COMPLIANCE FRAMEWORK

Effective Date: 16 May 2026  |  Last Updated: 16 May 2026

www.25wealthsecrets.com

1. Regulatory Identity and Registration

25Wealth Secrets is a formally registered and regulated financial advisory entity. Our regulatory credentials are as follows:

 

Regulatory Detail	Information
Entity Name	25Wealth Secrets
Type of Entity	SEBI Registered Investment Advisor (RIA)
SEBI Registration Number	INA000XXXXXX
SEBI Registration Date	[Registration Date]
SEBI Registration Valid Until	[Renewal Date]
AMFI ARN Number	ARN-XXXXXX
AMFI Registration Date	[ARN Date]
Compliance Officer	[Name of Compliance Officer]
Principal Officer	[Name of Principal Officer]
Registered Office Address	[Full Address], India
Website	www.25wealthsecrets.com
SEBI Regional Office	[Relevant SEBI Regional Office]

 

Clients and investors may verify our SEBI registration at any time at www.sebi.gov.in → Intermediaries/Market Infrastructure Institutions → Investment Advisers.

 

2. Governing Regulatory Framework

Our operations are governed by the following laws, regulations, and circulars:

2.1 Primary Legislation

•         Securities and Exchange Board of India Act, 1992

•         Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 (as amended)

•         Prevention of Money Laundering Act (PMLA), 2002

•         Foreign Exchange Management Act (FEMA), 1999

•         Income Tax Act, 1961 (as applicable to investment advisory services)

•         Information Technology Act, 2000 and IT (Amendment) Act, 2008

•         Indian Contract Act, 1872 (governing advisory agreements)

2.2 Key SEBI Circulars and Notifications

•         SEBI Circular SEBI/HO/IMD/DF1/CIR/P/2019/169 — KYC Requirements for Investment Advisers

•         SEBI Circular SEBI/HO/IMD/IMD-II/DOF3/P/CIR/2021/573 — Revised IA Regulations Implementation

•         SEBI Master Circular for Investment Advisers — as updated from time to time

•         SEBI Circular on ODR (Online Dispute Resolution) for Investor Grievances

•         SEBI Guidelines on Advertising Code for Investment Advisers

•         SEBI Circular on Cybersecurity and Cyber Resilience Framework

2.3 AMFI Guidelines

•         AMFI Code of Conduct for Intermediaries

•         AMFI Best Practices Guidelines Circular — as applicable to advisory services

•         AMFI Guidelines on KYC for Mutual Fund Investors

 

3. Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy

3.1 KYC Commitment

We are committed to full compliance with KYC requirements as mandated by SEBI, AMFI, and the Prevention of Money Laundering Act. We do not onboard any client — individual or institutional — without completing a mandatory KYC verification process.

3.2 KYC Process

Our KYC process covers the following:

•         Identity Verification: PAN card validation (mandatory), Aadhaar-based e-KYC (where applicable)

•         Address Proof: Government-issued address document verification

•         CKYC Registration: All clients are registered with the Central KYC Registry (CKYCR) maintained by CERSAI

•         Risk Categorisation: Clients are categorised as Low, Medium, or High risk based on their profile, income source, and transaction patterns

•         Periodic Re-KYC: KYC records are reviewed and updated periodically as required by SEBI

•         Enhanced Due Diligence (EDD): Additional verification is conducted for Politically Exposed Persons (PEPs), high-value clients, and NRI clients

3.3 Anti-Money Laundering (AML) Policy

We maintain a robust AML framework in compliance with PMLA, 2002:

•         Suspicious Transaction Reporting: Any transaction or client behaviour flagged as suspicious is reported to the Financial Intelligence Unit (FIU-IND)

•         Cash Transaction Reporting: Cash transactions above ₹10 lakh (or equivalent) are reported as required

•         Client Risk Assessment: All clients undergo AML risk profiling at onboarding and at periodic intervals

•         Staff Training: All advisory and compliance personnel receive mandatory AML training annually

•         Record Keeping: All KYC and AML records are maintained for a minimum of 5 years as required by PMLA

3.4 Politically Exposed Persons (PEPs)

We apply Enhanced Due Diligence (EDD) to all clients identified as Politically Exposed Persons or their close relatives. PEP clients require senior management approval before onboarding and are subject to more frequent account reviews.

