Anti-Money Laundering Policy.

The Prevention of Money Laundering Act, 2002 (PMLA) has been brought into force with effect from 1st July 2005. Necessary Notifications and Rules under the said Act have been published in the Gazette of India on 1st July 2005 by the Department of Revenue, Ministry of Finance, Government of India.

Under the recommendation made by the Financial Action Task Force on Anti-Money-Laundering standards, SEBI had issued the guidelines on Anti-Money-Laundering standards vide notification no. SEBI/HO/MIRSD/DOS3/CIR/P/2018/104 dated 4 July 2018, ISD/CIR/RR/AML/1/6 dated 18 January 2006, and vide letter no. ISD/CIR/RR/AML/2/6 dated 20 March 2006 had issued the obligation on Intermediaries registered under section 12 of the Securities and Exchange Board of India Act, 1992 (the Act). As per the SEBI guidelines, all Intermediaries have been advised to ensure that proper policy frameworks are put in place as per the guidelines on Anti-Money-Laundering standards notified by SEBI.

Sentinel Research Private Limited has formulated this policy on PMLA and an effective AML program to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities, or the flow of illegal money, or hiding money to avoid paying taxes. Money Laundering can be defined as engaging in financial transactions that involve income derived from criminal activity — transactions designed to conceal the true origin of criminally derived proceeds and appearing to have been received through legitimate sources or origins.

These policies and procedures apply to all employees and affiliates of Sentinel Research Private Limited as per the statutory provisions, and are to be read in conjunction with existing guidelines. The procedures below have been established to ensure that all employees know the identity of their customers and take appropriate steps to combat money-laundering incidents.

The objective of this policy framework is —

• To create awareness and provide clarity on KYC standards and AML measures.
• To have a proper Customer Due Diligence (CDD) process before registering clients.
• To monitor and maintain records of all cash transactions of the value of more than INR 10 lakh.
• To maintain records of all series of integrally connected cash transactions within one calendar month.
• To monitor and report suspicious transactions.
• To discourage and identify money laundering or terrorist financing activities.
• To take adequate and appropriate measures to follow the spirit of the PMLA.

Ms. Ashima Bali is the Principal Officer. She is responsible for overseeing the implementation of this Policy. Employees shall refer all matters concerning the issues covered by this Policy to the Principal Officer and shall act in accordance with her instructions in this behalf.

All submissions required to be made by Employees in terms of this Policy shall be addressed to the Principal Officer. The Principal Officer shall be responsible for maintaining and updating all records in accordance with this Policy or any applicable law / regulation.

Sentinel Research Private Limited has resolved that it would, as an internal policy, take adequate measures to prevent money laundering and shall put in place a framework for identifying, monitoring, and reporting suspected money-laundering or terrorist-financing transactions to FIU as per the guidelines of the PMLA Rules, 2002. Further, Sentinel Research Private Limited shall regularly review the policies and procedures on PMLA and Terrorist Financing to ensure their effectiveness.

The Principal Officer shall ensure overall compliance with the obligations imposed under the PML Act and the PML Rules. The Principal Officer will ensure the filing of necessary reports with the Financial Intelligence Unit (FIU-IND). The Principal Officer would act as a central reference point in facilitating onward reporting of suspicious transactions and playing an active role in the identification and assessment of potentially suspicious transactions.

Obtaining sufficient information about the client in order to identify who is the actual beneficial owner of the securities or on whose behalf the transaction is conducted. The beneficial owner is the natural person or persons on whose behalf a transaction is being conducted. It also incorporates those persons who exercise ultimate effective control over a legal person or arrangement.

Verify the customer's identity using reliable, independent source documents, data, or information.

Conduct ongoing due diligence and scrutiny of the account / client to ensure that the transactions conducted are consistent with the client's background, financial status, activities, and risk profile.

We will accept clients whose identity we are able to verify as per government guidelines. Either the client should visit the office or branch, or a concerned official may visit the client at their residence or office to get the necessary documents filled in and signed. We may also use approved online modes, methods, and standard practices to verify the identity and documents of prospective clients.

In case accounts are opened in the name of an NRI (where Sentinel Research Private Limited cannot personally verify the NRI Client), the KYC team shall ensure photocopies of all KYC documents and PAN Card are attested by the Indian Embassy or Consulate General in the country where the NRI resides — or as per the prevailing guidelines. The photocopies of the KYC documents and PAN Card should be signed by the NRI. If the NRI comes in person to open the account, the above attestation may be waived.

