Anti-Money Laundering (AML) Policy

Reddington Financial Advisory Private Limited (“Reddington,” “we,” “our,” or “us”) is committed to complying with all applicable anti-money laundering (AML) laws and regulations to prevent the use of our services for money laundering, terrorist financing, or other illegal activities. This Anti-Money Laundering Policy outlines the procedures and controls we have implemented to detect, deter, and report potential money laundering activities.

1. Purpose

The purpose of this AML Policy is to:

• Prevent the misuse of Reddington’s financial services for money laundering, terrorist financing, or other illegal activities.
• Comply with applicable laws, regulations, and guidelines, including those set forth by the Reserve Bank of India (RBI) and other relevant authorities.
• Protect the reputation and integrity of Reddington by implementing robust controls and procedures to mitigate AML risks.

2. Scope

This policy applies to all employees, contractors, clients, investors, and third-party service providers involved in financial transactions with Reddington, including:

• Individual and corporate clients.
• Partners, agents, and associates.
• Employees and contractors engaged in financial operations.

3. AML Compliance Framework

3.1 Risk-Based Approach (RBA)

Reddington adopts a risk-based approach to AML compliance, which involves:

• Identifying Risks: Assessing the level of AML risk associated with clients, transactions, and business activities.
• Risk Categorization: Classifying clients and transactions based on the level of risk they pose (e.g., low, medium, high).
• Tailored Controls: Applying enhanced due diligence, monitoring, and controls to higher-risk clients and transactions.

3.2 Customer Due Diligence (CDD)

Customer Due Diligence is a critical component of our AML framework and includes:

• Client Identification: Verifying the identity of clients through reliable and independent sources, as outlined in our KYC Policy.
• Risk Assessment: Evaluating the risk profile of each client, considering factors such as geography, nature of the business, transaction volume, and political exposure.
• Enhanced Due Diligence (EDD): Conducting EDD for high-risk clients or transactions, including those involving politically exposed persons (PEPs), large sums of money, or complex ownership structures.

3.3 Ongoing Monitoring

We conduct ongoing monitoring of clients and transactions to detect and report suspicious activities:

• Transaction Monitoring: Continuously monitoring transactions for unusual or suspicious patterns, including large or irregular transfers, transactions involving high-risk jurisdictions, and other red flags.
• Regular Reviews: Periodically reviewing client profiles and transactions to ensure that AML risks are adequately managed.
• Alert Systems: Implementing automated alert systems to flag suspicious activities for further investigation.

3.4 Suspicious Activity Reporting (SAR)

Reddington has established procedures for identifying and reporting suspicious activities:

• Internal Reporting: Employees are required to report any suspicious activities to the Compliance Officer immediately.
• SAR Filing: The Compliance Officer is responsible for reviewing suspicious activities and filing Suspicious Activity Reports (SARs) with the Financial Intelligence Unit (FIU) or other relevant authorities as required by law.
• Confidentiality: All SARs and related investigations are handled confidentially to protect the integrity of the process and comply with legal requirements.

3.5 Record Keeping

We maintain detailed records of all transactions, client information, and AML-related activities:

• Transaction Records: Keeping records of all financial transactions for at least [insert period, e.g., 5 years] as required by law.
• KYC Documents: Retaining copies of all client identification and verification documents as part of our CDD process.
• AML Compliance Logs: Maintaining logs of all AML-related activities, including SAR filings, client risk assessments, and internal audits.

3.6 Training and Awareness

Reddington ensures that all employees are adequately trained on AML compliance:

• Regular Training: Providing ongoing AML training to employees to ensure they are aware of their obligations and the latest AML trends and regulations.
• Role-Specific Training: Tailoring training programs to the specific roles and responsibilities of employees, particularly those involved in client interactions and financial transactions.
• Awareness Campaigns: Conducting regular awareness campaigns to highlight the importance of AML compliance and the risks associated with money laundering.

4. Roles and Responsibilities

4.1 Board of Directors

The Board of Directors is responsible for:

• Oversight: Providing oversight of the AML Policy and ensuring that it aligns with Reddington’s strategic objectives.
• Approval: Approving the AML Policy and any significant updates or changes.

4.2 Compliance Officer

The Compliance Officer is responsible for:

• Implementation: Ensuring that the AML Policy is implemented effectively across the organization.
• Monitoring: Regularly monitoring compliance with AML requirements and conducting internal audits.
• Reporting: Filing SARs and other required reports with regulatory authorities and providing regular updates to the Board of Directors.

4.3 Employees

All employees are responsible for:

• Compliance: Adhering to the AML Policy in their daily operations and reporting any suspicious activities to the Compliance Officer.
• Training: Participating in AML training programs and staying informed about the latest AML regulations and risks.
• Client Interaction: Ensuring that all client interactions are conducted in compliance with the AML Policy and that all necessary due diligence is performed.

5. Compliance with Regulatory Requirements

5.1 Regulatory Framework

Reddington’s AML Policy complies with all applicable AML laws and regulations, including:

• Prevention of Money Laundering Act (PMLA): Adhering to the provisions of the PMLA, including the reporting of suspicious activities and the maintenance of appropriate records.
• Reserve Bank of India (RBI) Guidelines: Complying with RBI’s guidelines on AML and KYC practices.
• Foreign Exchange Management Act (FEMA): Ensuring that all transactions involving foreign entities comply with FEMA regulations.

5.2 Regulatory Reporting

We fulfill all AML-related regulatory reporting obligations, including:

• Suspicious Transaction Reports (STRs): Reporting suspicious transactions to the Financial Intelligence Unit (FIU) or other relevant authorities as required.
• Cash Transaction Reports (CTRs): Reporting large cash transactions exceeding regulatory thresholds.
• Regulatory Audits: Participating in audits conducted by regulatory authorities and implementing any required changes or improvements.

5.3 Sanctions Compliance

Reddington complies with all international and domestic sanctions, including those imposed by:

• United Nations: Adhering to UN sanctions lists and ensuring that no transactions involve sanctioned entities or individuals.
• OFAC: Complying with the U.S. Office of Foreign Assets Control (OFAC) sanctions, where applicable.
• Domestic Authorities: Complying with any additional sanctions imposed by Indian authorities.

6. Policy Review and Updates

This AML Policy is reviewed and updated annually or more frequently as necessary to ensure it remains relevant and effective in the face of evolving AML risks and regulatory changes. All updates are approved by the Board of Directors and communicated to all relevant stakeholders.

7. Non-Compliance and Penalties

Non-compliance with this AML Policy can result in:

• Disciplinary Action: Employees who fail to comply with the AML Policy may face disciplinary action, including termination of employment.
• Legal Consequences: Non-compliance with AML regulations can result in severe legal consequences, including fines, penalties, and criminal prosecution.

8. Closing Note

Reddington Financial Advisory Private Limited is dedicated to maintaining the highest standards of integrity and compliance in all our financial dealings. Our AML Policy reflects our commitment to preventing financial crime and protecting the integrity of our financial systems. We appreciate the cooperation of our employees, clients, and partners in upholding these principles and ensuring that our services are not used for illegal purposes.