• Obtaining sufficient information in order to identify persons who beneficially own or control the securities account. Whenever it is apparent that the securities acquired or maintained through an account are beneficially owned by a party other than the client, that party shall be identified using client identification and verification procedures. The beneficial owner is the natural person or persons who ultimately own, control or influence a client and/or persons on whose behalf a transaction is being conducted. It also incorporates those persons who exercise ultimate effective control over a legal person or arrangement.
• Verify the client’s identity using reliable, independent source documents, data or information. Where the client purports to act on behalf of juridical person or individual or trust, SHRENI SHARES LIMITED shall verify that any person purporting to act on behalf of such client is so authorized and verify the identity of that person;
  Provided that in case of a Trust, the reporting entity shall ensure that trustees disclose their status at the time of commencement of an account- based relationship.
  Identify beneficial ownership and control, i.e., determine which individual(s) ultimately own(s) or control(s) the client and/or the person on whose behalf a transaction is being conducted:
  • where the client is a company
    the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has a controlling ownership interest or who exercises control through other means Explanation: - For the purpose of this sub-clause: -
    • "Controlling ownership interest" means ownership of or entitlement to more than ten per cent of shares or capital or profits of the company;
    • "Control" shall include the right to appoint majority of the directors or to control the management or policy decisions including by virtue of their shareholding or management rights or shareholders agreements or voting agreements;
  • where the client is a partnership firm, the beneficial owner is the natural person(s) who, whether acting alone or together, or through one or more juridical person, has ownership of/ entitlement to more than ten percent of capital or profits of the partnership or who exercises control through other means. Explanation:- For the purpose of this clause:- “Control” shall include the right to control the management or policy decision;
  • where the client is an unincorporated association or body of individuals, the beneficial owner is the natural person(s), who, whether acting alone or together, or through one or more juridical person, has ownership of or entitlement to more than fifteen per cent. Page 4 of 6 of the property or capital or profits of such association or body of individuals;
  • where no natural person is identified under (a) or (b) or (c) above, the beneficial owner is the relevant natural person who holds the position of senior managing official;
  • Where the client is a trust, the identification of beneficial owner(s) shall include identification of the author of the trust, the trustee, the beneficiaries with ten per cent or more interest in the trust and any other natural person exercising ultimate effective control over the trust through a chain of control or ownership; and
  • where the client or the owner of the controlling interest is an entity listed on a stock exchange in India, or it is an entity resident in jurisdictions notified by the Central Government and listed on stock exchanges in such jurisdictions notified by the Central Government, or it is a subsidiary of such listed entities, it is not necessary to identify and verify the identity of any shareholder or beneficial owner of such entities.
  • Applicability for foreign investors: SHRENI SHARES LIMITED dealing with foreign investors’ may be guided by SEBI Master Circular SEBI/HO/AFD-2/CIR/P/2022/175 dated December 19,2022 and amendments thereto, if any, for the purpose of identification of beneficial ownership of the client;
  • The Stock Exchanges and Depositories shall monitor the compliance of the aforementioned provision on identification of beneficial ownership through half yearly internal audits. In case of mutual funds, compliance of the same shall be monitored by the Boards of the Asset Management Companies and the Trustees and in case of other registered intermediaries, by their Board of Directors.
• Verify the identity of the beneficial owner of the client and/or the person on whose behalf a transaction is being conducted, corroborating the information provided in relation to (iii)
• Understand the ownership and control structure of the client;
• Conduct ongoing due diligence and scrutiny, i.e. Perform ongoing scrutiny of the transactions and account throughout the course of the business relationship to ensure that the transactions being conducted are consistent with our knowledge of the client, its business and risk profile, taking into account, where necessary, the client’s source of funds.
• SHRENI SHARES LIMITED shall review the due diligence measures including verifying again the identity of the client and obtaining information on the purpose and intended nature of the business relationship, as the case may be, when there are suspicions of money laundering or financing of the activities relating to terrorism or where there are doubts about the adequacy or veracity of previously obtained client identification data; and
• SHRENI SHARES LIMITED shall periodically update all documents, data or information of all clients and beneficial owners collected under the CDD process such that the information or data collected under client due diligence is kept up-to-date and relevant, particularly for high risk clients.
• SHRENI SHARES LIMITED shall register the details of a client, in case of client being a non-profit organisation, on the DARPAN Portal of NITI Aayog, if not already registered, and maintain such registration records for a period of five years after the business relationship between a client and the registered intermediary has ended or the account has been closed, whichever is later.
• Non-profit organization” means any entity or organisation, constituted for religious or charitable purposes referred to in clause (15) of section 2 of the Income-tax Act, 1961 (43 of 1961), that is registered as a trust or a society under the Societies Registration Act, 1860 (21 of 1860) or any similar State legislation or a Company registered under the section 8 of the Companies Act, 2013 (18 of 2013).

