Anti-Bribery, Anti-Corruption, and Anti-Money Laundering Policy

1. Introduction: This policy outlines the commitment of Chamber of Prakash K. Pandya (“the Firm”) to ensuring compliance with all applicable anti-bribery, anti-corruption, anti-money laundering laws and regulations, including the Prevention of Money Laundering Act (PMLA) and the mandates of the U.S. Office of Foreign Assets Control (OFAC), to the extent applicable like when foreign entities that conduct business in or with the US, US persons, or utilising the US financial system, US origin goods or services and is also availing our services.

2. Policy Objective: To deter, detect, and prevent bribery, corruption, and money laundering, promoting a culture where illegal or unethical conduct is recognized, reported, and penalized.

3. Scope: This policy applies to all partners, employees, consultants, contractors, and third parties acting on behalf of the Firm.

4. Anti-Bribery and Anti-Corruption:

  • 4.1 The Firm prohibits bribes or other inducements in any form, whether directly or indirectly, to secure any form of advantage, whether commercial, contractual, regulatory, or personal.
  • 4.2 Facilitation payments, being payments to induce officials to perform routine functions they are otherwise obligated to perform, are also prohibited.
  • 4.3 Employees and associates must ensure they have read, understood, and comply with this policy, and attend training as required.

5. Anti-Money Laundering (AML):

  • 5.1 The Firm is committed to ensuring that its operations and business transactions adhere to all relevant legal and internal standards to prevent money laundering and terrorist financing.
  • 5.2 The Firm will ensure robust client due diligence, monitor transactions, and report any suspicious activities in line with the PMLA.

6. Compliance with OFAC:

  • 6.1 The Firm is committed to complying with OFAC regulations and ensuring no transactions are made with sanctioned individuals, entities, or countries.
  • 6.2 The Firm will regularly monitor and screen its clients and transactions against OFAC’s list of sanctioned parties.

7. Reporting:

  • 7.1 All individuals associated with the Firm are required to immediately report any potential or actual violations of this policy to the designated compliance officer.
  • 7.2 Whistleblowers are protected from any retaliation for making a report in good faith.

8. Record-Keeping:

  • 8.1 All financial transactions must be accurately recorded in the Firm’s books and records.
  • 8.2 Any gifts or hospitality given or received must be appropriately documented and approved.

9. Penalties for Non-Compliance:

  • 9.1 Non-compliance with this policy may result in disciplinary action up to and including termination of employment or association.
  • 9.2 The Firm may also report any illegal activities to relevant authorities, which could result in civil or criminal penalties.

10. Review and Amendment:

  • 10.1 This policy will be periodically reviewed to ensure its continued relevance and effectiveness.
  • 10.2 Amendments will be made as necessary in response to feedback, changes in practices, or changes in legal and regulatory requirements.

11. Acceptance and Acknowledgment:

All individuals associated with the Firm are required to read, understand, and acknowledge receipt and understanding of this policy.

Date of Last Update: [17 August 2023]