1. Policy Statement
Tattvam Markets Ltd (“the Company”) is committed to maintaining the highest standards of integrity and regulatory compliance in preventing money laundering and terrorist financing. The Company’s AML/CTF framework aligns with the Financial Action Task Force (FATF) Recommendations and applicable national laws. Its objective is to detect, prevent, and report any attempt to use the Company’s services for illicit financial activities.
2. Scope
This Policy applies to:
- All employees, agents, and contractors of the Company.
- All customers, products, and services.
- All jurisdictions in which the Company operates.
3. Definitions and Interpretation
“Money Laundering” shall be understood as the process of concealing or disguising the existence, source, movement, destination, or illegal application of illicitly derived funds or property for the purposes of making those funds appear legitimate. “Anti-Money Laundering (AML)” refers to procedures, regulations, and laws for the prevention of attempts to disguise illegally obtained funds. The money laundering offense may be committed by any person knowing that any monetary instrument or property represents, involves, or relates to, the proceeds of any unlawful activity, transacts or attempts to transact said monetary instruments or property.
Any person knowing that any monetary instrument or property involves the proceeds of any unlawful activity, performs or fails to perform any act as a result of which he facilitates the offense of money laundering referred to above.
4. Key Principles
- Zero Tolerance: The Company will not knowingly engage in or facilitate money laundering or terrorist financing.
- Risk-Based Approach: Controls and monitoring are applied proportionately to customer and jurisdictional risk.
- Customer Due Diligence (CDD): Verification of all customers and beneficial owners prior to engagement.
- Ongoing Monitoring: Continuous review of transactions and customer activity.
- Record Keeping: Maintenance of identification and transaction records for at least five (5) years.
- Training: Regular AML/CTF training for relevant staff.
- Reporting: Immediate escalation of suspicious activity to the Money Laundering Reporting Officer (MLRO) and regulatory authorities when required.
5. Customer Due Diligence (CDD)
I. For Individuals:
- Full name, date of birth, nationality, address.
- Genuine photograph depicted in an official document such as a passport, national ID card or driver’s license.
- Residential address of the client (corroborated by a valid utility bill, telephone bill or bank statement)
- Confirmation of whether the client is included in PEP lists, sanctions and/or other watchlists
- Valid government-issued ID and recent proof of address (≤3 months old).
II. For Corporates:
- Certificate of Incorporation, Memorandum & Articles, Board Resolution.
- Identification of directors, authorized signatories, and ultimate beneficial owners (UBOs).
Enhanced Due Diligence (EDD) applies to high-risk clients, jurisdictions, and politically exposed persons (PEPs).
6. Monitoring and Reporting
The Company is legally obliged to comply with the applicable framework for the detection, prevention, and information dissemination on money laundering activities. In line with this, the Client shall understand that the Company shall request and obtain from Clients certain verification documents.
In the case where the Client fails to provide the Company with the necessary information in regard to the above the Company reserves the right not to execute orders on behalf of the Client or block the Client’s trading account. Any delays that might arise due to delay in the verification documents of the Client are not the responsibility of the Company.
7. Suspicious or Covered Transactions
The Company will promptly report suspicious or covered transactions related to clients' trading accounts within the timeframe specified by law or the Supervising Authority. Special attention will be given to complex, unusual, or large business transactions, unusual transaction patterns, and insignificant but periodic transactions that lack an apparent economic or lawful purpose.
The Company will implement and follow procedures to monitor client and account activity, adequately identifying indicators related to transactions and patterns, sources of funds and wealth, and geographical risks. This will be done in accordance with FATF recommendations and international standards on combating money laundering, terrorism financing, and proliferation. All transactions are monitored for unusual or suspicious patterns.
If suspicious activity is detected, it is escalated to the MLRO for review and possible submission of a Suspicious Transaction Report (STR) to the competent authority.
8. Prohibited Practices
Tattvam Markets Ltd strictly prohibits:
- Cash or anonymous transactions.
- Dealings with shell banks or unlicensed institutions.
- Business with sanctioned or high-risk jurisdictions (as per FATF, UN, or local authorities).
The Company may suspend or terminate any relationship suspected of unlawful activity.
9. Compliance Oversight and Review
The Compliance Department, led by the MLRO, ensures adherence to AML/CTF obligations through:
- Ongoing risk assessments and audits.
- Staff training and awareness programs.
- Regular policy updates to reflect regulatory developments.
This Policy is reviewed annually or as required by law or business changes.
10. Risk Assessment
The Company follows a risk-based approach (RBA) to ensure that measures to prevent or mitigate money laundering and terrorist financing are proportionate to the identified risks. This approach includes client acceptance and ongoing monitoring policies and procedures that help identify clients who may pose higher money laundering and terrorist financing risks.
The Company adopts reasonable criteria for assessing risks in accordance with the applicable framework and conducts periodic reviews to determine if any adjustments to its risk ratings are necessary.
11. Record Keeping
Tattvam Markets maintains records of client transactions, securely storing them for five (5) years from the transaction date. For closed accounts, records of client identification, account files, and business correspondence are preserved and securely stored for at least five (5) years from the completion date of the relevant business or transaction, or from the termination of the business relationship. The Company ensures that client information and transaction records are available to authorities upon request.