Reliance on third party for carrying out Client Due Diligence (CDD):

SHRENI SHARES LIMITED may rely on a third party for the purpose of :

• identification and verification of the identity of a client and
• Determination of whether the client is acting on behalf of a beneficial owner, identification of the beneficial owner and verification of the identity of the beneficial owner. Such third party shall be regulated, supervised or monitored for, and have measures in place for compliance with CDD and record-keeping requirements in line with the obligations under the PML Act.

Such reliance shall be subject to the conditions that are specified in Rule 9 (2) of the PML Rules and shall be in accordance with the regulations and circulars/ guidelines issued by SEBI from time to time.

General:

SHRENI SHARES LIMITED shall frame own internal directives based on experience in dealing with their clients and legal requirements as per the established practices.

SHRENI SHARES LIMITED shall conduct ongoing due diligence where it notices inconsistencies in the information provided.

There shall be no minimum investment threshold/ category-wise exemption available for carrying out CDD measures.

No transaction or account-based relationship shall be undertaken withoutfollowing the CDD procedure.”

In case of transactions being suspicious in nature and relate to money laundering or terrorist financing, and SHRENI SHARES LIMITED believes that performing the CDD process will tip-off the client, SHRENI SHARES LIMITED shall not pursue the CDD process, and shall instead file a STR with FIU-IND.