Detailed search will be carried out to confirm that the client is not on defaulters or negative lists of regulators. Sentinel Research Private Limited will obtain complete information from the client. It shall be ensured that the initial forms taken from clients are filled in completely. All photocopies submitted by the client are checked against original documents without any exception. Ensure that the 'Know Your Client' guidelines are followed without any exception. All supporting documents as specified by SEBI and the Exchanges are obtained and verified.

We will not accept clients whose identity matches persons known to have criminal background. We will check whether the client's identity matches with any person having known criminal background or is banned in any other manner — whether in terms of criminal or civil proceedings by any enforcement or regulatory agency worldwide.

Reference databases checked before onboarding (indicative)

• fatf-gafi.org/en/home.html
• un.org/securitycouncil/content/un-sc-consolidated-list
• watchoutinvestors.com/default2a.asp
• Data available on the SEBI website and other relevant enforcement sites.
• Any other database available at the prevailing time.

We are very careful when accepting clients of the following categories:

• Non-Resident clients.
• High Net-Worth clients — clients having an annual income of INR 25 lakh or more, or a Net Worth of INR 10 crore or more.
• Trusts, Charities, NGOs, and organizations receiving donations.
• Companies having close family shareholdings or beneficial ownership.
• Politically Exposed Persons (PEPs) — individuals who are or have been entrusted with prominent public functions in a foreign country (e.g. Heads of State or Government, senior politicians, senior government / judicial / military officers, senior executives of state-owned corporations, important political party officials), applied also to the accounts of their family members or close relatives.
• Companies offering foreign exchange.
• Clients in high-risk countries (as per the latest data provided by the government) — where the existence or effectiveness of money-laundering controls is suspect, where there is unusual banking secrecy, countries active in narcotics production, countries where corruption is highly prevalent (as per Transparency International Corruption Perception Index), countries against which government sanctions are applied, and countries reputed as sponsors of international terrorism, offshore financial centers, tax havens, or countries where fraud is highly prevalent.
• Clients with dubious reputation as per public information available.
• Persons of foreign origin, companies having closed shareholding or ownership, companies dealing in foreign currency, shell companies, overseas entities, and clients in high-risk countries.

For non-individual customers, as part of the due diligence measures, sufficient information must be obtained in order to identify persons who beneficially own or control the securities account. Whenever it is apparent that the securities acquired or maintained through an account are beneficially owned by a party other than the client, that party should be identified and verified using client-identification and verification procedures as early as possible. The beneficial owner is the natural person or persons who ultimately own, control, or influence a client and / or persons on whose behalf transactions are being conducted, including persons who exercise ultimate effective control over a legal person or arrangement.

Do not accept client registration forms that are suspected to be fictitious. Ensure that no account is being opened in a fictitious, benami, or anonymous basis.

Do not compromise on submission of mandatory information or documents. The client's account should be opened only on receipt of mandatory information along with authentic supporting documents as per the regulatory guidelines. Do not open the account where the client refuses to provide information or documents — there is sufficient reason to reject the client when there is such reluctance.

To have a mechanism in place to establish the identity of the client along with firm proof of address — to prevent the opening of any account which is fictitious, benami, or anonymous in nature.

Documents that can be relied upon

• PAN Card — mandatory and the most reliable document; only one card is issued per individual and its genuineness can be checked independently through the IT website.
• Address Proof — Voter's Identity Card, Passport, Bank Statement, Aadhaar Letter, Ration Card, and latest electricity or telephone bill in the name of the client.

Documents to be obtained for new clients, by entity type

List is for illustration purposes. Actual need of documents will be dependent on the prevailing guidelines.

Risk assessment on money laundering depends on the kind of customers the RA deals with. Typically, risks are increased if the money launderer can hide behind corporate structures such as limited companies, offshore trusts, special-purpose vehicles, and nominee arrangements. The Risk Assessment is required in order to assess and take effective measures to mitigate ML and terrorist-financing risk with respect to clients, countries or geographical areas, nature and volume of transactions, payment methods used by clients, etc. The risk assessment shall also take into account any country-specific information that is circulated by the Government of India and SEBI from time to time, as well as the updated list of individuals and entities subjected to sanction measures under the various United Nations Security Resolutions and other international organizations of repute.

