Access control is a mechanism to ensure that authorised personnel have access to the information
and information processing resources that are assigned to them. It also helps track the accountability.
Logical access control ensures that only authorised personnel have access to the information or data
in electronic form; this includes access to the Operating system, application, trading system and
This policy applies to all the users. The physical and logical access to information and information
processing resources are covered in this policy.
Logical Access Control
A unique User ID should be created for every individual who is given access to the information processing
facilities. IT department will create a new user-id and provide the rights as requested by the user’s
User rights modification
The concerned business team head must notify the IT department for modification of the rights of any user
whose job functions have changed or the user has been transferred to another department.
The team head must immediately notify the IT Department for disabling / deleting the user-id of any user
who has resigned / has been terminated from the service. The head should also mention the date on which
the user id should be disabled / deleted with the request. In emergencies, such requests can be made over
phone;however, it must be followed by an email.
On receipt of notification, the IT Department must immediately carry out the requested action on the specified
date. All user-ids of ex-employees, that were disabled, must be deleted after 15 days, unless explicitly
requested by the business team head.
Deactivation of user-ids
A user-id would be disabled if a user has not logged in for more than 45 days. In case the owner of this user-id
is not with the company any more, the IT Department should delete the user id after the Head of Department
authorizes the deletion through mail.
A user-id will be locked if there have been more than 3 invalid login attempts.
Reactivation of User Account
The IT Department should reactivate user accounts that have got locked / disabled after receiving a request
from the Department Head. IT Department will verify the validity of the user before reactivating the
Users must not share their user-ids. If there is a business requirement or need to share user-ids, this must
be authorized. Details of such User IDs if created must be shared solely within the designated members of the
group. IT Department will maintain a document on list of such user IDs.
Administrator (privileged) rights
Administrator logins and privileged access rights allow users to override system controls.
Users must not be allowed to work with “administrator” ID or with privileged rights. Where users need
administrative rights for executing their job responsibilities, the IT Department may provide the user with
the privileged rights only for the required period.
Access Control List (ACL)
The IT Department must maintain an access control list giving details of the access given to a user.
The ACL should be reviewed and should be updated as and when any user Ids are created, modified, disabled
or deleted from the domain.
Access for printing facilities
The access to printing facilities is provided to users on a need-to-do basis. Users, whose job description
does not require printing, must not be given access to printers.
It is the responsibility of users to ensure that printers are used for official purpose only and personal
documents are not printed using these facilities.
Where required, senior personnel or departments processing sensitive information will be provided with a
separate printer, access to this printer will be provided only to those department staff or senior
Network access for third party laptops
Vendors / Client’s Laptops are not allowed to be connected to the company’s network. If any such laptop
needs to be connected to the network, it must be approved by the IT department.
IT department will ensure Vendor / Client Laptops have high end Business grade Anti-virus as well as VPN
connection for allowing them to be connected to the Network.
Access to Storage media
Floppy Disks, CDR / CDRW
The workstations and laptops will not be provided with Floppy disk drives, CD-Writers. This is to ensure
that no employee can transfer official data onto these devices.
If users require any of these devices for their workstation or laptop, the head of the department must
authorise the same by sending an email to the IT department.
The IT department must ensure that access to Floppy Disk drives, USB Drives, DVD, CDR / CDRW are disabled
in BIOS and if required provide access only to authorized personnel.
Access to USB ports
To ensure that no unauthorised transfer of information happens using any I/O devices through USB port,
company will not allow access to the USB port on any computer for connecting such devices.
Any user requiring access to USB ports for connecting input-output devices must get an authorisation
from both the department head and IT head.
Email and Internet access
Internet and email are provided to the employees for carrying out the business functions of the company.
The department heads must authorise the use of Email facilities, for example Web mail, public email
servers etc. Users are responsible for following the Email and the Internet policy.
Users must ensure that unattended systems must be logged-off or locked so that no unauthorised person can
gain access to the same. If system limitations prevent locking of a workstation / server, suitable password
enabled screen saver must be used.
i. ID Card for every employee
ii. Access to server room restricted to authorized IT personnel only
iii. Each desktop needs domain authentication during startup
iv. Server (share) access is permitted only after domain authentication
v. File server access allowed based on senior management’s instructions.
vi. Information sharing on a strictly need to know basis within the team.
Refusal of orders for penny/illiquid stock:
PWAPL may from time to time limit (quantity/value)/refuse orders in one or more securities due to various
reasons including market liquidity, value of security(es), the order being for securities which are not in
the permitted list of the PWAPL/exchange/SEBI. Provided further that PWAPL may require compulsory
settlement/advance payment of expected settlement value/delivery of securities for settlement prior to
acceptance/placement of order(s) as well. The client agrees that the trade related losses, if any on account
of such refusal or due to delay caused by such limits, shall be borne exclusively by the client alone. PWAPL
may require reconfirmation of orders, which are larger than that specified by PWAPL's Risk Management, and
is also aware that PWAPL has the discretion to reject the execution of such orders based on its risk
perception. PWAPL also reserves the right to publish its own list of illiquid/penny stocks. Such refusal by
PWAPL to place orders in illiquid/penny stock shall not constitute violation of code of conduct prescribed
by SEBI/Exchange for stock brokers.
