Internal Control Policy

Introduction

Blue Ocean Multi Client Family Office LLP (hereinafter referred to as the “Company”), an AMFI Registered Mutual Fund Distributor, has adopted various internal control measures and compliance procedures in accordance with applicable laws, regulations, and guidelines issued by SEBI, AMFI, and other regulatory authorities.

Client Registration

This is the first stage of interaction with the client. It is crucial to obtain adequate and accurate details to maintain proper records.

Whenever clients are onboarded for mutual fund distribution services via offline or online mode (with or without reference), the following measures shall be taken:

  • The Company registers clients by obtaining the Client Registration Forms as required under AMFI and applicable regulatory guidelines.
  • Basic client details shall be obtained, including:
    • Name of client
    • PAN verification as per SEBI guidelines
    • KYC completion for individual and non-individual clients as per SEBI/AMFI norms
    • For non-individual clients, necessary documents such as board resolution, memorandum & articles of association, shareholding pattern, and authorised signatory details shall be obtained
    • Bank details shall be verified through acceptable proof to ensure only registered accounts are used

Risk Disclosure Document

Mutual fund investments are subject to market risks. Clients must be informed of these risks. The Company will issue the Risk Disclosure Document (RDD) to all clients and obtain their acknowledgment.

Client Due Diligence

The Company shall apply appropriate Client Due Diligence measures as prescribed under KYC norms and its AML policy in compliance with PMLA regulations.

Financial Details of Client

The Company obtains financial details from clients as a self-declaration of their annual income/net worth. For non-individual clients, these must be supported by financial statements of the last two years.

Updating Client Financial Details

Annually, clients will be provided an option to update their financial information. Upon receipt, the Company shall update its records.

Unique Email ID and Mobile Number

To ensure secure access and communication: - Clients must provide a unique email ID. - Clients must provide a unique mobile number. Under exceptional circumstances and regulatory norms, the same mobile number/email ID may be used for members of the same family.

Record Keeping and Retrieval of Documents

Physical documents, once verified, will be stored securely. Online onboarding documents will be preserved electronically as per SEBI/AMFI guidelines. Record retention shall follow regulatory requirements.

Client Master Modification

Clients requesting changes in their registered details must submit a request form along with supporting documents. Updates shall also be reflected in KRA and CKYCR systems.

Risk Management System

The Company shall follow appropriate internal controls while executing mutual fund transactions, ensuring adherence to regulatory guidelines, client consent, and proper authorisation.

Investor Redressal Mechanism

The Company has a dedicated Customer Care department supervised by a Customer Care Head. Complaints will be resolved within internal TAT and SEBI/AMFI guidelines.

Surveillance Alerts System

The Company shall maintain an effective surveillance mechanism as per SEBI, AMFI, and other regulatory guidelines to identify suspicious activities. Alerts shall be reviewed, analyzed, and reported as required.

Review of Policy

This Policy shall be reviewed annually or as deemed necessary.

BY MANAGEMENT ORDER

Blue Ocean Multi Client Family Office LLP
AMFI Registered Mutual Fund Distributor