Client Onboarding, KYC and FATCA Policy
CLIENT ONBOARDING, KYC AND FATCA POLICY
This policy sets out how we onboard a new investor, what we verify before the first transaction is placed, and how we handle tax residency declarations. It applies to every investor serviced by Sanriya Finvest Private Limited.
THE ONBOARDING PROCESS
| Step | What happens | What is recorded |
| 1 | First discussion | We provide goal-based investment services on an execution-only basis, with guidance incidental to our distribution services. No separate fee is charged for these services. |
| 2 | Information gathering | Name, date of birth, permanent account number, address, mobile number, e-mail address, bank details, occupation and income range are collected with your consent. |
| 3 | KYC verification | KYC status is checked with a KYC Registration Agency and the Central KYC Registry. Where it is not complete, it is completed before any transaction is placed. |
| 4 | Verification of identity | In-Person Verification or the permitted online verification is carried out and the record is preserved. |
| 5 | Declarations | Tax residency declaration under FATCA and the Common Reporting Standard, and beneficial ownership details for a non-individual investor, are obtained. |
| 6 | Risk profile | Your risk profile is completed, scored, explained to you and signed before the first transaction. |
| 7 | Nomination | Your nomination, or your decision to opt out of nomination, is recorded for every folio. |
| 8 | Account activation | The account is activated on the transaction platform, a bank mandate is registered where required, and a welcome communication is sent to you. |
RULES WE DO NOT BREAK
- No transaction is placed for an investor whose Know Your Customer formalities are not complete.
- No transaction is placed on an investor’s behalf without an instruction from that investor.
- No cash is accepted, and no payment is accepted in the name of the firm or of any employee. Every payment is made in favour of the concerned Asset Management Company.
- No signed blank form, cheque or transaction slip is accepted or retained.
- A one time password, folio password, net banking credential or debit card detail is never sought from an investor.
- The Employee Unique Identification Number of the person who canvassed the transaction is recorded on every application.
TAX RESIDENCY, RECORDS AND UPDATION
- Every investor gives a self-certification of tax residency under FATCA and the Common Reporting Standard at onboarding. A fresh certification is obtained whenever a change in circumstances affects the declaration.
- Where an investor is a non-resident, the applicable account type and the repatriation position are recorded on the folio.
- Where the investor is a minor, the guardian’s Know Your Customer records are obtained and the date of majority is tracked so that the folio is regularised on time.
- Records of identity, transactions and correspondence are preserved for the periods required by the Prevention of Money Laundering Act, 2002 and the rules made under it.
- Changes in address, mobile number, e-mail address, bank account, tax status or nomination are given effect only through the Asset Management Company or the Registrar, on your authenticated instruction.