Setting up of Client's Exposure Limits:
Setting up client's exposure limits and conditions under which a client may not be allowed to take further
position or PWAPL may close the existing position of a client. PWAPL may from time to time impose and vary
limits on the orders that the client can place through PWAPL's trading system (including exposure limits,
turnover limits, limits as to the number, value and/or kind of securities in respect of which orders can be
placed etc). The client is aware and agrees that PWAPL may need to vary or reduce the limits or impose new
limits urgently on the basis of the PWAPL's risk perception and other factors considered relevant by PWAPL
including but not limited to limits on account of exchange/SEBI directions/limits (such as broker level/market
level limits in security specific/volume specific exposure etc.), and PWAPL may be unable to inform the
client of such variation, reduction or imposition in advance. The client agrees that PWAPL shall not be
responsible for such variation, reduction or imposition or the client's inability to route any order through
the PWAPL's trading system on account of any such variation, reduction or imposition of limits. The client
further agrees that PWAPL may at any time, at its sole discretion and without prior notice, prohibit or
restrict the client's ability to place orders or trade in securities through PWAPL trading system, or it may
subject any order placed by the client to a review before its entry into the trading system and may refuse to
execute/allow execution of orders due to but not limited to the reason of lack of margin/securities or the
order being outside the limits set by PWAPL/exchange/SEBI and any other reasons which PWAPL may deem
appropriate in the circumstances.
The client agrees that trade related losses, if any an account of such refusal or due to delay caused by such
review, shall be borne exclusively by the client alone. PWAPL is required only to communicate/advise the
parameters for the calculation of the margin/security requirements as rate(s)/percentage(s) of the dealing,
through anyone or more approved means or methods such as post/speed post/courier/registered post/registered
A.D./facsimile/e-mail/voice mails/telephone (telephone includes such devices as mobile phones etc.) including
SMS on the mobile phone or any other similar device; by messaging on the computer screen of the client's
computer; by informing the client through employees/agents of PWAPL; by publishing/displaying it on the website
of PWAPL/making it available as a download from the website of PWAPL; by displaying it on the notice board of
the branch/office through which the client trades or if the circumstances, so required, by radio broadcast/television
broadcast/newspaper advertisements etc; or any other suitable or applicable mode or manner.
The client agrees that the postal department/the courier company/ newspaper company and the e-mail/voice mail
service provider and such other service providers shall be the agent of the client. Once parameters for
margin/security requirements are so communicated, the client shall monitor his/her/its position
(dealings/trades and valuation of security) on his/her/its own and provide the required/deficit
margin/security forthwith as required from time to time.
The client is not entitled to trade without adequate margin/security and that it shall be his/her/its
responsibility to ascertain beforehand the margin/security requirements for his/her/its orders/trades/deals
and to ensure that the required margin/security is made available to PWAPL in such form and manner as may be
required by PWAPL. If the client's order is executed despite a shortfall in the available margin, the client
shall make up the shortfall immediately. The client further agrees that he/she/it shall be responsible for all
orders(including orders that may be executed without the required margin in the client's account) &/or any
trade related claim/loss/damage arising out of the non availability/shortage of margin/security required by
PWAPL&/or exchange &/or SEBI.
PWAPL is entitled to vary the form (Le., the replacement of the margin/security in one form with the
margin/security in any other form, say, in the form of funds instead of shares) &/or quantum &/or percentage
of the margin &/or security required to be deposited/made available, from time to time.
The margin/security deposited by the client with PWAPL are not eligible for any interest. PWAPL is entitled to
include/appropriate any/all payout of funds &/or securities towards margin/security without requiring specific
authorizations for each payout.
PWAPL is entitled to transfer funds &/or securities from his account for one exchange &/or one segment of the
exchange to his/her/its account for another exchange &/or another segment of the same exchange whenever
applicable and found necessary by PWAPL.
The client also agrees and authorize PWAPL to treat/adjust his/her/its margin/security lying in one
exchange &/or one segment of the exchange/towards the margin/security/pay in requirements of another
exchange &/or another segment of the exchange.
PWAPL is entitled to disable/freeze the account &/or trading facility/any other service facility, if in the
opinion of PWAPL, the client has committed a crime/fraud or has acted in contradiction of the Mandatory and
Voluntary Client Registration Documents or/is likely to evade/violate any laws, rules, regulation, direction
of a lawful authority whether Indian or foreign or if the stock broker so apprehends.