 

4. Suitability Assessment and Risk Profiling

4.1 Mandatory Suitability Assessment

In compliance with Regulation 16 of SEBI (Investment Advisers) Regulations, 2013, we conduct a comprehensive suitability assessment for every client before providing any personalised investment advice. No advisory recommendation is made without completing this process.

4.2 Risk Profiling Framework

Our risk profiling assessment covers the following dimensions:

•         Financial Situation: Income, expenses, assets, liabilities, and net worth

•         Investment Objective: Capital preservation, income generation, capital growth, or a combination

•         Investment Horizon: Short-term (under 3 years), medium-term (3–7 years), long-term (7+ years)

•         Risk Tolerance: Ability to withstand market volatility and potential capital loss

•         Risk Capacity: Financial ability to absorb losses without affecting essential financial goals

•         Investment Experience: Prior exposure to equity, debt, and other financial instruments

•         Liquidity Needs: Requirement for accessible funds in case of emergencies

4.3 Risk Categories

Risk Profile	Investment Approach
Conservative	Primarily debt funds, liquid funds, and capital protection instruments. Minimal equity exposure (up to 20%)
Moderately Conservative	Balanced approach with higher debt allocation (60-70%) and limited equity exposure (30-40%)
Moderate	Balanced hybrid approach — roughly equal equity and debt allocation based on goal timeline
Moderately Aggressive	Equity-dominant portfolio (60-70%) with debt as a stability component
Aggressive	High equity allocation (80%+) across large, mid, and small cap funds for long-term wealth creation

 

4.4 Suitability Documentation

For every advisory engagement, we maintain written documentation including:

•         Completed risk profiling questionnaire signed by the client

•         Suitability assessment report — matching client profile to recommended instruments

•         Written rationale for each specific fund or product recommended

•         Client acknowledgement of risks associated with recommended instruments

•         Record of any client instruction to invest contrary to our advisory recommendation

 

5. Fee Structure and Regulatory Compliance

5.1 SEBI-Prescribed Fee Limits

In compliance with SEBI (Investment Advisers) Regulations, 2013, our advisory fees are structured within SEBI-prescribed limits:

Client Category	Maximum Permissible Fee (SEBI Limit)
Individual / HUF (AUM-based)	2.5% per annum of Assets Under Advice
Individual / HUF (Fixed Fee)	₹1,25,000 per annum per family
Non-Individual Clients	As mutually agreed, within SEBI guidelines

 

We operate strictly within SEBI-prescribed fee limits. No fee exceeding these limits has been or will be charged to any retail client. All fees are disclosed in writing in our advisory agreement before engagement.

5.2 Fee Disclosure Requirements

In compliance with Regulation 14 of SEBI (Investment Advisers) Regulations, 2013, we disclose the following before every advisory engagement:

•         The exact fee amount or fee calculation methodology

•         The mode of fee payment (advance, quarterly, annual)

•         Whether the fee is fixed or AUM-linked

•         Any applicable taxes (GST) on advisory fees

•         The refund policy in case of service non-delivery

•         Confirmation that no commissions are earned from product providers

5.3 Separation of Advisory and Distribution

SEBI mandates a strict separation between investment advisory and distribution activities. We confirm:

•         25Wealth Secrets operates exclusively as an Investment Advisor — we do not act as a mutual fund distributor earning trail commissions

•         We do not hold an active AMFI ARN for distribution purposes simultaneously with our SEBI RIA registration (or maintain full compliance with SEBI circular requirements on separation if holding both)

•         No employee, director, or principal officer of 25Wealth Secrets receives distributor commissions in relation to clients advised by us

 

6. Client Advisory Agreement

In compliance with Regulation 19(1)(a) of SEBI (Investment Advisers) Regulations, 2013, we execute a written Advisory Agreement with every client before commencing advisory services.

