEBI RA regulations.
  • The management will review and update the policy as and when regulatory changes occur.

Confidentiality

All reports and communications made under this policy, including STRs or internal alerts, shall be keptstrictly confidential. No staff member shall “tip off” any client regarding an investigation or reporting activity.


Policy Review and Approval

This policy shall be reviewed periodically — at least once annually — or upon any change in SEBI/PMLA regulations. All revisions shall be approved by the Board of Directors of Truestock Universe Private Limited.