Delayed payment charges/Imposition of penalty:
The client agrees that any amount, which are overdue from the client towards trading or an account of any other
trade related reason to the PWAPL will be charged with delayed payment charges at 2% per month or 24% per annum
or such other rates as may be specified by PWAPL from time to time. The client agrees that PWAPL may impose
fines/penalties at above rate for any orders/trades/deals/actions of the client which are contrary to the
Mandatory and Voluntary Client Registration Documents/rules/regulations/bye laws of the exchange or any other
law for the time being in force. Further where PWAPL has to pay any fine or bear any punishment from any
authority in connection with/as a consequence of / in relation to any of the orders/trades/deals/actions of
the client, the same shall be borne by the client. The client agrees to pay PWAPL brokerage, commission, fees,
all taxes, duties levies imposed by any authority including but not limited to the stock exchanges. The client
agrees that he/she/it shall be liable for penal interest on T+1 basis. Any client's debit after T+2 day from
the date of trading shall result in client's securities (either received as delivery or as collateral) being
liquidated. The client shall have no right to plead or expect that his/her/its debit should be allowed to
remain unpaid on an infinite basis as it is anyway subject to penalty rate. This delayed payment charges will
be levied for the actual period for which the debit has remain unpaid/non cleared after it has become due. Any
delay in payment of M2M loss on any segment shall also result in client's securities (either received as
delivery in cash segment or as collateral) and also all such other collaterals of the client being liquidated
by us, to the extent of such Mark-to-Market loss. Further all outstanding position of the client in all
segment shall also be liable to be closed out in the market and costs, consequences, loss etc. if any arising
out of such close-out shall be for client to bear. Further PWAPL shall be at liberty to prescribe such higher
margin percentage at its own discretion for such defaulting clients. PWAPL.if it so desires, can also close
the accounts both trading and demat of such defaulting clients.
Applicable Brokerage Rate:
The client shall be subject to brokerage slab as agreed by client, evidenced by the client having duly signed
the tariff sheet after mentioning the tariff rates therein.
The Right to sell clients' securities or close clients' positions, without giving notice to the client,
an account/of non-payment of client's dues. (Limited to Margin/Settlement Obligations):
PWAPL maintains centralized banking and securities handling processes and related banking and depository
accounts at designated place. The client shall ensure timely availability of funds/securities in designated
form and manner at designated time and in designated bank and depository accounts(s) at designated place, for
meeting his/her/its pay in obligation of funds and securities. PWAPL shall not be responsible for any
claim/loss/damage arising out of non availability/short availability of funds/securities by the client in the
designated account(s) of PWAPL for meeting the pay in obligation of either funds or securities. If the client
gives orders/trades in the anticipation of the required securities being available subsequently for pay in
through anticipated payout from the exchange or through borrowings or any off market delivery(s) or market
delivery(s) and if such anticipated availability does not materialize in actual availability of
securities/funds for pay in for any reason whatsoever including but not limited to any delays/shortages of the
exchange or stock broker level/non release of margin by the stock broker etc., the losses which may occur to
the client as a consequence of such shortages in any manner such as an account of auctions/square off/closing
outs etc., shall be solely to the account of the client and the client agrees not to hold the PWAPL responsible
for the same in any form or manner whatsoever. In case the payment of the margin/security is made by the client
through a bank instrument, PWAPL shall be at liberty to give the benefit/credit for the same only on the
realization of the funds from the said bank instrument etc. at the absolute discretion of the PWAPL. Where the
margin/security is made available by way of securities or any other property, PWAPL is empowered to decline its
acceptance as margin/security &/or to accept it at such reduced value as the PWAPL may deem fit by applying haircuts
or by valuing it by marking it to market or by any other method as PWAPL may deem fit in its absolute discretion.
PWAPL has the right but not the obligation, to cancel all pending orders and to sell/close/liquidate all open
positions/securities/shares when Mark to Market (M2M) percentage reaches or crosses stipulated margin percentage
mentioned on the margin sheet whichever is earlier. PWAPL will have sole discretion to referred stipulated margin
or M2M percentage depending upon the market condition. In the event of such square off, the client agrees to bear
all the trade related losses based on actual executed prices.
If in case open position (Le. short/long) gets converted into delivery due to non square off because of any reason
whatsoever, the client agrees to provide securities/funds to fulfill the pay-in obligation failing which the client
will have to face auctions or internal close outs; in addition to this the client will have to pay penalties and
charges levied by exchange in actual and losses, if any. Without prejudice to the foregoing, the client shall also
be solely liable for all and any penalties and charges levied by the exchange(s).
