Investor Charter, Governance & Statutory Disclosures
All 9 documents required under the SEBI (Research Analysts) Regulations, 2014, in one place.
Disclaimer for Website & Research Services
Mandatory disclosure statement governing the dissemination of research recommendations, analytical reports, and digital communications by Saanvi Research under SEBI (Research Analysts) Regulations, 2014.
- Securities Market Risk: Investment in securities market is subject to market risks. Read all the related documents carefully before investing.
- SEBI & NISM Disclaimer: Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.
- Past Performance: Past performance is not indicative of future results. Market conditions can change rapidly and unpredictably.
1. Prohibition of Assured Returns & Fund Handling
- No Assured Returns: Saanvi Research does not offer assured returns, guaranteed profits, or fixed income products in any form whatsoever.
- No Portfolio Handling or Profit Sharing: Saanvi Research does not operate any profit-sharing scheme, automated trading execution services, Portfolio Management Services (PMS), nor does it handle or accept custody of client funds or securities.
- Client Data Confidentiality: Client information collected through this website is kept strictly confidential and used only for regulatory compliance, KYC verification, and authorized communication purposes.
2. Objectivity, Independence & Zero Intermediary Tie-ups
- No Third-Party Commissions: Saanvi Research is not affiliated with any other intermediaries and does not receive any brokerage, referral fee, or commission from any third-party brokers or platforms.
- No Broker Recommendations: Saanvi Research does not recommend any specific stock broker or depository participant to clients, nor receives any consideration by way of remuneration, compensation, or kickbacks in any form from any market intermediary.
- Regulatory Track Record: No penalties or directions have been issued against Saanvi Research under the SEBI Act, 1992, or by any other statutory regulatory body.
- No Issuer Affiliations: Saanvi Research does not have any association in any manner with any issuer of products/securities. This structural independence ensures that there are no actual or potential conflicts of interest, and objectivity in carrying out research services is strictly preserved.
- Chinese Walls: Saanvi Research ensures that individuals employed as research analysts are maintained completely separate from any personnel performing sales trading, dealing, corporate advisory, or marketing activities that could impair analytical independence. Research analysts may only receive feedback from sales or trading personnel to ascertain general market impact.
3. Nature of Investment Perspective & Research Analysis
- Research Methodology: Investment in equity shares and financial derivatives inherently carries risk. Sincere efforts have been made to present an objective investment perspective. The information contained herein is based on rigorous technical and fundamental analysis and on public sources considered reliable.
- No Guarantee of Completeness: Saanvi Research does not vouch for the absolute accuracy, consistency, or completeness of third-party public data. This material is prepared solely for informational purposes, and Saanvi Research accepts no financial liability or responsibility for any direct or indirect losses incurred from acting on research recommendations.
- No Sectoral Bias: Saanvi Research does not provide any promise or assurance of a favorable view toward any particular industry, sector, or corporate business group in any manner.
- Suitability Evaluation: Every investor is strictly requested to evaluate all risk factors, including their own financial condition, liquidity requirements, and risk-return suitability profile before acting on any research setup.
- Position Holdings Disclosure: Saanvi Research, its research analysts, and related persons may hold trading positions in the securities recommended from time to time, subject to SEBI holding period and pre-clearance disclosure mandates.
- Opinions vs. Discretionary Advice: If a client requests a view on a specific personal portfolio holding, any response provided shall be treated solely as an informational opinion (not individualized financial planning). Saanvi Research shall not be liable for any portfolio outcome arising from such opinions.
4. Proprietary Intellectual Property & Anti-Piracy Notice
Strict Prohibition Against Unauthorized Forwarding:
Research recommendations, reports, portal access, and trade alerts are provided exclusively to authorized, registered subscribers of Saanvi Research. Any client (paid or trial), recipient, or third party has no right to copy, redistribute, forward, publish, or share our calls, SMS, WhatsApp alerts, Telegram messages, or research reports to/with any individual, group, or channel through any medium whatsoever. Any unauthorized leakage or republishing will invite immediate account termination, forfeiture of fees, and stringent civil and criminal legal action under the Copyright Act, 1957, and the Information Technology Act, 2000.