• SHRENI SHARES LIMITED shall not allow the opening of or keep any anonymous account or account in fictitious names or account on behalf of other persons whose identity has not been disclosed or cannot be verified.
• Factors of risk perception (in terms of monitoring suspicious transactions) of the client are clearly defined having regard to clients’ location (registered office address, correspondence addresses and other addresses if applicable), nature of business activity, trading turnover etc. and manner of making payment for transactions undertaken. The parameters shall enable classification of clients into low, medium and high risk. Clients of special category (as given below) may, if necessary, be classified even higher; Such clients require higher degree of due diligence and regular update of Know Your Client (KYC) profile.
• SHRENI SHARES LIMITED shall undertake enhanced due diligence measures as applicable for Clients of Special Category (CSC). CSC shall include the following:
  • Non - resident clients;
  • High net-worth clients;
  • Trust, Charities, Non-Governmental Organizations (NGOs) and organizations receiving donations;
  • Companies having close family shareholdings or beneficial ownership;
  • Politically Exposed Persons (PEP).
    Politically Exposed Persons” (PEPs). PEP shall have the same meaning as given in clause (db) of sub-rule (1) of rule 2 of the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005. The additional norms applicable to PEP as contained in the subsequent paragraph 14 of the master circular shall also be applied to the accounts of the family members or close relatives / associates of PEPs;
  • Clients in high risk countries. While dealing with clients from or situate in high risk countries or geographic areas or when providing delivery of services to clients through high risk countries or geographic areas i.e. places where existence or effectiveness of action against money laundering or terror financing is suspect, apart from being guided by the FATF statements that inter alia identify such countries or geographic areas that do not or insufficiently apply the FATF Recommendations, published by the FATF on its website (www.fatf-gafi.org) from time to time, we will also independently access and consider other publicly available information along with any other information which they may have access to. However, this shall not preclude from entering into legitimate transactions with clients from or situate in such high risk countries and geographic areas or delivery of services through such high risk countries or geographic areas.
    The intermediary shall specifically apply EDD measures, proportionate to the risks, to business relationships and transactions with natural and legal persons (including financial institutions) form countries for which this is called for by the FATF.
  • Non face to face clients.
    Non face to face clients means clients who open accounts without visiting the branch/offices of the SHRENI SHARES LIMITED or meeting the officials of SHRENI SHARES LIMITED Video based customer identification process is treated as face-to-face onboarding of clients.
  • Clients with dubious reputation as per public information available.
    In addition to above list, we shall exercise independent judgment to ascertain whether any other set of clients shall be classified as CSC or not.
• Documentation requirements and other information to be collected in respect of different classes of clients depending on the perceived risk and having regard to the requirements of Rule 9 of the PML Rules, Directives and Circulars issued by SEBI from time to time.
• An account is not opened where we are unable to apply appropriate CDD measures. This shall apply in cases where it is not possible to ascertain the identity of the client, or the information provided to us is suspected to be non - genuine, or there is perceived non - co-operation of the client in providing full and complete information. SHRENI SHARES LIMITED shall not continue to do business with such a person and file a suspicious activity report. It shall also evaluate whether there is suspicious trading in determining whether to freeze or close the account. SHRENI SHARES LIMITED shall be cautious to ensure that it does not return securities or money that may be from suspicious trades. However, SHRENI SHARES LIMITED shall consult the relevant authorities in determining what action it shall take when it suspects suspicious trading.
• The circumstances under which the client is permitted to act on behalf of another person / entity shall be clearly laid down. It shall be specified in what manner the account shall be operated, transaction limits for the operation, additional authority required for transactions exceeding a specified quantity/value and other appropriate details. Further the rights and responsibilities of both the persons i.e. the agent- client registered with Axis Capital Limited, as well as the person on whose behalf the agent is acting shall be clearly laid down. Adequate verification of a person’s authority to act on behalf of the client shall also be carried out.
• Necessary checks and balance will be put into place before opening an account so as to ensure that the identity of the client does not match with any person having known criminal background or is not banned in any other manner, whether in terms of criminal or civil proceedings by any enforcement agency worldwide.
• The CDD process shall necessarily be revisited when there are suspicions of ML/TF.

• SHRENI SHARES LIMITED shall put in place appropriate risk management systems to determine whether a client or potential client or the beneficial owner of such client is a politically exposed person. Such procedures shall include seeking relevant information from the client, referring to publicly available information or accessing the commercial electronic databases of PEPs.
• Senior management approval will be taken for establishing business relationships with PEPs. Where a client has been accepted and the client or beneficial owner is subsequently found to be, or subsequently becomes a PEP, SHRENI SHARES LIMITED shall obtain senior management approval to continue the business relationship.
• SHRENI SHARES LIMITED shall also take reasonable measures to verify the sources of funds as well as the wealth of clients and beneficial owners identified as PEP.
• The client shall be identified by using reliable sources including documents / information. SHRENI SHARES LIMITED shall obtain adequate information to satisfactorily establish the identity of each new client and the purpose of the intended nature of the relationship.
• The information must be adequate enough to satisfy competent authorities (regulatory / enforcement authorities) in future that due diligence was observed in compliance with the directives. Each original document shall be seen prior to acceptance of a copy.
• Failure by prospective client to provide satisfactory evidence of identity shall be noted and reported to the higher authority by SHRENI SHARES LIMITED.

• a. To undertake the ML/TF risk assessments prior to the launch or use of such products, practices, services, technologies; and
• b. Adoption of a risk based approach to manage and mitigate the risks.