PWAPL is entitled to prescribe the date and time by which the margin/security is to be made available and PWAPL
may refuse to accept any payments in any form after such deadline for margin/security expires. Notwithstanding
anything to the contrary in the Mandatory and Voluntary Client Registration Documents or elsewhere, if the
client fails to maintain or provide the required margin/fund security or to meet the funds/margins/securities
pay in obligations for the orders/trades/deals of the client within the prescribed time and form, PWAPL shall
have the right without any further notice or communication to the client to take any one or more of the
i) To withhold any payout of funds/securities.
ii) To withhold/disable the trading/dealing facility to the client.
iii) To liquidate one or more security(s) of the client by selling the same in such manner and at such rate
which PWAPL may deem fit in its absolute discretion. It is agreed and understood by the client that securities
here includes securities which are pending delivery/receipt.
iv) To liquidate/Square off partially or fully the position of sale &/or purchase in anyone or more securities/contracts
in such manner and at such rate which PWAPL may decide in its absolute discretion.
v) To take any other steps which in the given circumstances, PWAPL may deem fit. The client agrees that the
trade related loss(s) if any, on account of anyone or more steps as enumerated herein above being taken by
PWAPL, shall be borne exclusively by the client alone and agrees not to question the reasonableness,
requirements, timing, manner, form, pricing etc., which are chosen by PWAPL.
Auction Policy :
As per the Exchange Settlement Norms the Pay in Obligation is paid in to the exchange. If Client fails to
deliver the relevant securities, Auction of Securities will be arise. It could be internal Auction or Exchange
Auction. There is different process for both cases.
As per the Exchange Settlement Norms the Pay in Obligation for securities are adjusted at Member level.It could
be possible that within the member’s client, there could be opposite positions in the same scrip, which then,
necessitates the internal adjustment.
The price of securities will be considered as highest price of the scrip prevailing in the NSE/BSE from the
first day of the relevant trading shortage day till the day of closing out on the auction day whichever is
In case of default in security pay in by the Client and the shortage is at Exchange level, the member shall be
procuring the price defaulting securities from the Exchange. The price of securities will be considered as
provided by Exchange + 6% penalty and other statutory charges.
(Above defined parameters are subject to change from time to time)
Conditions under which a client may not be allowed to take further position or PWAPL may close the existing position of a client:
Client may take exposure up to the amount of margin available with us. Client may not be allowed to take
position in case of non-availability/shortage or margin as per our RMS policy of the company. The existing
position of the client is also liable to square off/close out without giving notice due to shortage of
margin/non making of payment for their pay-in obligation/outstanding debts.
De-registering a client Notwithstanding anything to the contrary stated in the Mandatory and Voluntary
Client Registration Documents PWAPL shall be entitled to terminate the Mandatory and Voluntary Client Registration
Documents with immediate effect in any of the following circumstances:
i) If the action of the client are prima facie illegal/improper or such as to manipulate the price of any securities
or disturb the normal/proper functioning of the market, either alone or in conjunction with others.
ii) If there is any commencement of a legal process against the Client under any law in force.
iii) On the death/lunacy or other disability of the Client.
iv) If a receiver, administrator or liquidator has been appointed or allowed to be appointed of all or any part of
the undertaking of the client.
v) If the Client has voluntarily or compulsorily become the subject of proceedings under any bankruptcy or insolvency
law or being a company goes into liquidation or has a received appointed in respect of its assets or refers itself
to the Board for Industrial and Financial Reconstruction or under any other law providing protection as a relief undertaking.
vi) If the Client being a partnership firm, has any steps taken by the Client and/or its partners for dissolution of the
viii) If the Client have taken or suffered to be taken any action for its reorganization, liquidation or dissolution.
viii) If the Client has made any material misrepresentation of facts, including (without limitation) in relation to the Security.
ix) If there is reasonable apprehension that the Client is unable to pay its debts or Client has admitted its inability to pay its
debts as they become payable.
x) If the Client suffers any adverse material change in his/her/its financial position or defaults in any other agreement with the
xi) If the Client is in breach of any term, condition or covenant of this Mandatory and Voluntary Client Registration Documents.
However notwithstanding any termination of the Mandatory and Voluntary Client Registration Documents, all
transactions made under/pursuant to this Mandatory and Voluntary Client Registration Documents shall be
subject to all terms and conditions of this Mandatory and Voluntary Client Registration Documents and parties
to this Mandatory and Voluntary Client Registration Documents submit to exclusive jurisdiction of courts of
law at the place of execution of this Mandatory and Voluntary Client Registration Documents by Stock Broker.
Client Acceptance of Policies and Procedures stated here in above: I/We have fully understood the same and do
hereby sign the same. These policies and procedures may be amended/changed by the broker provided the change
is informed to me/us with through anyone or more approved means or methods such as post/speed
post/courier/registered post/registered AD/telegram/e-mail/voice mails/telephone (telephone includes such
devices as mobile phones etc.) including SMS on the mobile phone or any other similar device; by messaging on
the computer screen of the client's computer; by informing the client through employees/agents of PWAPL; by
publishing/displaying it on the website of PWAPL/making it available as a download from the website of PWAPL;
by displaying it on the notice board of the branch/office through which the client trades or if the
circumstances, so require, by radio broadcast/television broadcast/newspapers advertisement etc; or any other
approved suitable or applicable mode or manner by an advance notice of 15 days.