5. Client Responsibility, Execution Risk & Simulated Results
- Sole Execution Responsibility: Stock, index, and derivatives trading is inherently volatile. You agree to assume complete and full personal responsibility for all trade execution, stop-loss adherence, and capital allocation outcomes.
- Simulated & Backtested Metrics: Backtested or simulated track records do not represent actual executed trading by clients and cannot account for market slippage, broker latency, or execution delays. No representation is being made that any account will or is likely to achieve profits identical to backtested models.
- Independent Research Resource: Investors are strongly encouraged to use Saanvi Research publications as a disciplined analytical framework to complement their own due diligence before executing orders in the market.
6. Social Media Policy & Impersonation Alert
- Educational Purpose of Social Channels: All content, charts, and case studies published on public social media handles (Twitter/X, Facebook, YouTube, Telegram, LinkedIn) are strictly for educational and illustrative purposes and must not be construed as investment recommendations or individualized advice.
- Fraudulent Impersonators: Please exercise vigilance against fraudulent social media accounts, impersonators on Telegram/WhatsApp, and unofficial payment QR codes. Always verify credentials on www.saanviresearch.com and make fee payments only through authorized banking channels or the designated fee portal. Saanvi Research accepts no liability for losses caused by rogue third parties impersonating our brand.
Grievance Redressal / Escalation Matrix
In accordance with SEBI guidelines and BSE Circular (Notice No. 20241209-41), SANDEEP KUMAR PROPRIETOR OF SAANVI RESEARCH (SEBI Reg. No. INH000029980) provides the following structured escalation hierarchy to resolve investor grievances efficiently and transparently.
Approaching the Research Analyst prior to Regulatory Escalation:
The details provided below facilitate complainants to approach the concerned Research Analyst before filing a complaint to SEBI. We are committed to fair, prompt, and satisfactory redressal of all client issues.
| Details of Designation | Contact Person Name | Physical Address Location | Contact No. | Email-ID | Working Hours |
|---|---|---|---|---|---|
1Customer Care | Sandeep Kumar | C 01 Sai city, Dhabli Indore, Madhya Pradesh, 453771 · Business Office: Office No. 202 & 101-A, Plot No. 10, Radhika Palace, Main Road, Indore, Madhya Pradesh – 3rd Floor | +91 7566369126 / 0731-4001510 / 4001510 | [email protected] | Mon - Fri 09:00 AM – 05:00 PM |
2Head of Customer Care | -- | -- | -- | -- | -- |
3Compliance Officer | Sandeep Kumar | C 01 Sai city, Dhabli Indore, Madhya Pradesh, 453771 · Business Office: Office No. 202 & 101-A, Plot No. 10, Radhika Palace, Main Road, Indore, Madhya Pradesh – 3rd Floor | +91 7566369126 / 0731-4001510 / 4001510 | [email protected] | Mon - Fri 09:00 AM – 05:00 PM |
4CEO | -- | -- | -- | -- | -- |
5Principal Officer | Sandeep Kumar | C 01 Sai city, Dhabli Indore, Madhya Pradesh, 453771 · Business Office: Office No. 202 & 101-A, Plot No. 10, Radhika Palace, Main Road, Indore, Madhya Pradesh – 3rd Floor | +91 7566369126 / 0731-4001510 / 4001510 | [email protected] | Mon - Fri 09:00 AM – 05:00 PM |
We aim to resolve all grievances within 21 working days from the date of receipt.
If your grievance is not resolved within this timeframe, you can escalate it to SEBI’s SCORES Platform (SEBI Complaints Redress System):
SCORES Portal: scores.sebi.gov.inIn case you are unsatisfied with the resolution provided through our support or the SCORES platform, you can access the Online Dispute Resolution (ODR) Portal.
ODR Portal: smartodr.inCode of Conduct for Research Analysts
In accordance with Regulation 24(2) read with the Third Schedule of the Securities and Exchange Board of India (Research Analysts) Regulations, 2014, SANDEEP KUMAR (PROPRIETOR OF SAANVI RESEARCH, SEBI Reg. No. INH000029980) shall maintain the following Code of Conduct.
