AML & PMLA Policy — Trade Grow

1. Regulatory Framework & Scope

The Prevention of Money Laundering Act, 2002 (PMLA), together with SEBI Master Circulars on AML/CFT, mandates that all registered stock brokers establish comprehensive Client Due Diligence, record preservation, and suspicious transaction reporting mechanisms.

Trade Grow enforces a zero-tolerance policy against money laundering, terror financing, and financial fraud.

2. Client Due Diligence (CDD)

Prior to activating trading privileges, Trade Grow performs thorough verification:

Identity Verification: Direct validation of PAN with the Income Tax Department and Aadhaar-based e-KYC through licensed KRAs.
In-Person Verification (IPV): Live video or digital photo IPV to prevent impersonation or proxy account creation.
Beneficial Ownership: Verification of ultimate natural persons holding ownership interest in non-individual entities.
Sanctions Screening: Checking all applicant names against UN Security Council (UNSC) lists, MHA UAPA banned lists, and statutory PEP (Politically Exposed Persons) databases.

3. Strict Prohibition of Third-Party Transfers

All funds and securities transfers must be in the client’s own name. Under Indian broking regulations:

Fund deposits must originate from a verified bank account registered in your name.
Credits from accounts belonging to spouses, parents, siblings, or friends are strictly rejected and returned.
All payout requests are remitted solely to your primary registered bank account.
Cash deposits or cash withdrawals are completely prohibited.

4. Transaction Monitoring & Red Flags

Our automated risk management and compliance engines monitor trading activity for red flags:

Sudden, unexplained spikes in trading volume disproportionate to declared financial profile.
Circular trading, price manipulation, or synchronized order placement between related accounts.
Frequent changes in registered bank accounts or residential addresses without valid justification.
Attempts to execute trades in illiquid scrips at artificial off-market prices.

5. Reporting to FIU-IND

As a registered intermediary, Trade Grow is legally mandated to report to the Financial Intelligence Unit - India (FIU-IND):

Suspicious Transaction Reports (STR): Submitted where transactions give rise to reasonable suspicion of illicit origin or lack bona fide commercial purpose.
Non-Profit Organization Reports (NTR): As applicable under statutory rules.

In compliance with statutory “tipping off” prohibitions under PMLA, brokers are legally prohibited from informing clients when an STR has been submitted.

6. Principal Officer & Designated Director

In accordance with PMLA guidelines, Trade Grow has designated a Principal Officer responsible for AML compliance:

Designation: Principal Officer (PMLA)
Name: Information to be verified
Email: Information to be verified
Address: Information to be verified, Information to be verified