I/We agree that the postal department/the courier company/newspaper company and the e-mail/voice mail service
provider and such other service providers shall be my/our agent. These policies and Procedures shall always be
read along with the Mandatory and Voluntary Client Registration Document and shall be compulsorily referred to
while deciding any dispute/difference or claim between me/us and PWAPL before any court of
low/judicial/adjudicating authority including arbitrator/mediator etc.
Temporarily suspending or closing client's account at Client's request
On the written request of the client, the client account can be suspended temporarily and can be re-activated
on the written request of the client only. During suspension period, the market transaction will be prohibited.
However client's pending settlement can take place. PWAPL can withhold the payout of client and suspend his
trading account due to surveillance action or judicial or/and regulatory order/action requiring client
suspension. On the written request of the client, the client account can be closed provided the client adheres
to formalities for account closure including settlement of all dues in the account and closing of all open
position. If the client wishes to again open a broking account then the client shall have to complete the KYC
and account opening formalities once again. PWAPL also reserve rights to suspend client's account if client's
PAN or UID has been asked for latest financial documents updates from exchange or any regulatory body and
client is not supporting for submission of the said documents.
Policy for Dormant Accounts:
A Trading Account (Irrespective whether having debit or credit balance) shall be classified as dormant account
in case there are no transactions for a period in excess of 365 days from the last transaction date. A dormant
account can be re-activated on receipt of a request for reactivation along with valid proof of identity or
Client can also send mail from his/her registered email id.
Policy for Minor Trading Account:
A minor demat account can be open for the purpose of IPO/FPO subscription. This is limited purpose
trading/demat account where minor trading account allowed only to sell share/s allotted in IPO/FPO and no
further buy of security or trading allowed.
We, at Patelwealth.com acknowledge and accept that the personal details that you impart to us, is to be kept
in strict confidentiality and to use the information only in the manner which would be beneficial to our
customers. We consider our relationship with you as invaluable and strive to respect and safeguard your right
We shall protect the personal details received from you with the same degree of care, but no less than a
reasonable degree of care, to prevent the unauthorized use, dissemination, or publication of these information
as we protect our own confidential information of a like nature.
We shall use the personal information to improve our service to you and to keep you updated about our new
product or information that may be of interest to you. The information collected from you would be used in the
right spirit and context in which it is intended to be used. Your information would be used by us to process
your trading request and to carry out the settlements of your obligations.
We would ensure that we collect personal information only to the extent it is necessary to administer our
services in the best possible manner and what is required under the various regulations of Indian Laws. To
ensure high quality services and high degree of value addition to you, we may combine the information given
by you on the web or through other channels.
Under certain circumstances we may be required to share the information given by you with the third parties,
where we feel they can contribute to add value and improve the quality of services imparted by us to you. We
shall take all reasonable steps to ensure that the confidentiality of your information is maintained by
imposing strict confidentiality standards on all the third parties with whom we part this information. In
all circumstances we shall ensure that your personal information is protected by strict confidentiality
agreement. We shall not allow any third parties to retain your personal information longer than what is
warranted by the nature of services rendered.
We would also impart your personal information wherever it is required to be disclosed under law to any
of the governmental agency or regulatory bodies.
We ensure that the personal information given to us by you on the web is placed in the secured portion of our
web-site. We use the most advanced encryption technology, Secure Socket Layer (SSL), to ensure that the
information transmitted between you and us across the Internet is safe and cannot be accessed by any outsider.
SSL has been universally accepted on the World Wide Web for authenticated and encrypted communication
between clients and servers.
To ensure security of access to the personal information and transaction details, the access to the secured
zone of our website is restricted by the unique login ID and Password selected by you. You should be very
careful in handling the ID and password and you should ensure that you do not reveal it to anybody, nor do
you keep it in writing. You should keep changing your password periodically.
To ensure safety of your trading access, our technology automatically logs you out of the site if no activity
is registered for 30 minutes. However, you should ensure that each time you leave your terminal you log
yourself out. This prevents someone else from accessing your account if you leave your computer and your
session has not "timed out"
To enable us serve you better, it is necessary that your personal information available with us is updated
and accurate. Our web-site enables you to update your personal information. You can also send us an e-mail
at Customer Service and we shall ensure that your information is updated and protected from any misuse or
PATEL WEALTH ADVISORS PVT. LTD. Welcomes your comments regarding this privacy statement. If you believe that
PATEL WEALTH ADVISORS PVT. LTD. has not adhered to this privacy statement, please contact PATEL WEALTH ADVISORS
PVT. LTD. by email at email@example.com, and we will use commercially reasonable efforts to promptly
determine and remedy the problem.
Information Sharing and Disclosure/Disclaimer.