Honesty and Good Faith
Saanvi Research and its research analysts shall act honestly, transparently, and in utmost good faith in all dealings with clients, market participants, and the public.
Diligence & Thorough Analysis
Saanvi Research shall act with due skill, care, diligence, and objective rigor, ensuring that every research report and recommendation is formulated strictly after comprehensive data analysis and verifiable methodology.
Conflict of Interest Management
Saanvi Research shall effectively identify and address any actual or potential conflicts of interest that could compromise the impartiality of research analysis, and shall make prompt, full, and prominent disclosures to address the same.
Prohibition of Insider Trading & Front Running
Saanvi Research and all associated research personnel shall strictly not engage in insider trading, front running, or pre-emptive positioning ahead of releasing any research report, trading call, or recommendation to clients.
Confidentiality & Chinese Walls
Saanvi Research shall maintain absolute confidentiality regarding the contents, price targets, and rationale of research reports until such reports are officially finalized and published to authorized subscribers.
Professional Standards
Being engaged in institutional research analysis, Saanvi Research and its analysts shall observe the highest professional standards, market ethics, and quantitative integrity while authoring research deliverables.
Strict Regulatory Compliance
Saanvi Research shall strictly comply with all regulatory statutes, circulars, and inspection directives issued by SEBI, the Stock Exchanges, RAASB, and the Ministry of Finance applicable to its intermediary operations.
Responsibility of Senior Management
The senior management and Principal Officer of Saanvi Research bear primary responsibility for establishing supervisory systems, monitoring analytical independence, and maintaining adherence to proper governance procedures.
Annual Compliance & Governance Review:
This Code of Conduct is continuously audited and supervised by the designated Compliance Officer of Saanvi Research. Any material breach or non-compliance is subject to disciplinary sanctions, regulatory notification to SEBI, and immediate internal remediation.
Compliance Audit Status
Under Regulation 25(3) of the SEBI (Research Analysts) Regulations, 2014, a Research Analyst shall conduct an annual audit in respect of compliance with the regulations from a member of the Institute of Chartered Accountants of India (ICAI) or Institute of Company Secretaries of India (ICSI).
Saanvi Research maintains an unblemished regulatory audit track record. The annual compliance audit evaluates adherence to analytical independence, research report disclosures, conflict management, record retention, investor grievance handling, and PMLA requirements.
| Sr. No. | Financial Year (FY) | Audit Period | Audit Completion Status | Any Adverse Comments |
|---|---|---|---|---|
| 1 | 2024–25 | April 01, 2024 – March 31, 2025 | Completed / Complied | Nil (No adverse observations) |
| 2 | 2025–26 | April 01, 2025 – March 31, 2026 | In Compliance / Current Cycle | Nil (Ongoing oversight) |
Statutory Inspection & Access Note
Since SEBI Research Analyst registration (INH000029980) was granted on Sep 07, 2026 with perpetual validity, the compliance audit will be conducted annually as per Regulation 25(3). The Audit Reports for the respective financial years are available on demand and can be furnished to the Investor or Regulatory Authority upon request.
Mandatory Regulatory Disclosures
Under Chapter III of SEBI (Research Analysts) Regulations, 2014, SANDEEP KUMAR PROPRIETOR OF SAANVI RESEARCH (SEBI Reg. No. INH000029980) provides the following comprehensive disclosures governing ownership, financial interests, conflict avoidance, and technological research tools.
Registration Particulars
Mr. Sandeep Kumar is registered with SEBI as an Individual Research Analyst (Proprietor of Saanvi Research) under Registration No. INH000029980, dated Sep 07, 2026 with perpetual validity, having registered office address at C 01 Sai city, Dhabli Indore, Madhya Pradesh, 453771. He provides professional Research Analyst services to clients under this statutory registration.
