Investing with Confidence & Precision

Know Your Customer (KYC) Policy

Every customer — individual or institutional — wishing to open a trading account with IMS must provide the required documents as per our account opening form. No anonymous or fictitious account will be opened under any circumstances.

IMS collects information on the customer's age, gender, occupation, knowledge of markets, investment intent (short-term or long-term), and risk profile. This helps classify the customer as low or high risk from a KYC/CDD perspective:

• Domestic salaried employees → typically Low Risk
• Government employees → Medium-High Risk (potential conflict of interest)
• Foreign organizations / foreign currency sources → High Risk (enhanced monitoring)
• Corporate clients → beneficial ownership and controlling parties must be verified

Physical presence of the account opener is required. For non-resident or overseas customers, verification may be done via NADRA Verisys, reliable third-party, reference of existing customer, or confirmation from another broker.

Customer Due Diligence (CDD)

IMS will not open or maintain any anonymous or fictitious account. CDD measures are applied at the outset of every business relationship, when ML/TF is suspected, or when previously obtained identification data is found to be inadequate.

CDD includes identification and verification of the customer and beneficial owners, understanding the purpose and nature of the business relationship, and ongoing monitoring of accounts to ensure transactions are consistent with the customer's known profile and source of funds.

Politically Exposed Persons (PEPs)

PEPs are individuals entrusted with prominent public functions — heads of state, ministers, senior government/judicial/military officials, executives of state-owned corporations, and important political party officials — including their family members and close associates.

IMS applies Enhanced Due Diligence for all PEP relationships. Senior management approval is required before any business relationship with a PEP is established or continued. IMS considers the following PEP categories:

Suspicious Transaction Reporting (STR / CTR)

IMS maintains a robust process for identifying, escalating and reporting suspicious transactions to the Financial Monitoring Unit (FMU) of Pakistan. STRs are filed within 7 days of CEO approval. IMS reports total STRs to SECP on a bi-annual basis within 7 days of each half-year close.

A Currency Transaction Report (CTR) is filed for any cash-based transaction involving payment, receipt, or transfer of Rs. 2 million and above. Monthly reports are maintained for customers whose net traded amount exceeds:

Governance, Compliance & Internal Audit

The Board of Directors is responsible for oversight and effective implementation of the AML/CFT policy. The Compliance Officer holds a senior management position, reports directly to the Board, and is the focal point for all AML/CFT activities. The Internal Audit department reports directly to the Board and conducts AML/CFT audits on at least a quarterly basis.