1. Introduction to aml
Money Laundering is nothing but a transaction or a series of transactions undertaken with a view to
switching around proceeds received or earned from unlawful activities and/or to concealing the true
identity of the person/entity who has earned such proceeds. Financial Institutions & intermediaries
have been largely used by criminal and terrorist groups to launder money for their unlawful activities.
Hence, there is need to develop a proper PMLA framework.
A financial intermediary must therefore institute PMLA measures at client level & transaction level.
There is need to adopt proper surveillance measures to monitor demat& trading activities.
This Policy has been framed by PWAPL in order to comply with the applicable Anti Money Laundering (AML)
Standards/ Combating the Financing of Terrorism (CFT) /Obligations of Securities Market Intermediaries
under the Prevention of Money Laundering Act, 2002 and pursuant to the recommendations made by the
Financial Action Task Force on anti-money laundering standards, SEBI had issued the Guidelines on Anti
Money Laundering Standards vide their notification No.ISD/CIR/RR/AML/1/06 dated 18th January 2006, vide
Circular No.ISD/CIR/RR/AML/2/06 dated 20th March 2006 vide letter No. ISD/AML/CIR-1/2008 dated December
19, 2008,vide Circular No. ISD/AML/CIR-1/2009 dated September 01, 2009, Vide Circular No. ISD/AML/CIR-2/2009
date October 23,2009, vide Circular CIR/ISD/AML/3/2010 dated December 31, 2010, vide Circular
No. ISD/AML/CIR-1/2010 dated February 2010, vide Circular number CIR/MIRSD/11/2014 dated March 12th, 2014,
vide Circular SEBI/HO/MIRSD/DOS3/CIR/P/2018/104 dated July 04th, 2018 and vide Circular
No. SEBI/HO/MIRSD/DOP/CIR/P2019/113 dated October 15, 2019, SEBI/HO/MIRSD/MIRSD-SEC-5/P/CIR/2023/022 dated
February 03, 2023&SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2023/091 dated June 16, 2023 had issued the obligations
of the intermediaries registered under Section 12 of SEBI Act, 1992. As per these SEBI guidelines, PWAPL
have ensured that proper policy frameworks are put in place as per the Guidelines on Anti Money Laundering
Standards notified by SEBI.
The purpose of this document is to instruct & educate employees of PWAPL and its associates about the efforts
needed on their part to detect and deter money laundering and/or terrorist financing activities. It shall be
the responsibility of all employees of PWAPL and associates to ensure that implementation of PMLA policy is
done as per spirit & intent of law.
PWAPL shall consider carefully the specific nature of its business, organizational structure, type of client
and transaction, etc. to satisfy itself that the PMLA measures taken by it are adequate and appropriate to
follow the spirit of the suggested measures and the requirements as laid down in the PMLA.
Global measures taken to combat drug trafficking, terrorism and other organized and serious crimes have all
emphasized the need for financial institutions, including securities market intermediaries, to establish
internal procedures that effectively serve to prevent and impede money laundering and terrorist financing.
Our PMLA policy is in line with these measures and mandates that all employees & AP ensure the fulfillment
of the aforementioned obligations.
To be in compliance with these obligations, the senior management shall be fully committed to establishing
appropriate policies and procedures for the prevention of ML and TF and ensuring their effectiveness and
compliance with all relevant legal and regulatory requirements. We shall:
Policies and procedures to combat ML shall cover:
The purpose of this document is to guide all the employees of PWAPL and employees of its associates on the
steps that they are required to take and implement to prevent and identify any money laundering or terrorist
financing activities. It shall be the responsibility of each of the concerned employees that they should be
able to satisfy themselves that the measures taken by them are adequate, appropriate and follow the spirit of
these measures and the requirements as enshrined in the “Prevention of Money Laundering Act, 2002”.
Some of these suggested measures may not be applicable to every circumstance or to each department, Branch / AP.
However, each entity should consider carefully the specific nature of its business, type of customer and
transaction to satisfy itself that the measures taken by the employees are adequate and appropriate to follow
the spirit of these guidelines.
5. Implementation of this policy
CLIENT DUE DILIGENCE
The CDD measures comprise the following:
The main aspect of this policy is the Customer Due Diligence Process which means:
6. Client acceptance policy
Client acceptance policies and procedures aim to identify the types of clients that are likely to pose a
higher than average risk of ML or TF. To apply client due diligence on a risk sensitive basis depends on
the type of client business relationship or transaction. The following safeguards shall be followed by the
company while accepting the clients
Clients which are likely to pose a high risk to RSBPL, may be categorized as high risk.
-Clients who have defaulted in the past
-Clients who have a suspicious background
-HNIs whose identity and source of wealth are difficult to identify
-Politically exposed persons
-Clients of Special Category*
Clients which are likely to pose a medium risk to RSBPL may be categorized as
medium risk. They can be the following:
-Where the client profile of the person opening the account is doubtful or dubious.