Analyst Qualifications & Expertise
Mr. Sandeep Kumar is a qualified Research Analyst. With a strong analytical skill set, quantitative modeling acumen, and market experience, he excels in identifying institutional investment ideas and implementing disciplined trading strategies.
Methodology of Research Recommendations
Research recommendations and trading setups are formulated using: (a) Fundamental Analysis (macroeconomic indicators, corporate earnings, balance sheet strength, sector valuation), and (b) Technical Analysis (price action, market structure, momentum indicators, volume profile, support-resistance frameworks).
Clean Regulatory & Disciplinary Track Record
There are no outstanding litigations, inquiries, or regulatory proceedings, and no disciplinary actions or penalties have ever been taken against Mr. Sandeep Kumar or Saanvi Research by SEBI or any other statutory authority.
Due Diligence & Timeliness of Data
Mr. Sandeep Kumar has exercised due diligence in checking the correctness and authenticity of the information contained herein, so far as it relates to current and historical information, but does not guarantee its accuracy or completeness. Opinions expressed are based on research as of the date appearing in the material and may be subject to change from time to time without notice.
Limitation of Liability & Client Judgment
Mr. Sandeep Kumar does not accept any liability arising from the use of this document or the information contained herein. The recipients of this material should rely on their own judgment and take their own professional advice before acting on this information.
Non-Liability for Inadvertent Errors
Mr. Sandeep Kumar shall not be in any way responsible for any loss or damage that may arise to any person/s from any inadvertent error in the information contained, views and opinions expressed in this publication.
Conflict of Interest & Shareholding Disclosure
Mr. Sandeep Kumar or his associates, including relatives: (a) Do not hold any financial interest in the subject Company; (b) Do not have any actual/beneficial ownership of more than 1% in the company; (c) Do not have any other material conflict of interest at the time of publication of the research report.
No Intermediary Affiliation or Kickbacks
Mr. Sandeep Kumar or his associates are not affiliated with any other intermediaries and have not received any brokerage or commission from any third party.
No Corporate Compensation Received
Mr. Sandeep Kumar or his associates have not received any compensation from the Company covered by the Research Analyst during the past twelve months.
No Public Offering Management
Mr. Sandeep Kumar or his associates have not managed or co-managed any public offering of securities of the Company during the past twelve months.
No Executive Roles or Market Making Activities
Mr. Sandeep Kumar or his associates have not served as an officer, director or employee of the Company and have not been engaged in market making activity of the Company.
Independent Investor Risk Evaluation
Mr. Sandeep Kumar has ensured that the facts mentioned in the research report are taken from reliable sources and information. However, investors are advised to independently evaluate the market conditions/risks involved before making investment decisions.
Artificial Intelligence (AI) Tools Disclosure
Mr. Sandeep Kumar / Saanvi Research may use Artificial Intelligence (AI) tools and algorithmic screeners as part of the research process to enhance analysis, data processing, and research efficiency.
Legal Confirmation of Disclosure Validity:
These disclosures are maintained in continuous effect and updated whenever any material change occurs in the operational or financial status of the Research Analyst. All subscribers are invited to review these terms prior to engaging any research service.
Redressal of Investor Grievances
As an Individual Research Analyst (SANDEEP KUMAR PROPRIETOR OF SAANVI RESEARCH, SEBI Reg. No. INH000029980), we believe that investor service is an essential part of building trust and sustaining long-term relationships.
Our Commitment to Transparent Resolution:
My aim is to ensure that every investor receives prompt, fair, and respectful service across all communication points. Since research services are provided directly to investors, resolving queries and complaints efficiently becomes extremely important.
How to Raise a Complaint
If you are not satisfied with my services and would like to lodge a complaint, I encourage you to first reach out to me directly. All communication will be handled professionally, responsibly, and with a genuine intent to resolve the issue.
C 01 Sai city, Dhabli Indore, Madhya Pradesh, 453771 · Business Office: Office No. 202 & 101-A, Plot No. 10, Radhika Palace, Main Road, Indore, Madhya Pradesh – 3rd Floor
All complaints will be resolved on a best-effort basis within 7 business days from the date of receipt.
