Continuous Due Diligence
- a. It is the duty of every client manager/client owner to satisfy himself about the soundness and investment objectives of client
- b. Portfolio/Investment size/order sizes are commensurate with annual income disclosed by client
- c. Maintain continuous familiarity and follow up with clients where any inconsistency in the information is provided.
- d. Verify sources of fund disclosed by client.
- e. Every client owner/manager should carry on independent grading of his/her client on periodical basis (12months or 18 months) and intimate compliance department of his finding if there is any adverse change in grading.
Back office members should immediately inform Operations head/Accounts head who in turn will inform Principal Officer about any transaction which is inconsistent with client regular trading or if funds and securities are coming from account other than the account specified by client or if they receive request to transfer fund or security to account other than the designated account. Never make client aware of your suspicion.