Risk Classification

The level of Money Laundering risks that Sentinel Research Private Limited is exposed to by an investor relationship depends on the type of customer and nature of business, the type of product or service availed, and the country where the customer is domiciled. Based on these criteria, customers may be classified into three categories:

This list is indicative only and will depend on various other relevant factors at the time of evaluation. The risk profile also depends on the trading pattern, payment pattern, financial status, and background of the client. Sentinel Research Private Limited will put in place a system of periodic review of risk categorization. For High-Risk clients, categorization shall be carried out at least once in six months; for Medium and Low-Risk clients, the frequency shall be once in a year.

Safeguards while accepting clients

• The client account should not be opened in a fictitious / benami name or on an anonymous basis.
• Risk perception of the client needs to be defined having regard to client's location (registered office, correspondence, and other applicable addresses), nature of business activity, turnover, manner of making payment for transactions undertaken.
• Documentation (KYC, broker-client agreement, Risk Disclosure Document, and other information) prescribed by SEBI and any other regulatory authority is to be collected depending on perceived risk.
• Ensure that a client account is not opened where the organization is unable to apply appropriate client due-diligence / KYC policies — including cases where it is not possible to ascertain the identity of the client, or the information provided is suspected to be non-genuine, or there is perceived non-cooperation. Discontinue dealings with such a person and file a suspicious activity report.
• Where a client is permitted to act on behalf of another person / entity, clearly specify the manner of operation, transaction limits, additional authority required for transactions exceeding specified quantity / value, and the rights and responsibilities of both persons (agent and principal).
• Adequate verification of a person's authority to act on behalf of the customer.
• Necessary checks and balances before opening an account to ensure the identity of the client does not match persons with known criminal background or those banned by any enforcement agency worldwide.

For New Clients

• Each client may be met in person or through online verification (as per regulatory guidelines) before accepting the KYC.
• Verify the PAN details on the Income Tax website.
• All documentary proofs given by the client should be verified with original.
• Documents like the latest Income Tax returns and annual accounts should be obtained for ascertaining financial status. Obtain additional information if required.
• Obtain complete information about the client and ensure that KYC documents are properly filled, signed, and dated.
• If the client does not provide the required information, do not open the account.
• As far as possible, prospective clients should be accepted only if introduced by Sentinel Research Private Limited's existing client, associate, or known entity.

For Existing Clients

• Keep updating the financial status of the client by obtaining the latest Income Tax Return, Net Worth Certificate, annual accounts, etc.
• Update client details (address, contact number, demat details, bank details, etc.). If unable to contact the client, contact the introducer for alternative details.
• Check whether the client's identity matches any person with known criminal background. Reference: watchoutinvestors.com, SEBI Prosecution Database / List of Vanishing Companies, and the RBI Defaulters Database on cibil.com.
• Scrutinize minutely the records pertaining to special-category clients (NRIs, HNIs, Trusts, Charities, NGOs, companies with close family shareholding, PEPs, persons of foreign origin, current / former Heads of State and senior politicians, foreign-exchange offering companies, etc.) and clients from high-risk countries or countries with high corruption / fraud.
• Review the above on an ongoing basis to ensure transactions are consistent with knowledge of the customer, their business, and risk profile.

Mandate Holder Policy

• The primary objective is to ensure we are aware of who is the ultimate beneficiary of the transaction and that transactions executed through the mandate holder are bona fide.
• Trading accounts may be opened in the name of various family members with one holding the mandate; for NRI clients based abroad, a PoA / mandate may be in favour of a person residing in India.
• Whenever an account is operated by a mandate holder, find out the relationship with the client and establish the identity of the mandate holder by obtaining proof of identity and address.
• Do not accept payment from the mandate holder's account in favour of the client. All payments must be received from the client's bank account only. Similarly, payout cheques should be issued only in the name of the client.
• If there is suspicion on the relationship between the mandate holder and the actual client — or if the holder's behaviour is suspicious — take necessary advice from the Business Head.

