AML / CFT and PMLA

Clause 18 — Research Analyst

Params Data Provider Private Limited is a Research Analyst registered under the SEBI (Research Analysts) Regulations, 2014. Clause 18 of the Master Circular for Research Analysts (HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026 dated 06 February 2026) requires every Research Analyst to comply with SEBI’s master circular on AML standards, CFT, and the obligations of securities-market intermediaries under the Prevention of Money Laundering Act, 2002 (PMLA) and the Prevention of Money-laundering (Maintenance of Records) Rules, 2005 (PML Rules).

This page is the Research Analyst’s written AML/CFT policy for clients, staff, and examiners. It is approved by senior management and is reviewed when the PMLA, the PML Rules, or SEBI’s directions change, and at least once a year.

Master Circular for Research Analysts: HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026 dated 06 February 2026. AML/CFT Master Circular: SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2024/78 dated 06 June 2024.

What this Research Analyst does

• It publishes research and provides research services. It does not execute trades and does not open or operate a trading, demat, or bank account for a client.
• It does not take client funds for investment. Research fees, where charged, are collected only through banking channels such as bank transfer, UPI, or another permitted non-cash mode. Cash is not accepted.
• Client due diligence under this policy applies to fee-paying clients and to any other person with whom a business relationship is established, together with the KYC requirements in Clause 19 of the same Master Circular.
• The Research Analyst has no overseas branch and no majority-owned foreign subsidiary. If that changes, the stricter of the Indian and host-country AML/CFT standards will be applied, and SEBI will be informed where a host country prevents proper implementation.

Officers responsible under the PMLA

The PML Rules require a Principal Officer at management level and a Designated Director who ensures overall compliance with Chapter IV of the PMLA. For this company, the Designated Director is a director authorised to manage its affairs. Their name, designation, and address, and any change, are intimated to the Director, Financial Intelligence Unit – India (FIU-IND).

Staff report a concern about a client or a transaction to the Principal Officer at compliance@predictram.com. A client is not told that a report to FIU-IND is being considered or has been filed.

Client acceptance, identification, and due diligence

Written procedures cover the four parts of client due diligence required by the AML/CFT master circular: acceptance of clients, identification of clients, risk management, and monitoring.

• Identity is verified from reliable, independent documents or electronic sources before a fee-paying relationship begins. Where a person acts for a company, firm, trust, or other client, that person’s authority and identity are also verified.
• The purpose and intended nature of the relationship are recorded. For this Research Analyst, that purpose is the provision of research services.
• Beneficial ownership is identified. For a company or partnership, a natural person who owns or is entitled to more than ten per cent of the shares, capital, or profits, or who otherwise exercises control, is identified. For an unincorporated association or body of individuals, the threshold is more than fifteen per cent. For a trust, the author, trustee, settlor, protector, and beneficiaries with ten per cent or more interest are identified. Where no such natural person is found, the senior managing official is identified. A listed company in India, or a subsidiary of such a listed company, is treated as provided in the PML Rules. Thresholds follow the PML Rules as amended.
• A non-profit organisation is checked for registration on the DARPAN portal of NITI Aayog, and that record is kept.
• Client due diligence is repeated when the relationship continues, when information becomes doubtful, and when the risk of the client changes. Where completing due diligence would tip off the client, due diligence is not pursued and a suspicious transaction report is filed instead.
• Client identification is done by the Research Analyst. A third party is relied on only to the extent the PML Rules and the SEBI master circular allow.

Risk-based approach

Clients are placed in a low, medium, or high risk category using the client type, location, delivery channel, and whether the client or a beneficial owner is a politically exposed person. Politically exposed person has the meaning in the PML Rules, and the same care is applied to family members and close associates.

• A relationship with a politically exposed person, or with a client whose beneficial owner is a politically exposed person, is accepted only with senior-management approval. The same approval is taken if an existing client or beneficial owner later becomes a politically exposed person.
• For those relationships, reasonable measures are taken to verify the source of funds and the source of wealth.
• Higher-risk relationships receive enhanced due diligence and closer monitoring. Lower-risk relationships are not exempted from identification.

Sanctions, terrorist financing, and prohibited relationships

Before a relationship begins, and periodically afterwards, the client and beneficial owners are screened against the lists of individuals and entities designated under United Nations Security Council resolutions, Section 51A of the Unlawful Activities (Prevention) Act, 1967, and Section 12A of the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005, as circulated to intermediaries.

• No business relationship is started or continued with a designated person or entity. Funds, financial assets, or economic resources are not made available to such a person.
• A confirmed match is reported without delay to the authorities specified in those directions, including FIU-IND where a suspicious transaction report is required, and to SEBI’s UAPA nodal officer where that direction applies.
• Relationships with links to jurisdictions that do not apply, or insufficiently apply, the FATF recommendations are treated as higher risk.

The consolidated sanctions lists are those circulated by the relevant UN Security Council committees and by the Government of India. The FIU-IND site is https://fiuindia.gov.in.

Monitoring and reporting to FIU-IND

The relationship and the payments received for research services are monitored for activity that is inconsistent with the client’s profile. A suspicious transaction, including an attempted transaction, is reported to the Principal Officer at once. The Principal Officer records the reasons and, if satisfied, files a suspicious transaction report (STR) with the Director, FIU-IND.

• An STR is filed within seven days of the conclusion that the transaction, or a series of connected transactions, is suspicious, and without undue delay in reaching that conclusion.
• A cash transaction report is filed by the 15th of the following month only if a reportable cash transaction occurs. The policy of this Research Analyst is not to accept cash. No nil report is filed when there is nothing to report.
• A non-profit organisation transaction report, where one arises, is filed by the 15th of the following month.
• The Principal Officer is responsible for timely submission. Reports are filed on FIU-IND’s FINGate / FINNET system in the prescribed format. Filing is kept confidential.
• Directors, officers, and employees do not disclose to the client, before, during, or after the filing, that an STR or related information has been or will be provided to FIU-IND. Making a report is not, by itself, a reason to freeze the relationship.

FIU-IND: Director, Financial Intelligence Unit – India, 6th Floor, Tower-2, Jeevan Bharati Building, Connaught Place, New Delhi 110001. Website: https://fiuindia.gov.in.

Records

• Records of transactions required by the PML Rules are kept for five years from the date of the transaction between the client and the Research Analyst.
• Records evidencing the identity of the client and beneficial owners, account files, and business correspondence are kept for five years after the business relationship ends or the account is closed, whichever is later.
• Information on transactions reported to FIU-IND, whether attempted or executed, is kept for five years from the date of the transaction.
• Records are kept so that they can be retrieved when SEBI, RAASB, FIU-IND, or another competent authority asks for them.

Employees and clients

• People hired into roles that handle client identity, payments, or compliance are screened for suitability, having regard to the size of the business and the money-laundering risk of the role.
• Staff receive ongoing training on these obligations, with attention to people who onboard clients and people who handle compliance.
• Clients may be asked for information that is required only because of this framework, including information on the source of funds. That request comes from the PMLA and the SEBI AML/CFT directions, not from a demand to invest through the Research Analyst.
• Compliance with this policy is part of the annual compliance audit of the Research Analyst. Adverse findings of that audit, and the action taken, are published on the website when the audit report so requires.

A question about this policy can be sent to the Principal Officer at compliance@predictram.com or by telephone at +91-98733-87612, on Monday to Friday, 10:00 a.m. to 6:00 p.m. IST (except public holidays).