• Regular monitoring of transactions is vital for ensuring effectiveness of the AML procedures. We shall pay special attention to all complex unusually large transactions or patterns which appear to have no economic purpose. The RMS team shall specify internal threshold limits for each class of client accounts and pay special attention to transactions which exceed these limits. RMS team under online and compliance under offline surveillance keep track of the transactions.
  • SHRENI SHARES LIMITED shall not accept cash from any clients.
  • Record of all transactions and KYC documents collected from the clients shall be maintained at least for such period as prescribed under the relevant regulations. Attempt shall be made to maintain electronic scanned copies of client documentation.
• Any transactions needing special attention such as complex transactions, unusually large transactions or patterns which appear to have no economic rationale shall be brought to the notice of the Principal Officer. The background including all documents, office records, memorandums, and clarifications sought pertaining to such transactions and purpose thereof shall also be examined carefully and findings shall be recorded in writing. Further such findings, records and related documents shall be made available to auditors and also to SEBI, stock exchanges, FIU-IND or other relevant authorities during audit, inspection or as and when required.
• Client due diligence measures will also be applied to existing clients on the basis of materiality and risk, and due diligence shall be conducted on such existing relationships appropriately. The extent of monitoring shall be aligned with the risk category of the client.
• We shall ensure compliance with the record of the transactions preserved and maintained in terms of Section 12 of the PMLA and that transactions of a suspicious nature or any other transactions notified under Section 12 of the Act are reported to the Director, FIU-IND. Suspicious transactions shall also be regularly reported to the higher authorities within the intermediary.
• The compliance team of the intermediary will randomly examine a selection of transactions undertaken by clients to comment on their nature, i.e., whether they are in the nature of suspicious transactions or not.

• Transactions in the nature as below are few examples of suspicious transactions and any such suspicious transaction should be reported immediately to the Principal Officer mentioned hereunder and his advice taken:
  • Clients whose identity or verification seems difficult or client appears not to cooperate.
  • Substantial increase in business without apparent cause.
  • Asset management services for clients where the source of the funds is not clear or not in keeping with clients’ apparent standing/business activity.
  • Clients based in high risk jurisdictions.
  • Clients transferring large sums of money to or from overseas locations with instructions for payment in cash.
  • Attempted transfer of investment proceeds to apparently unrelated third parties.
  • Requests for transfer of investment proceeds to apparently unrelated third parties, unusual transactions by CSCs and business undertaken by shell corporations, offshore banks/financial services, business reported in the nature of export-import of small items, etc.
• Any suspicious transaction shall be immediately notified to the Principal Officer or any other designated officer. The notification may be done in the form of a detailed report with specific reference to the clients, transactions and the nature/reason of suspicion. However, it shall be ensured that there is continuity in dealing with the client as normal until told otherwise and the client shall not be told of the report or suspicion. In exceptional circumstances, consent may not be given to continue to operate the account, and transactions may be suspended, in one or more jurisdictions concerned in the transaction, or other action taken. The Principal Officer and other appropriate compliance, risk management and related staff members will have timely access to client identification data and CDD information, transaction records and other relevant information.
• It is likely that in some cases transactions are abandoned or aborted by clients on being asked to give some details or to provide documents. SHRENI SHARES LIMITED will report all such attempted transactions in STRs, even if not completed by clients, irrespective of the amount of the transaction.
• In case of clients of high risk countries including countries where existence and effectiveness of money laundering controls is suspect or which do not or insufficiently apply FATF standards, shall also be subject to appropriate counter measures like enhanced scrutiny of transactions, enhanced relevant reporting mechanisms or systematic reporting of financial transactions, and applying enhanced due diligence while expanding business relationships with the identified country or persons in that country.

• The nature of the transactions;
• The amount of the transaction and the currency in which it is denominated;
• The date on which the transaction was conducted; and
• The parties to the transaction.

