Anti-Money Laundering (AML) Policy for Stoic Wealth

  • Entity Name: Stoic Wealth

  • SEBI Registration Number: INH000022224

  • Registered Address: A-101, 45 Paramount, Lalit Estate, Baner, Pune, Maharashtra, 411045

1. Introduction

  • This document outlines the formal Anti-Money Laundering (AML) Policy of Stoic Wealth, a SEBI-registered Research Analyst Firm.

  • This policy strictly complies with the Prevention of Money Laundering Act, 2002 (PMLA), the rules framed thereunder, and all relevant SEBI guidelines.

  • The framework is designed to prevent and ensure that Stoic Wealth’s operations are not directly or indirectly misused for money laundering or terrorist financing activities.

2. Objective

The primary objective of this policy is to establish a robust framework for detecting, preventing, and reporting suspicious transactions while ensuring 100% compliance with applicable laws. This policy comprehensively covers:

  • 2.1. Policy for acceptance of clients.

  • 2.2. Procedure for identifying clients (KYC).

  • 2.3. Transaction monitoring and reporting, specifically Suspicious Transactions Reporting (STR).

  • 2.4. Client Due Diligence (CDD) processing.

3. Policy for Acceptance of Clients

  • 3.1. No account or client relationship will be established under a fictitious, anonymous, or benign name.

  • 3.2. Client onboarding will be outright refused if adequate Client Due Diligence (CDD) / Know Your Customer (KYC) measures cannot be successfully applied.

  • 3.3. Stoic Wealth will ensure that all clients are formally KYC-registered and have provided valid, legally recognized documentation.

  • 3.4. The firm will rigorously verify client identities to ensure they do not appear on any lists of banned persons or entities issued by SEBI, stock exchanges, or global bodies.

  • 3.5. Risk assessments will be conducted systematically, including mandatory checks against global sanctions lists maintained by the United Nations Security Council Resolutions (UNSCR).

4. Procedure for Identifying Clients (Client Due Diligence)

  • 4.1. Only reliable, independent, and primary sources of data/documents will be utilized to verify client identity and secure complete KYC details.

  • 4.2. All submitted client documentation must be strictly cross-verified; any discrepancies, anomalies, or red flags must be immediately escalated to higher authorities and the compliance team.

  • 4.3. The firm will maintain a continuous, periodic follow-up schedule on client information, updating data records as required by regulatory shifts.

5. Maintenance of Records

  • 5.1. All essential client onboarding records, KYC documents, and transaction logs will be securely maintained for a minimum period of 10 years.

  • 5.2. In the event of any ongoing regulatory actions, investigations, or litigation, records will be preserved beyond the 10-year limit until the final resolution of the matter.

6. Monitoring and Reporting of Transactions

6.1. Monitoring Transactions

  • 6.1.1. The primary financial interaction encountered by Stoic Wealth involves the collection of advisory/service fees.

  • 6.1.2. All fee collections will be accepted exclusively through verifiable digital banking channels (e.g., NEFT, RTGS, IMPS, UPI, Net Banking).

  • 6.1.3. Cash transactions are strictly prohibited. Absolutely no physical cash will be accepted under any circumstances.

6.2. Reporting Suspicious Transactions

  • 6.2.1. Any transaction or onboarding behavior deemed anomalous will be immediately escalated to the Compliance Officer via a detailed internal report highlighting client profiles, transaction nature, and explicit reasons for suspicion.

  • 6.2.2. The designated Compliance/Principal Officer is responsible for the timely and accurate reporting of suspicious activities to the Financial Intelligence Unit – India (FIU-IND).

  • 6.2.3. Absolute statutory confidentiality will be maintained throughout the filing processes for both Cash Transaction Reports (CTR) and Suspicious Transaction Reports (STR)—tipping off the client is strictly forbidden.

7. Roles and Responsibilities

7.1. Principal / Compliance Officer

  • 7.1.1. Clearly communicate the internal AML policy updates to all active employees.

  • 7.1.2. Oversee and end-to-end ensure absolute compliance with overall AML and PMLA regulations.

  • 7.1.3. Act as the sole point of contact for timely reporting of suspicious transactions to FIU-IND.

  • 7.1.4. Promptly address regulatory queries and clarify doubts raised by employees regarding the firm’s AML framework.

7.2. Onboarding Staff

  • 7.2.1. Diligently adhere to the established KYC and CDD procedures during every stage of the client onboarding lifecycle.

  • 7.2.2. Immediately report any red flags or suspicious activities noticed during client interactions to the Principal Officer.

  • 7.2.3. Maintain personal compliance with prevailing AML laws and Stoic Wealth’s internal codes.

8. Communication & Training

  • 8.1. A digital/physical copy of this updated AML policy will be distributed to all existing and incoming staff members.

  • 8.2. Mandatory annual training sessions will be conducted across the firm to spread compliance awareness, identify emerging money-laundering typologies, and ensure strict adherence.

9. Compliance, Cooperation & Review

  • 9.1. Stoic Wealth remains committed to absolute cooperation with all statutory law enforcement authorities, providing necessary client or transaction details whenever legally mandated.

  • 9.2. This AML policy is subject to a mandatory periodic review to evaluate its ongoing operational effectiveness and ensure alignment with updated SEBI and FIU-IND regulatory guidelines.