-Where the trading and settlement pattern of the client is suspicious
-Intraday clients or speculative client.
Clients who pose low or nil risk.
-They are corporate/HNIs who have a respectable social and financial standing.
-Clients who fulfill obligations on time.
* To undertake enhanced due diligence measures as applicable for Clients of SpecialCategory (CSC).
CSC shall include the following:
7. Client identification procedure:
The KYC policy shall clearly spell out the client identification procedure (CIP) to be carried out at different
stages i.e. while establishing the intermediary – client relationship, while carrying out transactions for the
client or when the intermediary has doubts regarding the veracity or the adequacy of previously obtained client
Following requirements shall form part of CIP:
RELIANCE ON THIRD PARTY FOR CARRYING OUT CDD
PWAPL may rely on a third party for the purpose of –
8. Risk – based approach:
The risk assessment shall also take into account any country specific information that is circulated
by the Government of India and SEBI from time to time, as well as, the updated list of individuals and
entities who are subjected to sanction measures as required under the various United Nations' Security
Council Resolutions. These shall be accessed by the company at the URL
9. Record keeping requirements & retention of records
Records pertaining to transactions of clients shall be maintained and preserved for a period of
five years from the date of the transaction. Record of documents evidencing the identity of the clients
and beneficial owners (e.g., copies or records of official identification documents like
passports, identity cards, driving licenses or similar documents) as well as account files and
business correspondence shall be maintained and preserved for a period of five years even after the
business relationship with the client has ended or the account has been closed, whichever is later. Records
shall be maintained 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 or if there be any suspected drug related or other 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, the following
information of the client shall be maintained in order to maintain a satisfactory audit trail:
a. the beneficial owner of the account;
b. the volume of the funds flowing through the account; and
c. for selected transactions:
System is been maintained to record all such transaction as prescribed under rule 3 of the PML Rules
It may, however, be clarified that for the purpose of suspicious transactions reporting, apart from
‘transactions integrally connected’, ‘transactions remotely connected or related’ shall also be considered.
In case there is a variance in CDD/AML standards prescribed by SEBI and the regulators of the host country,
branches/overseas subsidiaries of intermediaries are required to adopt the more stringent requirements of the
Record of information related to transactions, whether attempted or executed, which are reported to the
Director, FIU‐IND, as required under Rules 7 & 8 of the PML Rules, shall be maintained and preserved for
a period of five years from the date of the transaction with the client.
In the case of transactions where any investigations by any authority has been commenced and in the case of
transactions which have been the subject of suspicious transactions reporting all the records shall be
maintained till the authority in forms of closure of the case.
10. Information to be maintained:
Following information in respect of transactions referred to in Rule 3 of PML Rules shall be maintained:
11. Monitoring of transactions:
Special attention shall be paid to all complex unusually large transactions / patterns which appear to have no
economic purpose. Internal threshold limits for each class of client accounts shall be defined and special
attention shall be paid to transactions which exceeds these limits.
The background including all documents/office records /memorandums/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/FIUIND/ other relevant Authorities, during audit, inspection or as and when required. These records
shall be preserved for a period of five years from the date of transaction with such client.
Record of the transactions in terms of Section 12 of the PMLA shall be preserved and those transactions of a
suspicious nature or any other transactions notified under Section 12 of the Act shall be reported to the
Director, FIU-IND. Suspicious transactions shall be regularly reported to the Senior Management.
12. Suspicious transaction monitoring and reporting:
All are requested to analyze and furnish details of suspicious transactions, whether or not made in cash. It should
be ensured that there is no undue delay in analysis and arriving at a conclusion.
What is a Suspicious Transaction?
What to Report?
13. List of designated individuals or entities
An updated list of individuals and entities which are 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 its website at
Precaution shall be taken to ensure that no account is opened whose name shall be appearing in such list.
Periodic review of the existing account shall be conducted to ensure that no existing account are linked to
any of the entity or individual included in the list.
Any resemblance found shall be reported to SEBI and FIU-IND.
14. Procedure for freezing of funds, financial assets or economic resources or related services:
15. Reporting to FIU:
In terms of the PMLA rules, brokers and sub-brokers are required to report information relating to cash and
suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) 6th Floor, Hotel Samarat,
Chanakyapuri, New Delhi - 110021 as per the schedule given below:
Allcashtransactionsofthevalueofmore than Rs.10 Lakhsoritsequivalent inforeign currency
All series of cash transactions integrally connected to each other which
have been valued below Rs.10 Lakhs or its equivalent in foreign currency where
such series of transactions have taken place within a month
All suspicious transactions whether or not beingmade in cash
Not later than seven days on satisfied that thetransaction is suspicious
The Principal Officer will be responsible for timely submission of CTR, STR and NTR to FIU-IND. Utmost
confidentiality shall be maintained in filing of CTR, STR and NTR to FIU-IND. No nil reporting needs to
be made to FIU-IND in case there are no cash/ suspicious/ non – profit organization transactions to be
Irrespective of the amount of transaction and/or the threshold limit envisaged for predicate offences
specified in the PMLA, 2002, an STR shall be filed, if there are reasonable grounds to believe that
the transactions involves proceeds of crime.
