1. OBJECTIVES

The Surveillance policy has been framed by the Company on recommendation of CDSL (CDSL/OPS/DP/SYSTM/2021/309) for the following purposes:

• Generation of suitable surveillance alerts which may be guided by indicative
• Review and disposal of transactional alerts provided by
• Disposal of alerts within specified
• Reporting to CDSL and other authorities as applicable, in case of any abnormal
• Documentation of reasons for delay, if any, in disposition of
• Framework of appropriate actions that can be taken by the Participant as per obligations under Prevention of Money Laundering Act (PMLA)
• Record maintenance for the period as stipulated under applicable statutes
• The surveillance policy of the DPs shall be reviewed once in a year
• To comply with applicable laws and regulatory guidelines

1. DEFINITIONS

1. “Customer“ means

• A person who is engaged in a financial transaction or activity with MMFL DP and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting.
• Any other person connected with a financial transaction who can pose significant risk to MMFL.

2. “Senior Management”
   • Senior Management for the purpose of the policy shall constitute Managing Director, Compliance Officer, Chief Information Security Officer, Chief Risk Officer and Head DP Operation.
3. “Obtaining certified copy of Officially Valid Document (OVD)” – Means comparing the copy of OVD with the original and recording the same on the copy by authorized officer of MMFL. Provided that in case of Non-Resident Indians (NRIs) and Persons of Indian Origin (PIOs), as defined in Foreign Exchange Management (Deposit) Regulations, 2016 {FEMA 5(R)}, alternatively, the original certified copy of OVD, certified by any one of the following, may be obtained:

• Authorised officials of overseas branches of Scheduled Commercial Banks registered in India,
• Branches of overseas banks with whom Indian banks have relationships,
• Notary Public abroad,
• Court Magistrate,
• Judge,
• Indian Embassy/Consulate General in the country where the Non-resident customer resides.

Certified OVD shall also contain the customer id number and shall be filed carefully for future verification.

2. KEY ELEMENTS OF THE POLICY 

This policy is applicable to all branches / DP department of MMFL and it is to be read in conjunction with related operational guidelines issued from time to time.

The policy includes the following key elements:

1. Generation of surveillance based on various indicative
2. Review and disposal of transactional
3. Reporting any abnormality to CDSL
4. Quarterly reporting of alerts to
5. Obligation of DP regarding Client Due Diligence
6. Obligations of Compliance Officer and Internal
7. In case of no alerts, filing of “Nil Report” within 15 days after every

Obligation of DP, Compliance Officer and Internal Auditor

DP is required to maintain register (electronic/physical) for recording of all alerts generated.

• While reviewing alerts, DP shall obtain transaction rationale, verify demat statement and also obtain supporting documents as required from the
• After verifying the documentary evidences, DPs will record its observations for such identified transactions of its Client.
• With respect to the transactional alerts provided by Depository, DP shall ensure that all alerts are reviewed, and status thereof (Verified & Closed / Verified & Reported to Depository) including action taken is updated within 30
• With respect to the alerts generated at the DP end, DP shall report instances with adverse observation, along with details of action taken, to CDSL within 7 days of the date of identification of adverse observation.

The surveillance activities of DP shall be conducted under overall supervision of its Compliance Officer.

• A quarterly MIS shall be put up to the Board on the number of alerts pending at the beginning of the quarter, generated during the quarter, processed and acted upon during the quarter and cases pending at the end of the quarter along with reasons for pendency and action plan for Also, the Board shall be apprised of any exception noticed during the disposal of alerts.
• Internal auditor of DP shall review the surveillance policy, its implementation, effectiveness and review the alerts generated during the period of audit. Internal auditor shall record the observations with respect to the same in their
• Internal Auditor shall verify that the quarterly MIS is prepared and placed before the Board of the DP.

ANNEXURE 1

ANNEXURE 2

REPORTING OF ALERTS

• DP alerts to be reported to CDSL within 7 days of
• Transactional [CDSL] alerts shall be reviewed and status to be updated within 30
• Quarterly updating mandatory
• In case of no alert, ‘Nil’ Report to be filed every
• Detailed procedure r.t sharing of alert by CDSL with DP and report submission by DP in this regard will be provided separately.

REGISTER

Electronic / Physical register of alerts to be maintained and should be available for inspection.

Report format of alerts generated by the DP

Report format of alerts generated by CDSL

Details of any major surveillance action taken (other than alerts reported to Depository), if any, during the quarter:

Date: 05-08-2025

Place: Chennai