KYC & AML Policy

Purpose

This policy sets out how client identity is established and verified before research services are provided, in accordance with the Prevention of Money Laundering Act, 2002, the rules made under it, and SEBI's requirements for registered intermediaries.

Client identification

No subscription is activated until identification is complete. We collect and verify:

• Proof of identity — PAN, mandatory and verified.
• Proof of address — Aadhaar, passport, voter ID, driving licence or utility bill.
• Contact details — email and mobile, each verified by one-time password.
• Where available, an existing CKYC record is used, reducing what you have to submit.

Your KYC status is displayed in the member area as Pending or Done, so you always know where you stand. Access to paid research begins only when it reads Done.

Risk categorisation and monitoring

Each client is categorised as low, medium or high risk on the basis of identity, location and the nature of the engagement. Higher-risk clients are subject to enhanced due diligence and periodic re-verification. Records are updated when we are told of a change and reviewed periodically.

Payments

• Fees are accepted only through traceable banking channels — bank transfer, UPI, or card through the payment gateway.
• Cash is never accepted, in any amount, for any reason.
• Payment must come from an account in the client's own name. Third-party payments are refused and returned.
• Every payment is invoiced, and the invoice is available to the client in the member area.

When we will refuse or discontinue business

We will decline to onboard, or will discontinue service, where identity cannot be satisfactorily established, where a client refuses to provide required information, where a client appears on a designated sanctions or prohibited list, or where the engagement cannot be served without breaching a regulatory obligation. Where the engagement is discontinued for a reason other than the client's breach, the unused period is refunded pro-rata under the Refund Policy.

Suspicious transactions

Transactions that appear suspicious are reported to the Financial Intelligence Unit — India as required by law. Such a report is confidential and is not disclosed to the client.

Record retention

KYC records, client agreements and transaction records are retained for a minimum of five years from the end of the client relationship or the date of the transaction, whichever is later, and are produced to any competent authority on request. How that data is protected is described in the Privacy Policy.

Designated officers

Principal Officer: to be notified on grant of registration, wisdominvestments@protonmail.com.
Compliance Officer: to be notified on grant of registration, wisdominvestments@protonmail.com.