Evaluation of Your Complaint
The first step is for us to be clear about the nature of your complaint, and determine what can be done to resolve it. After completing our review/investigations into your complaint, we will be in touch to provide you with a full response to your complaint.
Escalation to Principal Officer
If you are still not satisfied with the response or the handling of your complaint, you can approach and write an email directly to Sandeep Kumar, Principal Officer at [email protected] with complete details. Sandeep Kumar will get in touch with you at the earliest and try to resolve your complaint as soon as possible.
Escalation to SEBI SCORES 2.0 / RAASB (After 21 Days)
If your complaint is not resolved within a period of 21 days, you may refer your complaint to the regulator – The Securities and Exchange Board of India (SEBI), through the SCORES platform.
Two level review for complaint/grievance against Research Analyst:
- First Review: Done by designated body (RAASB).
- Second Review: Done by SEBI.
SMART Online Dispute Resolution (SMART ODR)
If the Investor is not satisfied with the resolution provided by the SCORES, they may file the complaint/grievance on SMARTODR platform for its resolution through online conciliation or arbitration.
Physical Filing of Complaints with SEBI
With regard to physical complaints, investors may send their complaints to:
Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4-A, ‘G’ Block,
Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051.
Investor Complaints Data & Trend
Mandatory monthly disclosure format prescribed by SEBI for Research Analysts to publish investor complaint records, disposal status, and historical trends on their website and mobile applications.
Zero Escalations & Clean Record
Total complaints pending at month end: 0 • Average resolution time: 0 days
Table 1: Complaint Data for the Month Ending March 31, 2026
Updated: Monthly Basis| Sr. No. | Received From | Pending Last Month | Received | Resolved* | Total Pending# | Pending >3 Months | Avg. Resolution Time^ |
|---|---|---|---|---|---|---|---|
| 1 | Directly from Investors | 0 | 0 | 0 | 0 | 0 | 0 days |
| 2 | SEBI (SCORES 2.0) | 0 | 0 | 0 | 0 | 0 | 0 days |
| 3 | Other Sources (if any) | 0 | 0 | 0 | 0 | 0 | 0 days |
| Grand Total | 0 | 0 | 0 | 0 | 0 | 0 days | |
Table 2: Historical Trend of Monthly Complaint Disposal
| Month | Carried Forward | Received | Resolved* | Pending# |
|---|---|---|---|---|
| Dec-24 | 0 | 0 | 0 | 0 |
| Jan-25 | 0 | 0 | 0 | 0 |
| Feb-25 | 0 | 0 | 0 | 0 |
| Mar-25 | 0 | 0 | 0 | 0 |
| Apr-25 | 0 | 0 | 0 | 0 |
| May-25 | 0 | 0 | 0 | 0 |
| Jun-25 | 0 | 0 | 0 | 0 |
| Jul-25 | 0 | 0 | 0 | 0 |
| Aug-25 | 0 | 0 | 0 | 0 |
| Sep-25 | 0 | 0 | 0 | 0 |
| Oct-25 | 0 | 0 | 0 | 0 |
| Nov-25 | 0 | 0 | 0 | 0 |
| Dec-25 | 0 | 0 | 0 | 0 |
| Jan-26 | 0 | 0 | 0 | 0 |
| Feb-26 | 0 | 0 | 0 | 0 |
| Mar-26 | 0 | 0 | 0 | 0 |
| Total Cumulative | 0 | 0 | 0 | 0 |
Mandatory Regulatory Notes:
- *Resolved: Includes previous months’ pending complaints redressed and resolved during the reporting month.
- #Pending: Includes complaints pending at the close of the reporting month.
- ^Average Resolution Time: Computed as Total resolution days ÷ Total number of resolved complaints.
Investor Charter in Respect of Research Analysts (RAs)
Published in accordance with SEBI circulars to foster investor education, outline regulatory responsibilities, articulate investor rights, and enforce disciplined market standards.
To protect the interests of investors in securities and to promote the development of, and to regulate the securities market by providing independent, objective, and unbiased research analysis.
