AML Policy

Anti-money Laundering (AML) & Combating Financing of Terrorism (CFT) Policy

ENTITY DETAILS

• Entity Name: Forever Research
• Registration Type: SEBI Registered Research Analyst
• SEBI Registration Number: INH000022783
• Registration Validity: August 20, 2025 – Perpetual
• BSE Enlistment Number: 6893
• Registered Office:
Adeesh Nilaya, TPK Road, Saptagiri Extension,
Near Nalanda Convent, Tumkur, Karnataka – 572102
• Compliance Officer: Pradeep Adimurthy
• Contact Details:
Email: foreverresearch49@gmail.com
Phone: +91 98863 73572
Website: https://www.foreverresearch.com/

1. PREAMBLE, PURPOSE & COMMITMENT

Forever Research (“the Firm”) adopts a comprehensive Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) Policy in accordance with:

• Prevention of Money Laundering Act, 2002 (PMLA)
• SEBI (Research Analyst) Regulations and applicable circulars
• Applicable statutory rules, amendments, and global AML/CFT standards

Objectives:

a) Prevent money laundering and terrorist financing
b) Ensure regulatory and statutory compliance
c) Support national and global AML/CFT initiatives
d) Assist competent authorities in investigation and enforcement

2. DEFINITIONS

For the purpose of this Policy:

a) Money Laundering: As defined under the Prevention of Money Laundering Act, 2002, including concealment, possession, acquisition, or use of proceeds of crime.

b) Beneficial Owner (BO): The natural person(s) who ultimately own(s) or control(s) a client and/or the person on whose behalf a transaction is being conducted, as defined under PML Rules.

c) Designated Director: A person designated by the Firm to ensure overall compliance with obligations under Chapter IV of the PMLA and Rules thereunder.

d) Principal Officer: An officer designated to ensure compliance with AML/CFT obligations and reporting to FIU-IND.

e) Suspicious Transaction: A transaction, whether or not made in cash, which gives rise to reasonable ground of suspicion that it may involve proceeds of crime.

f) Politically Exposed Person (PEP): Individuals who are or have been entrusted with prominent public functions in a foreign country or India.

3. SCOPE AND APPLICABILITY

This Policy applies to:

• All business operations and services of Forever Research
• All directors, employees, partners, and associates
• All clients and associated parties

The Firm ensures AML/CFT compliance across all operational levels.

4. GOVERNANCE STRUCTURE

4.1 Principal Officer

The designated Research Analyst shall act as the Principal Officer responsible for AML/CFT compliance.

4.2 Responsibilities

The Principal Officer shall:

a) Serve as the central AML compliance authority
b) Ensure policy implementation and adherence
c) Oversee record maintenance and regulatory reporting
d) Submit reports to FIU-IND
e) Conduct AML training programs
f) Issue internal compliance advisories
g) Notify FIU-IND of any changes in details or policy

5. CUSTOMER DUE DILIGENCE (CDD) & KYC FRAMEWORK

5.1 General Requirements

The Firm shall:

a) Verify identity and address prior to onboarding
b) Authenticate KYC documents against originals
c) Ensure PAN verification through IT/NSDL/KRA
d) Prohibit anonymous, fictitious, or benami accounts
e) Conduct transactions strictly via banking channels (no cash dealings)
f) Screen clients against sanctions and watchlists
g) Obtain declarations where required regarding legitimacy of funds

5.2 SEBI-Compliant CDD Procedures

The Firm shall:

• Identify and verify client and beneficial owner
• Apply CDD for account-based relationships and transactions above ₹50,000
• Understand the purpose of the business relationship
• Assess ownership and control structure

5.3 Enhanced Due Diligence (EDD)

EDD shall be applied for Clients of Special Category (CSC) including:

• NRIs
• HNIs
• Politically Exposed Persons (PEPs)
• Trusts, NGOs
• Clients from high-risk jurisdictions

5.4 Ongoing Monitoring

• Continuous transaction monitoring
• Periodic KYC updates
• Verification of source of funds and transaction consistency

5.5 Digital KYC

• Video-based verification
• Aadhaar-based authentication
• Secure digital onboarding processes

5.6 Regulatory Restriction Note

The Firm operates strictly within the scope of SEBI (Research Analyst) Regulations and does not undertake investment advisory or financial planning services. However, KYC and AML compliance shall be carried out as per PMLA and SEBI requirements.

