VOGUE COMMERCIAL COMPANY LIMITED
Manual for Prevention of Money Laundering Act, 2002
To prevent and control Money Laundering, we have appointed Mr. Rajesh Jain, Vice
President Technical & Administration as a “Principal Officer” in terms of Money
Laundering Act, 2002 and the same were intimated to FIU-DIRECTOR, Chanakyapuri,
Delhi for all segments i.e. NSE and DPs – (NSDL & CDSL).
We have adopted the following four specific parameters, pursuant to the latest
SEBI Master circular no. ISD/AML/CIR-1/2008 dated 19-Dec-2008, which are related
to the overall ‘Client Due Diligence Process’ :
a) Policy for acceptance of clients
b) Procedure for identifying the clients of special category
c) Transaction monitoring and reporting especially Suspicious Transactions
d) Employees’ Hiring / Employee’s Training / Investor Education
(a) Policy for acceptance of clients
We are taking following safeguards while accepting the clients:
- We have instructed our account opening section not to open any account in a
fictitious / benami name or on an anonymous basis in any circumstances in
respect of NSE and DP.
- We have not been allowing any account to be opened, where it is unable to apply
appropriate clients due diligence measures / KYC policies.
- We have been regularly updating KYC profile of “clients of special category”
defined under Money Laundering Act 2002, if any.
- We have been properly complying documentation requirement and other information
in respect of different classes of clients depending on perceived risk and
having regard with the requirement to the Prevention of Money Laundering Act
2002, guidelines issued by RBI and SEBI from time to time.
- We have not been allowing any client to act on behalf of another person /
- We have been taking special caution in case of account opening of NRI, OBC, FIIs
(b) Procedure for identifying the clients
- The ‘Know your Client’ (KYC) policy is clearly defined and adopted under the
supervision of Principal Officer.
- We have been identifying the clients by using reliable sources including
documents / information
- We have seen each original documents prior to acceptance of a copy and same be
stamped “Verified with the original”. The information collected by us is enough
to satisfy competent authorities (regulatory / enforcement authorities) in
future that due diligence was observed by us in compliance with the Guidelines.
- We sort out the clients of special category and update the same after detailed
analysis of financial information furnished by the client and his trades
involving higher volume on daily basis. We always ensure that in respect of
these clients proper care is taken in respect of financial transactions. For
monitoring the funds received by the respective clients we have proper system to
get the thorough check by matching the bank details with the date base available
with us. If there is any mismatch then we give the credit of the amount only
when he updates the bank account details with us and same is updated in our data
(c) Transaction monitoring and reporting especially Suspicious
- We have been taking close surveillance, where transaction amounting to Rs. 10
Lacs or more.
- We have not been allowing any cash transaction with client.
Apart from this there is also proper system to generate, monitor and report the suspicious transaction report.
- Generation of STR
We have adequate system to get STR files from NSDL/CDSL on fortnightly
basis and we keep the log of the same for our records
2. Monitoring of STR
Once we received the STR files we check and verify the details of each and every
clients with the records available with us in respect of bank account and volume
of transactions by means of their financial capabilities.
For monitoring the funds received by the respective clients we have proper
system to get the thorough check by matching the bank details with the date base
available with us. If there is any mismatch then we give the credit of the
amount only when he updates the bank account details with us and same is updated
in our data base also.
For monitoring the large volumes done by the clients we at the end of day
scrutinize and analyze the volumes of each and every client with the help of
trail balance of the particular trade date and assess his financial capabilities
based on the financial information provided by them to us. If there is any
discrepancy found then we call the client and take the reasons and source of
funds for these trades for our satisfaction.
3. Reporting of STR
As we verify the STR in detail and same is found not suspicious and hence ‘NIL’
record is kept by us and there is no need to report the same to FIU-India.
The Principal Officer would act as a central reference point in facilitating
onward reporting of suspicious transactions and for playing an active role in
the identification and assessment of potentially suspicious transactions.
(d) Employees’ Hiring/Employee’s Training/ Investor Education
Hiring of Employees
There is proper system of screening procedures to ensure high standards when
employees are hired for the position vacant with the organization. Especially
the employees in the category of senior executive level and accounts head are
selected who are highly competent to ensure and comply the provisions of PMLA
Act, 2002 and rules made there under in true sense.
We have policy for ongoing employee training programme so that the total staffs
of our company completely aware of the provisions of AML and CFT procedures and
amendments thereof. These training programmes are totally focused for frontline
staff, back office staff, compliance staff, risk management staff and staff
dealing with new customers as it is very crucial that all those concerned fully
understand the rationale behind these guidelines, obligations and requirements,
implement them consistently and are sensitive to the risks of their systems
being misused by unscrupulous elements, if there is any lapse on the part of any
staffs of the company.
To implement AML/CFT provisions in true sense there is need to get certain
information from investors which may be of personal nature or which has hitherto
never been called for. Such information can include documents evidencing source
of funds/income tax returns/bank records etc. To satisfy the investors on these
aspects so that they can easily provide the information to us we have made them
aware of PMLA provisions by way of literature formulated by us for all the
(e) Other parameters
Retention of Records
We have observed the following document retention:
a. We have bound to maintain all necessary records, if any, on transactions,
both domestic and international at least for the minimum period prescribed under
the relevant Act (PMLA, 2002 as well SEBI Act, 1992) and other legislations,
Regulations or exchange bye-laws or circulars.
b.We have also bound to kept records, if any, on customer identification (e.g.
copies or records of official identification documents like passports, identity
cards, driving licenses or similar documents), account files and business
correspondence for the same period.
In situations where the records relate to on-going investigations or
transactions which have been the subject of a suspicious transaction reporting,
they must be retained until it is confirmed that the case has been closed.