Client Onboarding & Client Acceptance Policy
Risk-based framework for client acceptance and onboarding — KYC and due diligence, risk classification, UCC and account activation, periodic refresh, record keeping and training.
Risk-based framework for client acceptance and onboarding — KYC and due diligence, risk classification, UCC and account activation, periodic refresh, record keeping and training.
The purpose of this Policy is to establish a consistent, risk-based framework for accepting and onboarding clients of Vimal & Sons, while ensuring compliance with applicable SEBI, stock exchange, clearing corporation, depository, PMLA/AML, KYC and other regulatory requirements.
The Policy is intended to ensure that only appropriately identified and verified clients are onboarded; Vimal & Sons understands the client’s identity, ownership, nature of business and risk profile; higher-risk clients receive enhanced due diligence; records are maintained; client accounts are monitored on an ongoing basis; and relationships presenting unacceptable or unmitigable risks are not accepted.
This Policy applies to all prospective and existing clients of Vimal & Sons and to all employees, officers, authorised persons and functions involved in client acquisition, KYC, account opening, compliance, operations, dealing and client monitoring.
Vimal & Sons shall accept clients only on referral basis. No walk-in clients will be entertained.
The onboarding process shall include the applicable KYC and client due-diligence controls before trading activation.
Vimal & Sons shall, as applicable:
Vimal & Sons shall classify clients considering customer type, ownership/control, geography, products/services, expected activity, source of funds/wealth where relevant, PEP/sanctions exposure, adverse information and other AML/operational risk indicators.
Vimal & Sons shall not onboard a prospective client where:
After completion of applicable onboarding requirements, the client shall be allotted the required Unique Client Code (UCC) and other account identifiers.
System controls should prevent trading activation until mandatory KYC, documentation, screening and approval controls are completed.
No employee or business function may manually bypass a mandatory regulatory control without a documented and authorised exception where such exception is legally permissible.
Vimal & Sons shall maintain processes for identifying when client information requires updating and shall obtain refreshed information within applicable regulatory timelines.
Material changes in address, contact details, bank account, occupation/business, constitution, authorised signatories, beneficial ownership, controlling persons or other material KYC information shall trigger appropriate review.
Vimal & Sons shall maintain complete and accurate onboarding and KYC records, including information obtained, documents submitted, verification results, screening results, risk classification, approvals, exceptions, subsequent KYC updates and relevant monitoring/escalation records.
Retention periods shall comply with applicable PMLA, SEBI, exchange, depository and other regulatory requirements. Records shall be retrievable for regulatory, audit and internal review purposes.
Relevant employees and authorised persons shall receive periodic training on KYC, AML/CFT, client acceptance, red flags, sanctions/PEP screening, investor protection and escalation procedures.
This Policy shall be reviewed at least annually and earlier where there is a material change in applicable law, regulation, business model, products/services, risk profile or control environment.
The Compliance Officer shall document the review and place material amendments before the designated approval authority.