16. Principal officer
The company has designated the Principal Officer who shall be responsible for implementation and compliance
of this policy shall include the following:
17. Designated director
“Designated Director” means a person designated by the Board of Directors to ensure over all compliance with
the obligations imposed under The Prevention of Money Laundering Act, 2002 and the Rules framed there under,
as amended from time to time, and include the Managing Director or a Whole‐time Director duly authorized by
the Board of Directors. The Company shall appoint a Designated Director and communicate the details of the
Designated Director, such as, name, designation and address to the Office of the Director, FIU‐IND and update
the same whenever there is any change.
18. Details of designated director & principal officer
Minish M. Patel
Minish M. Patel
“OXYGEN”, M/2/3, Gaurav Park, Opp. Pradhyuman Royal Heights, Near Neel Da Dhaba, Off.
Kalawad Road, Rajkot 360005 Gujarat, India
“OXYGEN”, M/2/3, Gaurav Park, Opp. Pradhyuman Royal Heights, Near Neel Da Dhaba, Off.
Kalawad Road, Rajkot 360005 Gujarat, India
19. System and procedure for hiring of employees
20. Employees training:
21. Investors education
As the implementation of AML/CFT measures being sensitive subject and requires us to demand and collect certain
information from investors which may be of personal in nature or has hitherto never been called for, which
information include documents evidencing source of funds/income tax returns/bank records etc. and can sometimes
lead to raising of questions by the client with regard to the motive and purpose of collecting such information.
There is, therefore, a need for us to sensitize the clients about these requirements, as the ones emanating
from AML and CFT framework. We shall circulate the PMLA Circulars and other specific literature/pamphlets etc.
so as to educate the client of the objectives of the AML/CFT program. The same shall also be emphasized on,
in the Investor Awareness Programs conducted by us at frequent intervals of time. The importance of the same
is also made known to them at the time of opening the Account.
Note: This policy has been reviewed in terms of SEBI/HO/MIRSD/MIRSD-SEC-5/P/CIR/2023/022 February 03, 2023
&SEBI/HO/MIRSD/MIRSDSECFATF/P/CIR/2023/091 dated June 16, 2023 by Board of Directors of erstwhile PWAPL
during its meeting held on 06thJuly, 2023and is being circulated to all concerned for compliance of the
In order to mitigate the Risk in Securities Business of the Company, the management of the Company is agreed to
accept and implement the below mentioned Risk Management Policy. The Policy will help the Member to mitigate
the risk, monitor the different margin obligations, and protect the clients.
Setting up client exposure limit
Exposure is allowed to the clients depending upon the margin available in form of funds or approved securities
values after deducting an appropriate haircut. Clients is liable to pay Applicable initial margins, withholding
margin, special margins or such other margin as Are considered necessary by the Exchange. Further Patel Wealth
at its discretion may collect additional margin or may even reduce the margin even though not required by the
Exchange. Clients are supposed to maintain sufficient balance with the Patel Wealth Pre Trade Depending on the
channel through which they trade. Patel Wealth may even levy additional Margin or relax the margins earlier
imposed based on factors such as, client’s level positions, Volatility in particular stock or the market in
general. Exposure allowed to clients may very Depending in the clients past trading performance, quality of
collateral market circumstances And dynamics and other such factors.
Imposition of penalty/ delayes payment charges
Conditions under which a client may not be allowed to take further position or The broker may close
existing position of a client:
The objective of this policy to have effective surveillance frame work for DP’s. It will also help identify
adverse situation in markets and pursue appropriate preventive action thereby providing Investor protection.
The alerts will be provided by depository (NSDL) all such alerts will be verified by the compliance officer
and due diligence of such clients will be undertaken once again.
DP shall maintain a record of all alerts provided by the Depository (NSDL) and will also record the action
taken against such alerts.
Any adverse observation in the alerts will be reported to NSDL. This policy was place before the board the
director and approved by the boards on the 1st August 2023.
This policy shall be reviewed once in a year and shall be revised as and when required. Following alerts
will be generated by DP.
In point 8,9,10 all such cases DP shall conduct due diligence of the client and shall ensure there is no
adverse observation and if found shall be reported to NSDL.
DP will report to NSDL in the prescribed format at the end of every quarter the status of alerts.
The compliance officer shall be responsible for supervision and surveillance of policy.
The data of alerts provided by NSDL and generated by the DP and the action taken against such alerts shall
be placed before the board.
Compliance officer shall ensure the internal audit of such all alerts and shall further ensure the any adverse
observation are submitted to DP.