To maintain high standards of integrity, due diligence, and analytical objectivity; ensure robust conflict management; and empower investors with transparent insights to take informed investment decisions.
C. Details of Business Activities & Obligations
- To publish research reports and recommendations based strictly on thorough technical, quantitative, and fundamental analysis.
- To disclose all material information, ownership interest, conflict of interest, and extent of Artificial Intelligence (AI) tool utilization in research formulation.
- To maintain confidentiality regarding research reports prior to public distribution and prevent front running.
- To ensure non-discriminatory dissemination of reports to all eligible subscribers simultaneously.
- To treat all clients with utmost honesty, dignity, and integrity without any misleading advertising.
D. Rights of Investors
Clients have the absolute right to have their personal, financial, and contact information safeguarded with strict confidentiality protocols.
Entitled to receive clear, unambiguous communication regarding fees, service scope, analytical methodologies, and performance metrics.
Every client is entitled to non-discriminatory dissemination of research reports and recommendations without preferential latency.
Right to receive comprehensive disclosures regarding RA registration, disciplinary history, material conflicts of interest, and holding positions.
Protected against deceptive marketing, exaggerated profit claims, or misleading promotional claims across all media channels.
Right to receive explicit cautionary notices and risk-reward parameters when dealing with complex instruments such as F&O derivatives.
Right to have grievances acknowledged, investigated, and redressed within statutory timeframes, with recourse to SEBI SCORES 2.0 and SMART ODR.
Right against coercive, unfair, or one-sided contractual terms; right to accessibility support for differently-abled participants.
E. Responsibilities of Investors (Do's & Don'ts)
| What You SHOULD Do (Do's) | What You Should AVOID (Don'ts) |
|---|---|
✓Always deal exclusively with SEBI registered Research Analysts. | ✗Never deal with unregistered telegram tipsters, social media influencers, or unregulated entities. |
✓Verify the SEBI registration certificate and Registration Number (SANDEEP KUMAR PROPRIETOR OF SAANVI RESEARCH: INH000029980) on SEBI’s official portal. | ✗Do not rely on verbal assurances or unverified screenshots claiming registration. |
✓Carefully read all statutory disclosures, rationale, and stop-loss levels in research reports before executing trades. | ✗Do not execute recommendations blindly without understanding underlying capital risks. |
✓Pay subscription fees strictly through authorized banking channels (NEFT/RTGS/UPI/CeFCoM) directly to the registered firm. | ✗Never make cash fee payments, transfers to personal accounts of employees, or unofficial UPI handles. |
✓Maintain full personal control over your trading, demat accounts, and passwords at all times. | ✗Never share your trading terminal login credentials, OTPs, or demat access with anyone, including research staff. |
✓Clarify all doubts, trade horizon, and sizing rules with the research team before entering positions. | ✗Do not expect assured, guaranteed, or fixed returns from the securities market. |
Grievance Redressal Access Note:
In case of any grievance, investors can lodge complaints directly with Saanvi Research at [email protected]. If unresolved within 21 days, escalate to SEBI via SCORES 2.0 (scores.sebi.gov.in) or SMART ODR (smartodr.in).
PMLA (Anti-Money Laundering) Policy
Framed and adopted in strict compliance with the Prevention of Money Laundering Act, 2002 (“PMLA”), SEBI Anti-Money Laundering Master Circulars, and Financial Intelligence Unit-India (FIU-IND) guidelines by SANDEEP KUMAR PROPRIETOR OF SAANVI RESEARCH (SEBI Reg. No. INH000029980).
Policy Formulation & Scope:
This Anti-Money Laundering (“AML”) and Combating Financing of Terrorism (“CFT”) Policy establishes mandatory systems, client due diligence procedures, and transaction monitoring obligations for Saanvi Research to prevent its research operations from being abused for illicit financial flows.
01.Objectives of the PMLA Policy
- To prevent Saanvi Research from being used, intentionally or unintentionally, by criminal syndicates for money laundering or terrorist financing activities.
- To institute clear Client Due Diligence (CDD) and Know Your Customer (KYC) standards prior to onboarding clients.
