Please Note: We Capitalize is a brand name and does not represent a separate legal entity. All research services are rendered by Gowtham Kumaresh, SEBI Registered Research Analyst, Registration No. INH000028981.
RA-Specific Context: Research Analysts do not hold or manage client accounts or funds. Clients are onboarded through signed Terms & Conditions, and KYC is performed via PAN verification using the KRA system. This policy reflects the AML obligations applicable specifically to a SEBI-registered Research Analyst operating within this scope.
1. Scope
This policy applies to all activities of the We Capitalize Research Analyst business, including:
- Onboarding clients for one-to-many research services.
- Verifying client identity via PAN through the KRA system.
- Delivering research reports and recommendations to subscribers.
We Capitalize / Gowtham Kumaresh does not hold or manage client accounts or funds. This policy does not extend to transaction execution, portfolio management, investment advisory, or any other activity outside the scope of SEBI-regulated Research Analyst services.
2. Definitions
The following abbreviations and terms are used throughout this AML Policy:
- CDD
- Client Due Diligence
- EDD
- Enhanced Due Diligence
- PEP
- Politically Exposed Person
- FIU-IND
- Financial Intelligence Unit – India
- STR
- Suspicious Transaction Report
- KRA
- KYC Registration Agency
- MITC
- Most Important Terms and Conditions
3. Governance
The following roles carry AML compliance responsibilities within We Capitalize:
- Designated Director: Ensures overall AML compliance and is responsible for policy approval and oversight.
- Principal Officer: The individual Research Analyst (or Principal Officer in the case of a non-individual RA) responsible for reporting suspicious activities to FIU-IND.
- Compliance Officer: Implements CDD processes, monitors client interactions, and maintains all required records in line with this policy and applicable regulations.
As an individual SEBI Registered Research Analyst, Gowtham Kumaresh (INH000028981) serves as the Designated Director, Principal Officer, and Compliance Officer for the purposes of this policy, in accordance with SEBI regulations applicable to individual Research Analysts.
4. AML Procedures
A. Client Acceptance and Risk Categorisation
- Clients must sign the Research Analyst's Terms & Conditions (including MITC) before onboarding to any paid research service.
- Client Due Diligence (CDD) is performed via PAN authentication through a registered KRA system.
- Clients are classified based on the plan and nature of the subscription. This does not amount to investment risk profiling; recommendation plans are structured based on the risk profile of the securities being recommended.
- Enhanced Due Diligence (EDD) is applied for Politically Exposed Persons (PEPs), clients from high-risk geographies, and any unusual engagement requests.
B. Client Due Diligence (CDD)
- Verify client identity using PAN via the KRA system prior to providing paid research services.
- Record client name, PAN, contact details, and engagement type at the time of onboarding.
- Identify and document any beneficial owners if the client is a corporate entity or non-individual.
- Understand the purpose and expected usage of the research services by the client.
C. Reliance on Third Parties
We Capitalize may rely on KRA systems for PAN verification under the CDD Rules. Ultimate responsibility for the adequacy and accuracy of CDD remains with the Research Analyst at all times.
D. Risk Assessment
- Conduct periodic risk reviews of the recommendation plans being offered to clients.
- Update risk categories when client circumstances or applicable regulations change materially.
- Document all assessment results for audit and regulatory review purposes.
E. Monitoring and Reporting
- Monitor client interactions and requests for signs of irregular or illicit use of research services.
- Report any suspicious client behaviour or requests to the Principal Officer / Individual RA immediately.
- File Suspicious Transaction Reports (STRs) with FIU-IND within 7 days of detecting suspicious activity.
- Maintain strict confidentiality throughout the reporting process to prevent tipping-off the subject of the report.
Suspicious Transaction Reports must be filed with FIU-IND within 7 days of detecting suspicious activity. Disclosure of an STR or the fact that an STR has been filed to the subject of the report (tipping-off) is prohibited under applicable regulations.
F. Record Keeping
- Retain signed Terms & Conditions documents, PAN KYC records, and client correspondence for a minimum of 5 years after the client relationship ends.
- Maintain a log of all STRs filed and related supporting documents for a minimum of 5 years from the date of reporting.
G. Sanctions Screening
- Screen client details against UN and Indian sanctions databases before completing onboarding.
- Decline service to any sanctioned individual or entity and report to the relevant authorities as required by applicable law.
H. Training and Awareness
- Provide annual AML training for individuals involved in client onboarding and research dissemination.
- Update training materials regularly to reflect regulatory changes and emerging AML / CFT risks.
5. Policy Review
This AML Policy shall be reviewed annually, or upon significant regulatory updates, and re-approved by the Designated Director.
- The next scheduled review will be conducted no later than June 2027, or earlier if triggered by material regulatory changes.
- Any updates to this policy will be published on this website with a revised “Last Updated” date.
- Clients with active subscriptions will be notified of material changes to this policy in accordance with the Terms & Conditions of the research service.
6. RA Details
This AML Policy is issued by and applicable to the following registered Research Analyst: