Client Acceptance Policy

Flameback Investment Advisors (Flameback), a Unit of Flameback Capital Private Limited (CIN: U65999KA2016PTC096684) is a Registered Investment Advisor (RIA) with Securities Exchange Board of India (SEBI) with Registration No: INA200013798 and BSE Administration & Supervision Ltd Membership ID: 1739

Flameback has a policy for accepting new clients and continuing existing client relationships. This policy is meant to be followed by the employees of the company.

We have two important requirements to accept clients that are central to Client Acceptance Policy (CAP) are:

  1. Accept only those clients whose identity and profile are established by conducting appropriate due diligence to determine risk tolerance, investment objective, preferences and other considerations that are important for recommending investment portfolios and strategies.
  2. Documentation for identification, KYC requirements and anti-money laundering (AML) guidelines are fulfilled.

No transaction or advice will be provided to any client unless the two requirements stated above are met.
If a proposed or existing client denies or does not respond to requests for required or additional information or documents, Flameback will not provide or continue to provide its investment advisory services.

Clients that will be accepted:

  • Indian residents and Non-Residents
  • Individuals, joint accounts, partnership firms, LLPs, Corporate Body, Trusts, Charities and NGOs
  • Clients who provide all the required documents and information to comply with KYC requirements, other statutory requirements, and internal procedures and requirements.
  • In the case of non-individuals, we will require additional documentation on the partners, directors and shareholders including information on the ultimate beneficiary or beneficiaries and financial information.
  • In the case of Politically Exposed Persons (PEP), the Company will identify him/her and confirm the sources of funds and will accept only after additional due diligence.
  • In cases where the employees of the company determine a particular client to be high risk, additional relevant information and documentation will be requested.
  • A client does not have a criminal background relating to serious crimes or financial crimes.
  • A client does not feature on sanctions list or banned from stock exchanges or other regulators and authorities. and barred from investing or engaging in financial transactions.

Clients that will not be accepted:

  • Clients who fail or refuse to submit the required information and documents for clients.
  • A client that has a criminal background relating to serious crimes or financial crimes.
  • A client is listed on sanctions list or banned from stock exchanges or other regulators and authorities. and barred from investing or engaging in financial transactions.
  • Clients from countries that is considered inadequate by FATF and its rules & regulations.
  • Clients where we determine that their nature of business entail a higher risk of money laundering or terrorist financing.
  • Clients where we cannot clearly identify the source of funds.
  • Clients where we identify suspicious transactions.
  • Clients that have not paid any dues charged by Flameback Capital or related parties for it’s services.