6.1 Mandatory Elements of Our Advisory Agreement

Our advisory agreement includes all SEBI-mandated clauses:

•         Scope of advisory services to be provided

•         Duration of the advisory agreement and renewal terms

•         Fee structure, payment schedule, and refund policy

•         Risks associated with the investment advisory services

•         Client's right to terminate the agreement with notice

•         Our obligations including suitability assessment and conflict of interest disclosure

•         Grievance redressal mechanism and escalation process

•         Governing law and dispute resolution mechanism

6.2 Agreement Execution

Advisory agreements may be executed:

•         Physically — with wet signatures on printed documents

•         Electronically — via SEBI-compliant e-signature mechanisms under the Information Technology Act, 2000

•         All executed agreements are stored securely for a minimum of 5 years post-termination

 

7. Record Keeping and Documentation

Regulation 19 of SEBI (Investment Advisers) Regulations, 2013 mandates comprehensive record keeping. We maintain the following records for a minimum of 5 years:

7.1 Client Records

•         KYC documents and identity verification records

•         Risk profiling questionnaires and suitability assessment reports

•         Advisory agreements and amendments

•         All investment recommendations made — with rationale and date

•         Client communications — emails, consultation notes, and written correspondence

•         Client complaints and resolution records

•         Fee receipts and payment records

7.2 Business Records

•         Register of all advisory clients (as required by SEBI)

•         Compliance calendar and audit trails

•         Annual compliance reports submitted to SEBI

•         Internal audit reports and management responses

•         Staff training and certification records

•         Register of employee personal investment transactions (conflict of interest monitoring)

7.3 Record Storage and Security

•         All digital records are stored on encrypted, access-controlled cloud infrastructure

•         Physical records are stored in secure, fire-resistant storage facilities

•         Access to client records is restricted to authorised personnel only on a need-to-know basis

•         Records are backed up daily with off-site redundancy

•         Record destruction follows SEBI-mandated timelines and uses secure disposal methods

 

8. Conflict of Interest Policy

8.1 Policy Statement

25Wealth Secrets is committed to identifying, managing, and disclosing all actual and potential conflicts of interest. As a fee-only advisory firm, we have structurally minimised conflicts. However, we acknowledge and disclose residual conflicts in the interest of full transparency.

8.2 Identified Conflicts and Mitigations

Potential Conflict	Our Mitigation
Advisor holds personal investments in recommended funds	Disclosed to clients upon request; personal holdings do not influence recommendations
Fee is linked to AUM (if applicable)	Fee structure disclosed upfront; recommendations are not influenced by AUM growth motive
Referral relationships with execution platforms	Disclosed; platform selection does not influence fund recommendations
Family members' financial interests	Personal trading policy applies to immediate family; disclosures made upon request
Continuing education sponsored by fund houses	Accepted only for educational events; no product-linked incentives accepted

 

8.3 Personal Trading Policy

All principals, directors, and employees of 25Wealth Secrets are subject to our Personal Trading Policy:

•         Pre-clearance required for all personal securities transactions above a defined threshold

•         Blackout periods apply around major client advisory events

•         Front-running client recommendations is strictly prohibited and grounds for immediate termination

•         All personal investment holdings are disclosed to the Compliance Officer annually

 

9. Investor Grievance Redressal Mechanism

We maintain a formal, SEBI-compliant grievance redressal mechanism. All complaints are treated with urgency and resolved in accordance with SEBI timelines.

9.1 Grievance Officer

Detail	Information
Grievance Officer Name	[Name of Grievance Officer]
Designation	Compliance Officer / Grievance Officer
Email	grievance@25wealthsecrets.com
Phone	[Contact Number]
Address	[Registered Office Address]
Working Hours	Monday to Friday, 9:00 AM – 6:00 PM IST

 

9.2 Grievance Resolution Process

Stage	Timeline
Acknowledgement of complaint	Within 48 hours of receipt
Initial response and investigation	Within 10 working days
Final resolution communication	Within 30 calendar days
Escalation to SEBI SCORES (if unresolved)	After 30 days from complaint date

 

9.3 Escalation Channels

•         SEBI SCORES Portal: www.scores.gov.in (for unresolved complaints after 30 days)

•         SEBI Toll-Free Helpline: 1800 22 7575 / 1800 266 7575

•         SEBI ODR Portal: www.smartodr.in (for conciliation and arbitration)

•         SEBI Office of Investor Assistance and Education: www.investor.sebi.gov.in

 

10. Advertising and Marketing Compliance

All marketing, advertising, and promotional content published by 25Wealth Secrets complies with SEBI's Advertising Code for Investment Advisers.

10.1 Our Advertising Standards

•         All advertisements are fair, clear, and not misleading

•         No advertisement guarantees or implies guaranteed returns on investments

•         All performance claims are based on actual, verifiable historical data with appropriate disclosures

•         Standard risk disclosure ('Mutual fund investments are subject to market risks...') is included in all relevant communications

•         SEBI registration number and type of registration are disclosed in all advertisements

•         Testimonials used in marketing comply with SEBI guidelines — no incentivised or fictitious testimonials

•         Social media content complies with SEBI's guidelines on digital and social media communications

10.2 Prohibited Marketing Practices

•         Guaranteeing specific returns, profits, or outperformance vs benchmarks

•         Misleading comparisons with other advisory firms or financial products

•         Using SEBI registration as an implied endorsement of quality or returns

•         Publishing selective performance data without full context and mandatory disclosures

•         Incentivising referrals through cash payments or undisclosed benefits

 

11. Cybersecurity and Data Protection Compliance

In compliance with SEBI's Circular on Cybersecurity and Cyber Resilience Framework and the Information Technology Act, 2000, we maintain a comprehensive cybersecurity policy.

11.1 Technical Safeguards

•         256-bit SSL/TLS encryption for all data in transit

•         AES-256 encryption for all sensitive data at rest

•         Multi-factor authentication (MFA) for all internal systems and client portals

•         Role-based access controls — least privilege principle applied to all data access

•         Regular penetration testing and vulnerability assessments (at least annually)

•         Web Application Firewall (WAF) and DDoS protection

•         Endpoint security and device management for all employee devices

11.2 Data Governance

•         Data minimisation — only necessary client data is collected and retained

•         Defined data retention schedules aligned with SEBI and PMLA requirements

•         Secure data disposal — certified destruction for expired records

•         Vendor security assessments for all third-party data processors

•         Annual data protection audits by qualified information security professionals

11.3 Incident Response

In the event of a cybersecurity incident or data breach:

•         Incident is escalated to the Compliance Officer within 2 hours of detection

•         Affected clients are notified within 72 hours if their data is compromised

•         SEBI and relevant regulatory authorities are notified as required

•         A full incident report and remediation plan is prepared within 7 days

•         Root cause analysis and preventive measures are implemented within 30 days

 

12. Internal Audit and Compliance Monitoring

12.1 Compliance Calendar

We maintain a structured compliance calendar covering all regulatory filing and reporting obligations:

Compliance Activity	Frequency
SEBI Annual Compliance Report submission	Annual (within prescribed deadline)
Client KYC review and update	Annual / as triggered by risk events
Risk profile review for all clients	Annual or upon material life change
Internal compliance audit	Semi-annual
Cybersecurity vulnerability assessment	Annual (minimum)
AML/CFT training for all staff	Annual
SEBI fee compliance review	Quarterly
Grievance register review	Monthly
Personal trading disclosure by staff	Annual
Advisory agreement renewal review	Annual

 

12.2 Internal Audit Framework

Our internal audit programme covers:

•         Suitability: Reviewing that all recommendations are supported by documented suitability assessments

•         Fee Compliance: Verifying that fees charged are within SEBI-prescribed limits and are fully disclosed

