At Satin Growth Alternatives Limited (SGAL), integrity forms the bedrock of our operations. We start from first principles: preventing money laundering, terrorist financing, bribery, and illicit funds is non-negotiable to protect legitimate business, stakeholders, and society.
Our zero-tolerance policy stems from core laws like PMLA 2002, Companies Act 2013, BNS 2023, and PCA 1988, ensuring every action upholds fairness and compliance across all dealings. This commitment binds every employee, director, associate, subsidiary, and third party — from vendors to consultants — fostering a culture of accountability at every level.
Core Framework
The CFO, as Compliance Officer, and Senior Directors, as Designated Directors, anchor our AML program. They design, update, and oversee policies; assess risks; train staff; and report directly to FIU-IND.
Know Your Client
We identify clients fundamentally — who they are, who owns them (>25% for companies, >15% for trusts), and their risk profile — using Officially Valid Documents. No anonymous accounts; enhanced checks for PEPs, high-risk jurisdictions, or non-face-to-face dealings. Low-risk gets simplified CDD; high-risk demands deeper scrutiny to match transactions with known profiles.
Vigilant Monitoring
Ongoing due diligence flags complex, large, or purposeless sources. We scrutinize patterns, document findings, and alert without tipping off clients. UN sanctions lists are non-negotiable: no accounts for matches.
Record Integrity
Every transaction (>₹10L cash or suspicious) is preserved for 10+ years — fund flows, owners, purposes — enabling swift audits or probes.
Reporting Backbone
CTR by the 15th of the following month, STR within 7 days, NTR as needed — all submitted to FIU-IND with full confidentiality. This transparency shields SGAL and upholds systemic trust. Annual reviews keep us adaptive and rooted in these principles.
