Investor Info

Risk Profile (High Risk Customers/ Low Risk Customers)
Z.A GHAFFAR Securities (Pvt.) Ltd must perform a risk assessment of all the existing and prospective customers on the basis of information obtained regarding their identity, nature of income, source of funding, location etc and based on the results of such assessment, categorize their customers among high risk, medium risk and low risk customers. Z.A GHAFFAR Securities (Pvt.) Ltd should develop clear guidelines for identification of High Risk customers which include:
i. Non-resident customer
illegal persons or arrangements including non-governmental organizations; (NGOs) / not- for-profit organizations (NPOs) and trusts / charities.
ii. Customers belonging to countries where CDD / KYC and anti-money laundering regulations are lax or if funds originate or go to those countries.
iii. Customers whose business or activities present a higher risk of money laundering such as cash based businesses;
iv. Customers with links to offshore tax havens.
v. there is reason to believe that the customer has been refused brokerage services by another brokerage house;
vi. Non-face-to-face / on-line customers;
vii. Establishing business relationship or transactions with counterparts from or in countries not sufficiently applying FATF recommendations; and
viii. Politically Exposed Persons (PEPs) or customers holding public or high profile positions.
Z.A GHAFFAR Securities (Pvt.) Ltd should conduct a self assessment for money laundering and terrorist financing risk, identifying and documenting the key risks presented to it by virtue of its business model, types of customers and geographical placement
Customers from or in countries where CDD/ KYC and anti-money laundering Regulations are lax and are not sufficiently applying Financial Action Task Force (FATF) recommendations: and
Customers who have been refused by another financial institution (based on Reasonable information)
While dealing with the high-risk customers including the PEPs, Z.A GHAFFAR Securities (Pvt.) Ltd should:
a) Obtain senior management approval for establishing business relationships with such customers. The same shall also apply in case of an existing customer which is classified as High-risk pursuant to these guidelines or which is subsequently classified as a result of ongoing due diligence;
b) Take reasonable measures to establish the source of wealth and source of funds.
If Z.A GHAFFAR Securities (Pvt.) Ltd is unable to comply with the above requirements, it should not open the account, or should terminate the business relationship, as the case may be
For Low Risk Customers, Z.A GHAFFAR Securities (Pvt.) Ltd may apply simplified or reduced CDD/ KYC measures. A client may be considered under Low Risk category, if the identity of the customer(s) and the beneficial owner of a customer are publicly known or where adequate checks and controls exist.
Following cases may be considered as Low Risk Customers for application of simplified or reduced CDD/ KYC;
Financial institutions provided they are subject to requirements to combat money Laundering and terrorist financing and are supervised for compliance with those Requirements; and
Public listed companies that are subject to regulatory disclosure requirements, Government administrations/entities.
TRAINING
There has to be on-going training of brokers, their employees and agents to ensure that they understand their duties under KYC/CDD and are able to perform those duties satisfactorily.
ENHANCED DUE DILIGENCE
Once a customer has been categorized as HIGH RISK, Policies and procedures are in place so that activities and transactions of HIGH RISK Customers are monitored and any unusual transactions are reported In a SUSPICIOUS TRANSACTION REPORT (STR).
ON-GOING DUE DILIGENCE
In order to guard against misuse, of their good offices against criminal transactions, we should keep monitoring transactions of our customers to ensure that the transactions executed in any particular account are within the understanding of the CEO in terms of the customer’s profile, risk category, historical pattern of the transactions and their historic funding source
Data Retention
Z.A GHAFFAR Securities (Pvt.) Ltd shall maintain the relevant documents obtained through the Application of KYC/CDD procedures, especially those pertaining to Identification of the identity of a customer, account files and Correspondence exchanged for a minimum period of five years.
Availability of Reports for Clients
We highly emphasize to make sure that clients are receiving their required reports such as CDC Balance Reports, ledger reports, billing invoice upon their requirement at any time.
Timely submission of Reports etc to the Regulators
Management is very serious in making the submission of all the required reports/statements to the regulators including Net Capital Balance Certificate, Annual and Bi-Annual Accounts, Segregation Reports and quarterly submission of data with SECP and makes all possible efforts to remain 100% compliant in this regard.
