Anti-Money Laundering
Policy

1. Purpose & Scope

Executive Chandigarh is a private residential enclave developed by SN Silos Pvt Ltd and marketed by Brillwood Capital Advisory. As a reporting entity under the Prevention of Money Laundering Act, 2002 (PMLA) and the Rules thereunder, and as a registered project under the Real Estate (Regulation and Development) Act, 2016 (RERA), we are obligated to establish, maintain, and enforce a comprehensive AML/CFT (Counter Financing of Terrorism) compliance programme.

This Policy applies to all prospective purchasers, intermediaries, and representatives engaged in any transaction relating to the acquisition of an estate within Executive Chandigarh.

2. Customer Due Diligence (CDD)

Prior to entering into any agreement for sale or accepting any payment, we conduct mandatory Know Your Customer (KYC) verification of all purchasers and beneficial owners. The following documentation is required:

3. Source of Funds & Wealth

All purchasers are required to provide satisfactory evidence of the source of funds used for the acquisition and, where relevant, source of wealth. Acceptable evidence includes:

• chevron_rightAudited financial statements for the preceding two financial years (for business owners and HNIs)
• chevron_rightIncome Tax Returns (ITR) for the preceding three assessment years
• chevron_rightSalary slips, ESOP documentation, or proof of inheritance / gift
• chevron_rightBank statements for the preceding six months evidencing accumulation of purchase funds
• chevron_rightFor NRI/OCI purchasers: FEMA compliance declaration and proof of remittance through approved banking channels

Cash payments of any amount are not accepted. All consideration must be paid by account-payee cheque, demand draft, or bank transfer from a bank account held in the purchaser's name.

4. Politically Exposed Persons (PEP) & Sanctions Screening

All prospective purchasers and their beneficial owners are screened against international and domestic PEP databases and sanctions lists, including:

• chevron_rightOFAC Specially Designated Nationals (SDN) list
• chevron_rightUN Security Council Consolidated Sanctions List
• chevron_rightEU Consolidated List of Persons, Groups and Entities
• chevron_rightMinistry of Home Affairs (India) designated terrorist organisations

PEP purchasers are subject to Enhanced Due Diligence (EDD), including senior management approval and enhanced ongoing monitoring. We reserve the right to decline any transaction where satisfactory EDD cannot be completed.

5. Suspicious Transaction Reporting

In accordance with Section 12 of PMLA, 2002, we are required to report Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) to the Financial Intelligence Unit — India (FIU-IND). Our Principal Officer designated for this purpose is the Compliance Head of SN Silos Pvt Ltd. Tipping off a subject of a suspicious transaction report is a criminal offence under PMLA.

6. Record Keeping

All KYC documents, transaction records, and due diligence files are retained for a minimum of five years from the date of the transaction or the cessation of the business relationship, whichever is later, in accordance with Rule 10 of the Prevention of Money Laundering (Maintenance of Records) Rules, 2005.

7. Contact — Compliance Officer

For compliance-related queries, please contact: