What are the Surveillance Action & Resolution on various abnormal trading / uncommon activity observed?

Sr. No.

Surveillance Observation

Surveillance Action

Due Diligence Required

1

ü Concentration based trading

ü Matching

ü Exchange Alert

ü Exchange Inquiry

ü Circular Trading

ü Price Rigging

ü Irrational Option Trading

ü Volume swing

Any of the below action:-

(i) Restrict client from further trading

(ii)  Block Scrip limit

(iii) Stop Additional limit

(iv) Block DP rights

(v) Allow only Square off

(vi) Impose charges

(vii) Reduce limit from normal to 1time

(i) Submit the undertaking duly signed by client.

(ii) Update the Financial Information Periodically

(iii) Update the latest contact details like address, telephone no., mobile no., email id, Bank details, DEMAT account details, etc...    

(iv) Submit documentary evidence such as latest bank statement / demat transaction statement / Net worth Certificate duly signed by chartered accountant or any other documents to satisfy itself.

(v)Check SOS AML s/w, for more details on Surveillance alert and reply from there.

2

Client Code Modification

Modification Rights disabled on terminal

Provide details of trade change to surveillance Team in prescribed format, Surveillance team will allow trade change rights only if it is keeping in line with SEBI guidelines.

3

DP Surveillance

(i) Block selling limit of shares received from third party

(ii) Impose 100% margin on such stock.

(iii) Impose Charges

Avoid Off market transactions.

4

Surveillance teams calls the clients on random basis & take confirmation of their awareness of the transaction executed in their A/c.

Sr. no.

Status of Call

Action by Surveillance

Required Due Diligence from BA

(i)

Aware

All the calls have been done from recorded line and will be stored as per Company policy.

No Action

(ii)

Not Aware

1. Suspension of client at EOD of Day 1.

2. Penalty will be imposing to BA / Dealer as per policy.

BA to submit Ledger confirmation, DP Transaction statement and Client withdrawal letter duly signed by client at earliest  only through BizOps -> Sites ->  Surveillance Reporting System, till then client’s suspension will not be revoked.

(iii)

Language

Problem

Surveillance Team will arrange a call to avoid such problem

BA to submit Ledger confirmation duly signed by client at earliest only through  BizOps -> Sites ->  Surveillance Reporting System.

(iv)

Not

Contactable and Call Back

1. Executive sends SMS to clients stating that you will receive a call from 022-39982545, kindly attend.

2. Executive tries for three attempts on same day and two attempts in next 5 days.

3. Send SMS to not contactable client on day 1.

4. Send Email to respective Branch / Franchisee owner thrice to make the client contactable

5. Allow only Square off Transactions from next Friday after day 11.

6. Normal trading rights will be restored only after confirmation is received from the client.

7. A physical copy of the ledger will be dispatched at the end of month.

I) Ask clients to call MOSL Surveillance Team on phone number 022-39982560, from their registered telephone / mobile number between 09.30 am to 5 pm during weekdays (Monday to Friday).

OR

II) Provide us the ledger (All segment) & DP Transaction statement of last 6 months, duly signed by the client(s) and upload these documents through BizOps -> Sites -> Surveillance Reporting System. Also hard copy of the said documents shall be sent to HO. (Said documents submitted through query@motilaloswal.com or surveillance@motilaloswal.com will not be considered.)

OR

III) Ask client to send Email Confirmation on MOSL Email ID surveillance@motilaloswal.com from his registered email id stating that he is fully aware about transactions done in his A/c along with ledger statement (All segment) and DP Transaction Statement of Last 6 months duly signed by client.

OR

IV) Please get the alternate mobile number updated in BIZ OPS through modification process if client contact details have changed due any reason e.g shifted to different state/country and update us about the same, so that we can reach the client(s) and obtain confirmation of the trade executed in his/their A/c.

(v)

Aware but Ledger confirmation Required

1. Client is aware but account verification is not provided by client then sends the Email to respective Branch / Franchisee owner twice to submit the ledger & DP statement of last 6 months.

2. If documents are not submitted by day 7 then we will allow only time limit from next Friday after day 8.

3. Normal trading rights will be restored only after ledger confirmation is received from the client.

Submit the ledger (All segment) & DP Transaction statement of last 6 months, duly signed by the client(s) only through BizOps -> Sites -> Surveillance Reporting System.

(vi)

Authorization Letter Required

1. Clients account is not being handled by client but handled by client’s family member (i.e. Father, mother, sister, brother, daughter, son) then Surveillance team send Email to respective Branch / Franchisee owner thrice to avail authority letter from client.

2. If the same is not received by day 10, then we will allow only One time limit to clients from next Friday after day 11.

3. Normal trading rights will be restored only after authority letter is received from the client.

Submit the Authorization letter duly signed by the client as well as authorized person along with PAN card copy of the Authorized person  through BizOps->Sites->Surveillance Reporting System.