Account Opening Form
2.1 Company does not open an account without a formal meeting with the respective client – which ultimately results in full confidence on both the parts.
Without completing all the formalities – no account will never be opened and no staff member is allowed to open the account without having consent of the CEO.
The following documents are required for opening an account:
1 Original NIC copy of the individual and Joint Account Holder.
2 Bank verification from the individual Account.
3 Zakat declaration (optional)
4 NTN Certificate (optional)
5 Nominee CNIC (If applicable)
Government account shall not be opened in the personal names of the Government Official(s);
Order confirmations and Order Taking
Order confirmations are provided through email at the end of the day which includes the total trades executed by the client on a particular day.
Moreover, clients are also informed of their buying/selling orders through verbal communications which is conducted by the respective Traders involved.
COMPLIANCE FUNCTION
Our compliance officer is designated and he have sufficient skills and experience to effectively perform the compliance function.
It is the responsibility of the compliance function to ensure that KYC/CDD guidelines are being complied with as well as with other regulatory requirements. This includes maintaining record of violations/non-compliance identified which has to be reported to the Board of Directors. Any such record has to be available for inspection by SECP and KSE as and when required.
Settlement
Nevertheless, after almost all the securities eligible for CDC, settlement has become very easy. In addition, after make sure to collect the CDC D.O/T.Os in advance from the respective clients, who opt to sell their shares (standing in CDC Investor Account)
Since, the settlement of securities is done automatically in NCCPL; thus, no major work is done by our staff and they rather concentrate on collection and disbursement of funds thereof. In this regard, company keeps a vigilant eye on smooth settlement, which is mutually beneficial for the company and its clients.
Segregation of Clients’ Funds and Securities
As a matter of fact, our company has a very limited business activity and thus faces no problem in segregation, which is monitored regularly and daily basis.
All the cheques to the clients and from the clients are performed through the clients account in which is separate from the house account.
We strongly believe that the securities and funds of the clients in our company are purely “Amanat” and thus it’s the duty of our company to keep them segregated from our own business/property.
The house account is only used for clearing and brokerage expenses.
Third party cheques are discouraged.
Compliance of Rules & Regulations
We believe that all the rules and regulation are indeed beneficial for the improvement and progress of the market and ourselves as well; thus, we concentrate in complying all the rules and regulations of the regulators including KSE & SECP.
In this regard, our compliance officer makes sure to read and keep the records of notices/circulars in this regard and after due discussions with the management, we make it sure to fully comply with.
Screening
Z.A GHAFFAR Securities shall develop and implement appropriate screening via procedures to ensure high standards while hiring staff. However, the screening process must be an on-going exercise and must be applied consistently to ensure that employees, particularly those working at sensitive positions, meet and maintain high standards of integrity and professionalism. Z.A GHAFFAR Securities must provide any information concerning its clients and their transactions to the exchanges, Financial Monitoring Unit or the Commission as and when required.
Others
Z.A GHAFFAR Securities must comply with the requirements of Anti Money Laundering Act, 2010 as applicable on them, including and any directives, circulars, guidelines issued in this regard by Federal Government, Financial Monitoring Unit and SECP.
Company policy
No client is entertained without complete documents provided, plus the NCCPL verifies the NIC and provides an UIN which allows validity of clients.
KYC covers brief information of the clients and is duly filled at the time of account opening form by the compliance officer. It covers the sources of funds and information as outlined by the KSE rule book. Z.A GHAFFAR Securities (Pvt.) Ltd has formulated a Customer Due Diligence/ Know Your Customer policy, referred here as “CDD/ KYC policy”, based on the criteria specified in the Securities & Exchange Commission of Pakistan (SECP).

The policy defines different types of customers, their minimum required information & Documents. It further explains how to ensure the identity of the clients, who initiates relationship with Z.A GHAFFAR Securities (Pvt.) Ltd and how to maintain and update the CDD/KYC measures for existing customers.