• It will be ensured to comply with the record keeping requirements contained in the SEBI Act, 1992, Rules and Regulations made thereunder, PMLA as well as other relevant legislation, Rules, Regulations, Exchange Byelaws and Circulars.
• We shall maintain such records as are sufficient to permit reconstruction of individual transactions (including the amounts and types of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of criminal behavior.
• In case of any suspected laundered money or terrorist property, the competent investigating authorities would need to trace through the audit trail for reconstructing a financial profile of the suspect account. To enable this reconstruction, SHRENI SHARES LIMITED shall retain the following information for the accounts of their clients in order to maintain a satisfactory audit trail:
  • The beneficial owner of the account;
  • The volume of the funds flowing through the account;
  • For selected transactions:
    • The origin of the funds;
    • The form in which the funds were offered or withdrawn (e.g. cheques, demand drafts etc.);
    • The identity of the person undertaking the transaction;
    • The destination of the funds;
    • The form of instruction and authority.
• We shall ensure that all client and transaction records and information are available on a timely basis to the competent investigating authorities. Where required by the investigating authority, they shall retain certain records, e.g. client identification, account files, and business correspondence, for periods which may exceed those required under the SEBI Act, Rules and Regulations framed thereunder PMLA, other relevant legislations, Rules and Regulations.
• SHRENI SHARES LIMITED shall have to maintain a record of all the transactions; the nature & value of which has been prescribed under Rule 3 of PML Rules. Such transactions shall include:
  • All cash transactions of the value of more than ten lakh rupees or its equivalent in foreign currency;
  • All series of cash transactions integrally connected to each other which have been individually valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds an amount of ten lakh rupees or its equivalent in foreign currency;
  • All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery of a valuable security or a document has taken place facilitating the transactions;
  • All suspicious transactions whether or not made in cash and including, inter-alia, credits or debits into or from any non-monetary account such as demat account, security account maintained by the registered intermediary.

• We shall take appropriate steps to evolve an internal mechanism for proper maintenance and preservation of such records and information in a manner that allows easy and quick retrieval of data as and when requested by the competent authorities. Records mentioned in Rule 3 of PML Rules have to be maintained and preserved for a period of five / eight (for DP records) years from the date of transactions between the client and SHRENI SHARES LIMITED.
• We will formulate and implement the client identification procedure containing the requirements as laid down in Rule 9 of the PML Rules and such other additional requirements that it considers appropriate. Records evidencing the identity of its clients and beneficial owners as well as account files and business correspondence shall be maintained and preserved for a period of five years after the business relationship between a client and SHRENI SHARES LIMITED has ended or the account has been closed, whichever is later and for other regulatory the same shall be preserved for eight years.
• In situations where the records relate to on-going investigations or transactions which have been the subject of a suspicious transaction reporting, they shall be retained until it is confirmed that the case has been closed.
• SHRENI SHARES LIMITED will maintain and preserve the records of information related to transactions, whether attempted or executed, which are reported to the Director, FIU – IND, as required under Rules 7 and 8 of the PML Rules, for a period of five years from the date of the transaction between the client and SHRENI SHARES LIMITED.

• SHRENI SHARES LIMITED shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA) and amendments thereto, they do not have any accounts in the name of individuals or entities appearing in the lists of individuals and entities suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC).
• In order to ensure expeditious and effective implementation of the provisions of Section 51A of UAPA, SHRENI SHARES LIMITED will refer to the procedure outlined by the Government of India through an order dated February 02, 2021, and the amended guidelines vide Gazette Notification dated June 08, 2021, for strict compliance.

• SHRENI SHARES LIMITED shall take note of the list of individuals and entities designated as terrorists by the Ministry of Home Affairs, in pursuance of Section 35(1) of UAPA 1967, as and when communicated by SEBI.
• All orders under Section 35(1) and 51A of UAPA relating to funds, financial assets, or economic resources or related services circulated by SEBI from time to time shall be taken note of for compliance.
• An updated list of individuals and entities subject to various sanction measures such as freezing of assets/accounts, denial of financial services, etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs), can be accessed at:https://press.un.org/en/content/press-release.
  