Roles & Duties

• The Sales Person / Relationship Manager / Dealer / Branch Manager / Branch Coordinator / Business Head / Marketing Manager should meet the client in person or via legally acceptable online mode at least once before opening the account.
• If the client is a walk-in, the branch official should make independent verification of background, identity, and financial worthiness.
• All mandatory proofs of identity, address, and financial status must be collected, verified against originals.
• In-Person Verification (IPV) can be done by the respective person or associate / affiliate / agent.
• For accounts handled by a PoA / mandate holder — establish the relationship, identity, and background of both client and holder, and ensure proper authorization.
• For corporate accounts — ensure the authorized person has Board Resolution and that identity / background is established with required documents.
• Foreign clients can deal in the Indian market only to sell shares allotted through ESOP or to buy / sell as Foreign Direct Investment. We cannot deal for foreign clients under any other circumstances.

• Sentinel Research Private Limited regularly monitors transactions to identify any deviation in transactions or activity, ensuring the effectiveness of AML procedures.
• The firm shall pay special attention to all unusually large transactions or patterns which appear to have no economic purpose.
• Internal threshold limits may be specified for each class of client accounts on the basis of various plans; transactions exceeding these limits attract special attention.
• The background — including all documents, office records, memorandums, clarifications sought pertaining to such transactions and the purpose thereof — shall be examined carefully and findings recorded in writing. Such findings, records, and related documents shall be made available to auditors and to SEBI, stock exchanges, FIU-IND, or other relevant authorities during audit, inspection, or as and when required. These records are required to be maintained and preserved for a period of five years from the date of transaction between the client and intermediary, as required under PMLA.

All are requested not to accept cash from clients — whether against obligations, as margin for purchase of securities, or otherwise. All payments shall be received from clients strictly by account-payee crossed cheques drawn in favour of Sentinel Research Private Limited. The same is also required as per SEBI circular no. SMD/ED/IR/3/23321 dated 18 November 1993 and SEBI/MSD/SE/Cir-33/2003/27/08 dated 27 August 2003.

In case account-payee cheques have been received from a bank account other than that captured in records, the same can be accepted after ascertaining that the client is the first holder of the account. Only in exceptional cases, a bank draft or pay-order may be accepted from the client provided the identity of the remitter / purchaser written on the draft or pay-order matches with that of the client — else a certificate from the issuing bank should be obtained to verify the same.

Reliance on a Third Party for Customer Due Diligence

Sentinel Research Private Limited may rely on a third party for the purposes of (i) identification and verification of the identity of a client; (ii) determination of whether the client is acting on behalf of a beneficial owner and identification of that owner; and (iii) verification of the identity of the beneficial owner.

Such third party shall be regulated, supervised, or monitored — and have measures in place for compliance with CDD and record-keeping requirements in line with the obligations under the PML Act. Such reliance shall be subject to the conditions specified in Rule 9(2) of the PML Rules, and in accordance with SEBI's regulations and circulars. Further, it is clarified that Sentinel Research Private Limited shall be ultimately responsible for CDD and undertaking enhanced due-diligence measures, as applicable.

Sentinel Research Private Limited shall ensure compliance with the record-keeping requirements contained in the SEBI Act, 1992, Rules and Regulations made thereunder, PMLA, as well as other relevant legislation, Rules, Regulations, Exchange Bye-laws, and Circulars.

More specifically, the firm shall put in place a system of maintaining proper record of transactions prescribed under Rule 3 of PML Rules as below:

• All cash transactions of the value of more than ten lakh rupees or its equivalent in foreign currency.
• All series of cash transactions integrally connected to each other which have been individually valued below ten lakh rupees or its equivalent in foreign currency, where such series of transactions have taken place within a month and the monthly aggregate exceeds an amount of ten lakh rupees or its equivalent in foreign currency.
• All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine, or where any forgery of a valuable security or document has taken place facilitating the transactions.
• All suspicious transactions whether or not made in cash, by way of as mentioned in the Rules.

Retention of Records

• All necessary records on transactions — both domestic and international — should be maintained for at least a minimum period of ten (10) years from the date of cessation of the transaction.
• Records on customer identification (copies or records of official identification documents like passports, identity cards, driving licenses, or similar documents), account files, books of account, and business correspondence should also be kept for ten years from the date of cessation of the transaction.
• Records shall be maintained in hard and soft copies.
• It shall be ensured that there is continuity in dealing with the client as normal until told otherwise, and the client should not be told of the report or suspicion. In exceptional circumstances, consent may not be given to continue to operate the account and transactions.
• Sentinel Research Private Limited shall take appropriate steps to evolve an internal mechanism for proper maintenance and preservation of such records — allowing easy and quick retrieval of data as and when requested by the competent authorities.