5.7 Third-party Payments and Funding Controls

a) Payments shall be accepted only from the client’s registered bank account
b) Third-party payments are prohibited
c) Name mismatch shall trigger enhanced due diligence

6. RECORD MAINTENANCE AND RETENTION

The Firm shall maintain records of:

a) Aggregated connected transactions exceeding ₹10,00,000 monthly
b) Suspicious transactions including forgery or counterfeiting
c) Transaction details (nature, value, date, currency, parties)

The Firm does not permit any cash transactions. All payments shall be conducted strictly through regulated banking channels.

Retention Period:

• Minimum 10 years after cessation of relationship
• Longer if required for investigations

Accessibility:

Records shall be promptly retrievable for regulatory authorities.

7. MONITORING OF SUSPICIOUS ACTIVITIES

Red Flags:

a) Difficulty in identity verification
b) Lack of client cooperation
c) Unclear source of funds
d) Links to high-risk jurisdictions
e) Sudden increase in transactions
f) Unusual cross-border flows
g) Transfers to unrelated third parties
h) Use of shell/offshore entities

All such cases shall be escalated to the Principal Officer.

8. REPORTING TO FIU-IND

The Firm shall:

a) Submit CTR and STR reports as prescribed
b) Adhere to reporting timelines and formats
c) Maintain strict confidentiality (no tipping-off)
d) Maintain supporting documentation
e) Avoid restricting accounts solely due to STR filing
f) Carry out reporting as per FIU-IND guidelines

Employees shall not disclose:

a) Filing of STR
b) Ongoing investigations
c) Internal suspicion

Strict confidentiality shall be maintained.

9. INTERNAL AUDIT AND CONTROLS

Periodic audits shall ensure:

a) Compliance with AML policy
b) Effectiveness of detection/reporting systems
c) Review of exception reports
d) Quality of reporting
e) Employee awareness

10. EMPLOYEE TRAINING AND INVESTOR EDUCATION

10.1 Employee Training

• Regular AML/KYC training programs
• Specialized training for high-risk roles
• Delivery via lectures, memos, and digital tools

10.2 Investor Awareness

Clients shall be informed about:

• Importance of KYC/AML
• Regulatory compliance requirements

11. EMPLOYEE CONDUCT AND WHISTLEBLOWER POLICY

a) Employee accounts subject to AML scrutiny
b) Principal Officer’s accounts reviewed by senior management
c) Confidential reporting mechanism available
d) Protection against retaliation

12. CERTIFICATION REQUIREMENT

All relevant personnel must obtain:

NISM Series XXIV: AML and CFT Provisions in Securities Markets Certification

Applicable to:

• Research Analysts
• Compliance Officers
• Partners
• Directors

13. FEE REFUND POLICY

The Firm shall reimburse certification fees to eligible associates upon successful completion of the NISM examination.

14. POLICY REVIEW AND COMMUNICATION

a) Periodic review and updates
b) Immediate effect of regulatory amendments
c) Presentation before management/Board
d) Communication across all stakeholders

15. MONEY LAUNDERING REPORTING OFFICER (MLRO)

Entity: Forever Research
Email: foreverresearch49@gmail.com
Phone: +91 98863 73572

16. DATA PROTECTION AND CONFIDENTIALITY

The Firm shall:

a) Ensure confidentiality of client data
b) Comply with applicable data protection laws
c) Protect KYC data from unauthorized access

17. FINAL DECLARATION

Forever Research affirms that this AML/CFT Policy:

• Ensures full compliance with SEBI and PMLA requirements
• Aligns with international AML/CFT standards
• Upholds the highest standards of integrity, transparency, and governance

18. ADDITIONAL INFORMATION

For Terms & Conditions, Disclosures and Disclaimers, Investor Charter, and other information visit our official website: https://www.foreverresearch.com/