Anti-Money Laundering (AML) Policy

Jupiter Research & Advisors Private Limited — SEBI Registration No.: INH000026008 | Framed pursuant to the Prevention of Money Laundering Act, 2002 (PMLA) and relevant SEBI circulars.

1. Policy Objective

This AML Policy is framed as per the Prevention of Money Laundering Act, 2002 (PMLA) and relevant SEBI circulars, to detect and report any suspicious activities and ensure that the Research Analyst does not become a conduit for money laundering or terrorist financing.

2. Applicability

This policy applies to:

• The Research Analyst (Ms. Aashi Pansari)
• All employees and associates of the Research Analyst
• All clients availing research services

3. Know Your Client (KYC) & Client Due Diligence (CDD)

We adhere to SEBI’s KYC framework:

• Mandatory PAN, Aadhaar, and Bank verification
• Risk-based classification: Low, Medium, High-Risk clients
• No service provided without successful KYC
• Enhanced Due Diligence (EDD) for high-risk clients, politically exposed persons (PEPs), or unusual payment patterns

4. Client Acceptance Policy

• No anonymous or fictitious accounts
• No acceptance of third-party or cash payments
• Refusal to onboard clients with doubtful background or links to criminal activity

5. Monitoring of Transactions

Although Jupiter Research & Advisors is a non-fund-handling entity:

• All incoming payments are monitored for abnormality
• We ensure all client payments are from KYC-verified bank accounts
• Any suspicious transactions are escalated for review

6. Record Keeping

As per SEBI & PMLA guidelines:

• Maintain KYC records, invoices, and correspondence for at least 5 years
• Maintain internal records of suspicious or attempted suspicious transactions

7. Reporting Obligations

• In case of detection of suspicious transactions, reports will be filed with the Financial Intelligence Unit – India (FIU-IND) as required under PMLA
• Suspicious Transaction Report (STR) shall be filed within 7 working days of identification

8. Employee Awareness & Training

• Internal AML training sessions will be conducted periodically
• Employees are instructed to immediately report any red flags to the Principal Officer

9. Principal Officer Details

Name

Ms. Aashi Pansari

Designation

Principal Officer

Email

info@jupiteradvisors.in

Phone

+91 9830267000

10. Confidentiality

All client data and transaction details shall be treated with utmost confidentiality, except when disclosure is required under the law.

11. Grievance Redressal

Email: info@jupiteradvisors.in | Phone: +91 9830267000

Clients may also escalate unresolved complaints through the SEBI SCORES portal.