Sentinel Research Private Limited, on an ongoing basis, monitors the transactions executed by clients in order to ascertain whether the same is "suspicious" — which should be reported to FIU-IND. The following surveillance / alerts based on the client's transactions on NSE / BSE / DP and circumstances may be in the nature of suspicious transactions.

Criteria for Ascertaining Suspicious Transactions

• Whether a particular transaction is suspicious or not will depend upon the client's details, transactions, identity, receipt / payment pattern, and other facts and circumstances.
• Clients whose identity verification is difficult — including non-cooperation of the client.
• Clients belonging to (or introduced by) persons or entities in high-risk countries.
• Increase in clients' business without justification and turnover not commensurate with financials.
• Unusual large cash deposits.
• Overseas receipts or payments of funds, with or without instructions to pay in cash transactions.
• Transfer of proceeds to unrelated parties.
• Negotiated trades / matched trades.
• Relation of the client with Sentinel Research Private Limited.
• Clients making huge and regular losses but still placing trades / orders — and further identifying the sources of funds in such cases.
• Large volume in the proprietary account of sub-brokers / affiliates / dealers.
• Asset management services where the source of funds is unclear or not in keeping with the client's apparent standing or business activity.
• Clients based in high-risk jurisdictions.
• Unusual transactions undertaken by "Client of Special Category (CSCs)" — i.e. offshore, etc.

Sentinel Research Private Limited shall maintain and preserve the records of information related to transactions — whether attempted or executed — which are reported to the Director, FIU-IND, as required under Rules 7 and 8 of the PML Rules, for a period of five years from the date of the transaction between the client and Sentinel Research Private Limited.

List of Designated Individuals / Entities

An updated list of individuals and entities which are subject to various sanction measures — such as freezing of assets / accounts, denial of financial services, etc. — as approved by the Security Council Committee established pursuant to various United Nations Security Council Resolutions (UNSCRs), can be accessed on the UN website.

Sentinel Research Private Limited ensures that accounts are not opened in the name of anyone whose name appears in said list. The firm shall continuously scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list. Full details of accounts bearing resemblance with any of the individuals / entities in the list shall immediately be intimated to SEBI and FIU-IND.

Procedure for Freezing of Funds

Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA), relating to the purpose of prevention of money laundering and coping with terrorist activities, was brought into effect through UAPA Amendment Act, 2008. The Central Government issued an order dated 27 August 2009 detailing the procedure for the implementation of Section 51A of the UAPA. Reference is also made to notification no. SEBI/HO/MIRSD/DOP/CIR/P/2021/36 dated 25 March 2021.

Under the aforementioned section, the Central Government is empowered to freeze, seize, or attach funds and other financial assets or economic resources held by, on behalf of, or at the direction of the individuals or entities listed in the Schedule to the Order — or any other person engaged in or suspected to be engaged in terrorism. The Government is also further empowered to prohibit any individual or entity from making any funds, financial assets, or economic resources, or related services, available for the benefit of the listed individuals or entities or any other person engaged in or suspected to be engaged in terrorism.

Sentinel Research Private Limited shall ensure effective and expeditious implementation of the procedure laid down in the UAPA Order dated 27 August 2009 and the order dated 2 February 2021.

In terms of the PML Rules, Sentinel Research Private Limited is required to report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address:

Sentinel Research Private Limited shall carefully go through all the reporting requirements and formats that are available on the website of FIU-IND under the section "Obligation of Reporting Entity — Furnishing Information — Reporting Format". These documents contain detailed directives on the compilation and manner / procedure of submission of the reports to FIU-IND. The related hardware and technical requirements for preparing reports, the related data files, and data structures are also detailed in those documents.

