This policy establishes the standardized KYC verification and client onboarding procedures followed by Sanwariya Investments Private Limited (ARN-315267), AMFI Registered Mutual Fund Distributor & SIF Distributor, in compliance with SEBI Mutual Fund Regulations, AMFI Code of Conduct, AMFI Master Circular for MFDs dated 14-January-2026, PMLA (Prevention of Money Laundering Act) Rules, and KYC/AML norms.
Client Onboarding Journey – Process Flow
Client approaches through website (www.niveshum.com), Niveshum App (Android/iOS), referral, or walk-in. Distributor introduces self as AMFI Registered Mutual Fund Distributor & SIF Distributor (ARN-315267). Clearly explain: We are NOT an Investment Adviser. All transactions will be in Regular Plan via BSE STAR MF platform. Explain difference between Regular Plan and Direct Plan.
Verify existing KYC status using client’s PAN through KYC Registration Agency (KRA) systems – CAMS KRA, CVL KRA, NDML KRA, or CKYC portal. If KYC is already compliant: Proceed to Step 4. If KYC is not compliant or incomplete: Proceed to Step 3.
Assist client in completing KYC through e-KYC (Aadhaar-based OTP verification) or physical KYC form submission. Collect:
- PAN card copy
- Aadhaar copy
- address proof
- photograph
- bank statement or cancelled cheque
- FATCA/CRS self-declaration
Perform mandatory In-Person Verification (IPV) as per AMFI/KRA guidelines. For non-individual investors: collect UBO (Ultimate Beneficial Owner) details, board resolution, and authorised signatory documents. Ensure compliance with PMLA (Prevention of Money Laundering Act) requirements.
Administer the Risk Profiling Questionnaire covering:
- Age
- income
- financial stability
- investment experience
- investment horizon
- risk tolerance
- financial goals
- existing investments
Assign risk category: Conservative (0-35%), Moderate (36-65%), or Aggressive (66-100%). Document the risk profiling outcome. Obtain client’s written/electronic acknowledgement of their assessed risk category. Map suitable mutual fund scheme categories as per the Fund Selection & Suitability Policy and NFP Suitability Matrix.
Based on assessed risk profile, recommend suitable scheme categories (NOT specific AMCs unless client requests). Provide Scheme Information Document (SID), Key Information Memorandum (KIM), and SAI to the client. Disclose commission/brokerage structure. Explain that investments are in Regular Plan. Obtain investor’s written/electronic consent before executing any transaction.
For Execution Only transactions:
- issue written Unsuitability Communication if scheme does not match risk profile
- Obtain signed Unsuitability Declaration from investor
Create investor account on BSE STAR MF platform with bank mandate registration. Execute first transaction (Lumpsum / SIP / STP / SWP) as per client instruction. Provide transaction confirmation to the investor via email/SMS. Record all details in Redvision backoffice system. Send welcome communication with portfolio access details for Niveshum App / website.
- Periodic risk profile review (at least annually or upon material change)
- Portfolio review and rebalancing recommendations
- Assist with non-financial service requests
- Maintain records for minimum 8 years
- Ensure compliance with AMFI Code of Conduct and SEBI regulations
KYC Document Checklist
| Individual Investors | Non-Individual Investors | NRI Investors |
|---|---|---|
|
PAN Card Aadhaar Card Address Proof Recent Photograph Bank Statement / Cancelled Cheque FATCA/CRS Self-Declaration In-Person Verification (IPV) |
PAN of Entity Certificate of Incorporation / Registration Board Resolution / Authorisation Letter List of Authorised Signatories UBO Details Audited Financials FATCA/CRS Declaration KYC of all Directors |
PAN Card Valid Passport with Visa Overseas Address Proof Indian Address Proof Foreign Bank Account Details Indian NRE/NRO Bank Account Details FATCA/CRS Self-Declaration PIS Permission Letter |
Execution Only Transactions – Special Procedure
- Document the transaction as “Execution Only”
- Send written communication if scheme not suitable
- Obtain written acknowledgement
- Maintain records
Periodic Review Schedule
| Review Activity | Frequency |
|---|---|
| Risk Profile Review | Annually or upon change |
| Portfolio Review | Semi-annually or upon request |
| KYC Update | As per KRA requirements |
| Commission Disclosure Update | Quarterly |
| Fund Selection List Review | Annually |
Sanwariya Investments Private Limited
AMFI Registered Mutual Fund Distributor & SIF Distributor (ARN-315267)
CIN: U64990RJ2024PTC096132
Disclaimers
Mutual fund investments are subject to market risks. Please read the scheme information and other related documents carefully before investing. Past performance is not indicative of future returns. Please consider your specific investment requirements before choosing a fund, or designing a portfolio that suits your needs.
Investments in Specialized Investment Fund involves relatively higher risk including potential loss of capital, liquidity risk and market volatility. Please read all investment strategy related documents carefully before making the investment decision.
The Company receives commission from Asset Management Companies / issuers for distribution of Mutual Fund and SIF products in Regular Plans, as permitted under SEBI and AMFI regulations. Such commissions may include trail or other permitted forms. No commission or fee is charged directly to investors for Mutual Fund or SIF distribution.
Sanwariya Investments Private Limited makes no warranties or representations, express or implied, on products offered through the platform of Sanwariya Investments Private Limited or the Niveshum mobile application. We provide incidental advisory services only. For investment advice, please consult a SEBI-registered Investment Adviser. It accepts no liability for any damages or losses, however caused, in connection with the use of, or on the reliance of its product or related services.
Sanwariya Investments Private Limited operates in compliance with SEBI and AMFI regulations.