- To identify, monitor, and report suspicious transactions (STR) directly to FIU-IND.
- To ensure compliance with statutory cash transaction reporting limits (> Rs. 10 Lakhs), alongside an absolute prohibition against accepting cash fees.
- To train employees and raise investor awareness regarding anti-money laundering norms.
02.Client Due Diligence (CDD) Framework
Prior to activating any research service subscription, Saanvi Research executes full CDD verification:
- KYC Verification: Obtaining verified identity proof (PAN card mandatory) and official valid address proof (Aadhaar, Passport, Voter ID) via CKYC/KRA integration.
- Direct Verification: Interacting with the client via registered telephonic or video channels to confirm identity authenticity.
- System Records: Digitally archiving all correspondence, fee receipts, and onboarding agreements in an encrypted audit trail.
03.Policy for Acceptance of Clients
- No Anonymous or Fictitious Accounts: Under no circumstances will services be rendered under fictitious names or anonymous accounts.
- Cash Fee Prohibition: Under no circumstances are fee payments accepted in cash. All subscriptions must originate from authorized banking channels (NEFT/RTGS/UPI/Net Banking).
- Non-Cooperation Rejection: Accounts will be immediately declined where the prospective client fails or refuses to provide complete KYC information.
- UNSCR Sanctions Screening: The applicant's identity is screened against United Nations Security Council Resolutions (UNSCR 1267) lists and domestic ban lists before account activation.
- Risk Categorization: Clients are classified into Low, Medium, or High Risk based on geographic origin, turnover scale, and professional occupation.
04.Identification & Reporting of Suspicious Transactions (STR)
Saanvi Research maintains systems to recognize suspicious patterns, including:
- Clients uncooperative with identity verification or attempting to conceal beneficial ownership.
- Unusual source of funds disproportionate to the client's declared financial standing.
- Transfers originating from high-risk offshore jurisdictions without clear economic rationale.
- Attempted routing of subscription fees through unrelated third-party bank accounts.
- Transactions abruptly abandoned or aborted when KYC or identity queries are initiated. (All aborted suspicious transactions are documented and reported as STR).
05.Monitoring of Transactions
- Special scrutiny of unusually large fee payments or complex settlement patterns.
- Threshold limits defined for each class of client; any exceeding payments undergo manual compliance review.
- All cash transactions over Rs. 10,000,000 (or equivalent foreign currency) or series of connected cash transactions within 30 days are statutorily flagged.
- Periodic reviews to verify existing client databases against updated UN sanctions lists.
06 & 07.Record Keeping & Five-Year Retention Mandate
In compliance with SEBI Regulations and Rule 3 of PML Rules, all records of client identity, transaction trail, fee invoices, bank account origins, and suspicious transaction filings are preserved securely for a minimum period of five (5) years from the date of the transaction or termination of the business relationship.
08.Statutory Reporting to Financial Intelligence Unit-India (FIU-IND)
In terms of the PML Rules, all suspicious transactions are directly submitted to the Director, FIU-IND:
The Director, Financial Intelligence Unit-India (FIU-IND)
6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110021
Portal: fiuindia.gov.in
09, 10 & 11.Principal Officer & Designated Director Particulars
To ensure complete compliance and direct reporting to authorities, the designated officers act as the central reference points:
Email: [email protected]
Telephone: +91 7566369126 / 0731-4001510 / 4001510
SEBI Reg. No.: INH000029980
Validity: Sep 07, 2026 – Perpetual
12 & 13.Staff Training, Investor Education & Policy Review
- Screening Procedures: Comprehensive background checks and qualification verifications are conducted when hiring research analysts and operations staff.
- Ongoing AML Training: All analytical and support personnel undergo periodic refresher training on AML/CFT typologies and red flag identification.
- Annual Policy Review: This PMLA Policy is reviewed annually or whenever SEBI/FIU-IND updates regulatory circulars, ensuring continuous regulatory alignment.
Investment in securities market are subject to market risks. Read all the related documents carefully before investing. Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Past performance is not indicative of future results.