  The details of the lists are as under:
  • The “ISIL (Da’esh) & Al-Qaida Sanctions List”, which includes names of individuals and entities associated with Al-Qaida. The updated list is available at:https://www.un.org/securitycouncil/sanctions/1267/press-releases.
  • The list issued by United Security Council Resolutions 1718 of designated Individuals and Entities linked to the Democratic People's Republic of Korea is available at:https://www.un.org/securitycouncil/sanctions/1718/press-releases.
• SHRENI SHARES LIMITED will ensure that accounts are not opened in the name of anyone whose name appears in the said list.
• SHRENI SHARES LIMITED will continuously scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list.
• SHRENI SHARES LIMITED will maintain updated designated lists in electronic form and run a check on the given parameters on a regular basis to verify whether the designated individuals/entities are holding any funds, financial assets, or economic resources or related services held in the form of securities with them.
• SHRENI SHARES LIMITED shall leverage the latest technological innovations and tools for effective implementation of name screening to meet the sanctions requirements.
• SHRENI SHARES LIMITED will also file a Suspicious Transaction Report (STR) with FIU-IND covering all transactions carried through or attempted in the accounts covered under the list of designated individuals/entities under Section 35(1) and 51A of UAPA.
• Full details of accounts bearing resemblance with any of the individuals/entities in the list shall immediately be intimated to the Central [designated] Nodal Officer for the UAPA, at Fax No. 011-23092551 and also conveyed over telephone No. 011-23092548. The particulars apart from being sent by post shall necessarily be conveyed by email to:jsctcr-mha@gov.in.
• SHRENI SHARES LIMITED shall also send a copy of the communication mentioned above to the UAPA Nodal Officer of the State/UT where the account is held and to SEBI and FIU-IND, without delay. The communication shall be sent to SEBI through post and through email (sebi_uapa@sebi.gov.in) to the UAPA nodal officer of SEBI, Deputy General Manager, Division of FATF, Market Intermediaries Regulation and Supervision Department, Securities and Exchange Board of India, SEBI Bhavan II, Plot No. C7, “G” Block, Bandra Kurla Complex, Bandra (E), Mumbai 400051. The consolidated list of UAPA Nodal Officers is available at the website of the Ministry of Home Affairs, Government of India.
• FATF Statements circulated by SEBI from time to time, and publicly available information, for identifying countries which do not or insufficiently apply the FATF Recommendations, shall be considered by SHRENI SHARES LIMITED.
• SHRENI SHARES LIMITED will take into account the risks arising from deficiencies in AML/CFT regimes of the jurisdictions included in the FATF Statements before having legitimate trade and business transactions with the countries and jurisdictions mentioned in the FATF statements.

• Information relating to cash and suspicious transactions will be reported to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address:
  
  

  Director, FIU-IND

  Financial Intelligence Unit - India
  6th Floor, Tower-2, Jeevan Bharati Building, Connaught Place, New Delhi-110001, INDIA
  Telephone: 91-11-23314429, 23314459
  91-11-23319793 (Helpdesk)
  Email: helpdesk@fiuindia.gov.in (For FINnet and general queries)
  ctrcell@fiuindia.gov.in (For Reporting Entity / Principal Officer registration related queries)
  complaints@fiuindia.gov.in
  Website:http://fiuindia.gov.in
• SHRENI SHARES LIMITED shall go through all the reporting requirements (Brochure on FIU) and formats available on the website of FIU–IND under the section Home → FINNET 2.0 → User Manuals and Guides → Reporting Format (Reporting Format).
• These documents contain detailed directives on the compilation and manner of submission of the reports to FIU-IND. The related hardware and technical requirements for preparing reports, data files, and data structures are also detailed in these documents.
• The following time schedule will be adhered to while reporting:
  • The Cash Transaction Report (CTR) for each month shall be submitted to FIU-IND by the 15th of the succeeding month.
  • The Suspicious Transaction Report (STR) shall be submitted within 7 days of arriving at a conclusion that any transaction or series of transactions are of suspicious nature. The Principal Officer shall record his reasons for treating such transactions as suspicious.
  • The Non-Profit Organization Transaction Reports (NTRs) for each month shall be submitted to FIU-IND by the 15th of the succeeding month.
  • The Principal Officer will be responsible for timely submission of CTR, STR, and NTR to FIU-IND.
  • NIL reporting needs to be made to FIU-IND in case there are no cash, suspicious, or non-profit organization transactions to be reported.
  • “Non-profit organization” means any entity constituted for religious or charitable purposes referred to in clause (15) of section 2 of the Income-tax Act, 1961, registered as a trust, a society under the Societies Registration Act, 1860, or a Section 8 company under the Companies Act, 2013.
  • SHRENI SHARES LIMITED, its Directors, officers, and employees shall ensure that the fact of maintenance referred to in Rule 3 of PML Rules and furnishing of information to the Director is kept confidential.
  • SHRENI SHARES LIMITED shall not put any restrictions on operations in accounts where an STR has been made and shall ensure there is no “tipping off” to the client at any level.
  • STR shall be filed irrespective of the transaction amount if there are reasonable grounds to believe that the transaction involves proceeds of crime.
  • Confidentiality requirements do not inhibit information sharing among entities within the group.