•         Record Keeping: Ensuring all mandatory records are complete, accurate, and securely stored

•         Conflict of Interest: Reviewing personal trading disclosures and identifying undisclosed conflicts

•         AML/KYC: Spot-checking KYC completeness and suspicious transaction monitoring

•         Advertising: Reviewing all published marketing content for regulatory compliance

•         Grievance Management: Ensuring all complaints are resolved within SEBI timelines

12.3 External Audit

In addition to internal audit, we engage qualified external auditors to conduct:

•         Annual SEBI compliance certificate (as required for RIA renewal)

•         Annual financial statements audit by a Chartered Accountant

•         Periodic cybersecurity audits by an empanelled information security firm

 

13. Staff Qualification and Compliance Training

13.1 Mandatory Qualifications

All advisory and principal personnel of 25Wealth Secrets hold the following minimum qualifications as required by SEBI:

•         Principal Officer: Post-graduate degree or professional qualification (CA/CFA/CFP/ICWA/MBA Finance) AND NISM Series X-A/X-B certification

•         Individual Investment Advisors: Graduate degree AND NISM Series X-A certification (Investment Adviser Level 1)

•         Additional certifications maintained by our team: CFP (Certified Financial Planner), CFA (CFA Institute)

13.2 Continuing Education

All advisory staff comply with SEBI-mandated continuing professional education requirements:

•         NISM certification renewal within prescribed validity periods

•         Annual compliance training covering SEBI regulation updates

•         Annual AML/CFT training as per PMLA requirements

•         Regular internal knowledge-sharing sessions on market developments, new products, and regulatory changes

13.3 Code of Conduct

All employees and directors of 25Wealth Secrets are bound by our internal Code of Conduct, which covers:

•         Fiduciary duty to act in the client's best interest at all times

•         Prohibition on accepting gifts, hospitality, or incentives from financial product providers

•         Mandatory disclosure of personal financial interests that may conflict with client interests

•         Prohibition on sharing confidential client information outside authorised channels

•         Adherence to SEBI's Code of Conduct for Investment Advisers (Schedule III of IA Regulations)

 

14. Regulatory Change Management

The financial advisory regulatory environment in India evolves continuously. We have a structured process for tracking and implementing regulatory changes:

•         A designated Compliance Officer monitors SEBI, AMFI, RBI, and IRDAI circulars and updates on a weekly basis

•         Material regulatory changes are assessed for impact on our advisory practices within 15 days of notification

•         Clients are informed of regulatory changes that materially affect their investments or our advisory relationship

•         Our advisory processes, agreements, and documentation are updated to reflect new requirements before the regulatory effective date

•         External legal counsel is engaged for complex regulatory interpretation where required

 

25Wealth Secrets is committed to being a proactively compliant firm — not just reactively compliant. We implement regulatory standards in spirit, not just in letter.

 

15. Compliance Contact and Regulatory Filings

Contact / Filing Detail	Information
Compliance Officer	[Name]
Compliance Email	compliance@25wealthsecrets.com
Grievance Email	grievance@25wealthsecrets.com
SEBI Registration Number	INA000XXXXXX
SEBI Regional Office (Jurisdiction)	[Relevant SEBI Regional Office]
AMFI ARN	ARN-XXXXXX
FIU-IND Registration (if applicable)	[FIU Reference Number]
GST Registration Number	[GST Number]

 

For any compliance-related queries, regulatory concerns, or to report a potential compliance violation, please contact our Compliance Officer directly at compliance@25wealthsecrets.com. All reports are treated confidentially.

 

Compliance Commitment

25Wealth Secrets is committed to the highest standards of regulatory compliance, ethical conduct, and client protection. Our compliance framework is reviewed and updated annually, or whenever material regulatory changes require revision. The last full review of this document was conducted on 16 May 2026.

© 2026 25Wealth Secrets. All Rights Reserved.

www.25wealthsecrets.com  |  compliance@25wealthsecrets.com