• The Cash Transaction Report (CTR) (wherever applicable) for each month shall be submitted to FIU-IND by the 15th of the succeeding month.
• The Suspicious Transaction Report (STR) shall be submitted within 7 days of arriving at a conclusion that any transaction (cash or non-cash, or a series of integrally connected transactions) is of suspicious nature. The Principal Officer shall record her reasons for treating any transaction as suspicious. There shall be no undue delay in arriving at such a conclusion.
• The Non-Profit Organization Transaction Reports (NTRs) for each month shall be submitted to FIU-IND by the 15th of the succeeding month.
• The Principal Officer will be responsible for timely submission of CTR, STR, and NTR to FIU-IND.
• Utmost confidentiality shall be maintained in filing of CTR, STR, and NTR to FIU-IND.
• No nil-reporting needs to be made to FIU-IND in case there are no cash / suspicious / non-profit-organization transactions to be reported.

Appointment of a Principal Officer

To ensure that Sentinel Research Private Limited properly discharges its legal obligations to report suspicious transactions to the authorities, the Principal Officer would act as a central reference point in facilitating onward reporting of suspicious transactions and for playing an active role in the identification and assessment of potentially suspicious transactions — and shall have access to and be able to report to senior management at the next reporting level.

Ms. Ashima Bali is appointed as Principal Officer. The details of her appointment have been intimated to the Financial Intelligence Unit, India (FIU-IND).

Names, designation, and addresses (including email addresses) of the Principal Officer — including any changes therein — shall also be intimated to the Office of the Director-FIU. As a matter of principle, the Principal Officer will be in a sufficiently senior position and able to discharge functions with independence and authority.

Hiring of Employees

Sentinel Research Private Limited shall have adequate screening procedures in place to ensure high standards when hiring employees. The firm shall identify key positions within its own organizational structures having regard to the risk of money laundering and terrorist financing and the size of business — and ensure employees taking up such key positions are suitable and competent to perform their duties.

Employees' Training

Sentinel Research Private Limited has an ongoing employee training program so that members of staff are adequately trained in AML, Combating the Financing of Terrorism (CFT), and other relevant procedures. Training requirements shall have specific focus for front-line staff, back-office staff, compliance staff, risk-management staff, and staff dealing with new clients. It is crucial that all those concerned fully understand the rationale behind these directives and implement them consistently — and are sensitive to the risks of their systems being misused by unscrupulous elements. Regular AML / CFT training programs will be conducted to ensure awareness of regulatory requirements and internal procedures, including case studies and examples relevant to the securities market.

Implementation of AML measures requires Sentinel Research Private Limited to demand certain information from investors which may be of personal nature or has hitherto never been called for. Such information can include documents evidencing source of funds, income-tax returns, bank records, etc. This can sometimes lead to questions from the client regarding the motive and purpose of collecting such information.

There is, therefore, a need for the firm to sensitize its clients about these requirements as the ones emanating from AML frameworks and Combating the Financing of Terrorism (CFT). Sentinel Research Private Limited shall prepare specific literature and pamphlets to educate clients on the objectives of the AML program. The said literature shall be displayed on the website.

Sentinel Research Private Limited shall ensure the following:

• The content of these Directives is understood by all staff members.
• The firm will regularly review the policies and procedures for the prevention of AML on an annual basis to ensure their effectiveness. The person doing such a review shall be different from the one who has framed such policies and procedures.
• Adoption of client-acceptance policies and procedures that are sensitive to the risk of AML.
• Undertake Client Due Diligence (CDD) measures to an extent that is sensitive to the risk of AML — depending on the type of client, business relationship, or transaction.
• Maintain a system for identifying, monitoring, and reporting suspected ML or TF transactions to law-enforcement authorities.
• Develop staff members' awareness and vigilance to guard against ML and TF.
• Risk-Based Approach — Clients will be classified into Low, Medium, and High risk categories based on parameters such as nature of business, geographic location, type of products / services used, and transaction patterns. Enhanced Due Diligence (EDD) will be applied for high-risk clients — including Politically Exposed Persons (PEPs), non-resident clients from high-risk jurisdictions, and those engaging in complex or high-value transactions.
• Enhanced Due Diligence (EDD) — For high-risk clients, additional information will be collected and verified including the source of funds / wealth, and transactions will be subject to enhanced monitoring. Periodic review frequency will be higher for such clients.
• Data Protection & Confidentiality — Sentinel Research Private Limited ensures secure storage of all KYC and transaction data, with access restricted to authorized personnel only. Data will be protected in compliance with applicable privacy laws.