• Appointment of a Principal Officer:

  To ensure that SHRENI SHARES LIMITED properly discharges its legal obligations to report suspicious transactions to the authorities, the Principal Officer shall act as a central reference point for facilitating onward reporting of suspicious transactions and play an active role in identifying and assessing potentially suspicious transactions. The Principal Officer shall have access to and be able to report directly to senior management at the next reporting level or the Board of Directors.
  
  Names, designations, and addresses (including email addresses) of the Principal Officer, including any changes therein, shall be intimated to the Office of the Director, FIU-IND.
  
  In terms of Rule 2(f) of the PML Rules, the definition of a Principal Officer is as follows:
  "Principal Officer means an officer designated by a registered intermediary; provided that such officer shall be an officer at the management level."

• Appointment of a Designated Director:

  SHRENI SHARES LIMITED shall designate the Managing Director or a Whole-Time Director duly authorized by the Board of Directors as the Designated Director in terms of Rule 2(ba) of the PML Rules.
  
  The name, designation, and address (including email address) of the Designated Director, including any changes therein, shall also be intimated to the Office of the Director, FIU-IND.

• Hiring of Employees:

  As a policy, SHRENI SHARES LIMITED has adequate screening procedures, including appropriate reference checks, in place to ensure high standards when hiring employees. For key positions within the organization, we ensure that they are suitable and competent to perform their duties to combat the risks of money laundering, terrorist financing, and to match the size and nature of the business. Employees taking up such key positions are assessed to ensure suitability and competence for their responsibilities.

• Training of Employees:

  SHRENI SHARES LIMITED will, on an ongoing basis, arrange and organize employee training programs for frontline staff, back-office staff, compliance staff, risk management staff, and staff dealing with new customers. These programs ensure that employees are adequately trained in AML and CFT procedures and understand the rationale behind these guidelines, obligations, and requirements.

• Investor Education:

  In order to implement AML/CFT measures, SHRENI SHARES LIMITED will communicate various regulatory directives issued from time to time by regulators to clients, to educate them about the objectives of the AML/CFT program. We shall also prepare specific literature, pamphlets, and other materials to educate clients about the importance and objectives of the AML/CFT framework.

• On the basis of the order issued by the Government of India, Ministry of Finance vide F No. P-12011/14/2022-ES Cell DOR (“the Order”) detailing the procedure for implementation of Section 12A of the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act 2005 (“WMD Act”), Shreni Shares Ltd. shall:
  • Maintain the list of individuals/entities (“Designated List”) and update it, without delay, in terms of paragraph 2.1 of the Order.
  • Verify if the particulars of the entities/individual, party to the financial transactions, match with the particulars of the Designated List and in case of match, Shreni Shares Ltd. shall not carry out such transaction and shall immediately inform the transaction details with full particulars of the funds, financial assets or economic resources involved to the Central Nodal Officer (“CNO”) at FIU India, without delay.
  • Run a check, on the given parameters, at the time of establishing a relation with a client and on a periodic basis to verify whether individuals and entities in the Designated List are holding any funds, financial assets or economic resources or related services, in the form of bank accounts, stocks, insurance policies etc., and in case of any such findings Shreni Shares Ltd. shall immediately report to the CNO at FIU India.
  • In case of any such reporting to CNO at FIU India, Shreni Shares Ltd. shall simultaneously send a copy of the communication, mentioned in paragraphs 59(ii) and 59(iii) above, without delay, to the Nodal Officer of SEBI through email.
  • Shreni Shares Ltd. shall, if it believes beyond doubt that funds and assets held by a client would fall under the purview of Section 12(A)(2)(a) or Section 12(A)(2)(b) of the WMD Act, file a Suspicious Transaction Reporting (STR) with FIU India covering all transactions in the said account.
  • While running all the aforementioned checks and respective reporting, Shreni Shares Ltd. shall comply with the provisions regarding exemptions from the above orders of the CNO and inadvertent freezing of accounts as may be applicable.