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Segregated Nominee Account FAQ
The SNAS is a structure which offers ease of market access for foreign investors in IFSC wherein orders of foreign investors may be routed through an eligible Segregated Nominee Account Provider (Provider) for trading on the INDIA INX with due adherence to regulatory requirements.
The following can register as a Provider offering SNAS services:
  • SEBI registered brokers in the International Financial Services Centre (IFSC) at GIFT City
  • SEBI registered Foreign Portfolio Investors (FPIs) under Category I and II as per SEBI (FPI) Regulations, 2019 and as per amendments thereafter
  • Trading / Clearing members of international Stock Exchanges / Clearing Corporations that are regulated by a member of Financial Action Task Force (FATF). Such entities shall be eligible to register as a Provider subject to successful completion of a due diligence / KYC verification and validation performed by a SEBI registered intermediary operating in the IFSC or by a bank which is permitted by RBI to operate in IFSC.
Yes. Entities need to be registered with INDIA INX as Providers to offer SNAS services.
Entities applying to register as a Provider at INDIA INX should have a minimum net worth of USD 500,000. The applicant should submit a Net-worth Certificate duly certified by a Chartered Accountant or Certified Public Accountant (or equivalent) or a Company Secretary in their home jurisdiction or in India along with their application.
Yes. At the time of registration, the entity is required to give a declaration to furnish information relating to the end-Clients of Provider, as and when sought by the Exchange, Clearing Corporation or by any regulatory authority.

Providers and Trading / Clearing Members shall furnish to the Exchange, inter alia, information relating to KYC and any other details in relation to accounts of their end-Clients, as and when requested.
Applicants wanting to register with the Exchange as Providers are required to submit the duly completed Application Form and supporting documents as per Annexure 1 of INDIA INX Circular ref no. 20180611-1. The Exchange reserves the right to request for further information regarding the Applicant for the purpose of KYC / AML related due diligence.
Yes. The Exchange, post completion of provider registration process, assigns a unique identifier called the Provider Code or PCODE to the applicant, post which it can then act as a Segregated Nominee Account Provider.
Yes. After the PCODE is issued by the Exchange, a Provider who is not a trading member of an Exchange in the GIFT IFSC, can register with one or more Trading Members for opening Trading Account(s) after completing the due account opening procedure prescribed by the Exchange for each of his accounts.
Only foreign clients can be on-boarded by the Providers.
Providers are required to ensure appropriate due diligence of end-Clients as per global standards including KYC and AML compliance before on-boarding Clients for offering SNAS services.

Providers shall ensure adherence to the provisions of the Prevention of Money Laundering Act, 2002 (PMLA) and the rules thereof, including those relating to capturing the KYC information for sharing with the Central KYC Registry (CKYCR) to the extent applicable to FPIs for their end-Clients
Yes. There needs to be a clearly defined bilateral agreement in writing between the Provider and the end-Client. It should contain all relevant commercial terms pertaining to the conduct of trading, margins, settlements, reporting etc. The Exchange reserves the right to access / verify / validate the terms of such agreements.
The details of the end-Client shall be disclosed to the Exchange / Clearing Corporation and may not be disclosed to Trading / Clearing Members. The Provider shall also be required to disclose such information to SEBI and any relevant authority if required by them.
Providers are required to furnish to SEBI, inter alia, information relating to trades on stock Exchanges in IFSC originated by them, including KYC details of their end-Clients, as and when requested.

Providers shall ensure that the provisions of Prevention of Money Laundering Act, 2002 (PMLA) and the rules thereof, including those relating to capturing the KYC information for sharing with the Central KYC Registry (CKYCR) to the extent applicable to FPIs, are adhered to by ‘Providers’ for their end-Clients.
Providers registered with INDIA INX shall request for a CLCode for each of their end-Clients by submitting the duly completed Application Form and supporting documents as per Annexure 1 of INDIA ICC Circular ref no. 20180611-2.
No. An end-Client can open a Segregated Nominee Account (SNA) with only one Provider. This ensures that the trades of an end-Client are cleared and settled only through one clearing member.
Submission of the Legal Entity Identifier (LEI) code is mandatory at the time of applying for onboarding an end-Client. Basis the LEI the Clearing Corporation, which does the end-Client registration further to an application by the Provider, can do a de-duplication check to ascertain that the applicant end-Client has not opened a SNA with any other Provider.
Yes. Upon registration of each end-Client by the clearing corporation, each end-Client is assigned a Unique Client Identifier (CLCODE), which will be unique across all end-Clients of all Providers in the IFSC. The SNA related end-Client information along with the CLCODE is shared by the Clearing Corporation with the Exchange.
Yes. The CLCODE is to be mandatorily entered in the client code field at the time of order entry by the Provider/Trading Member.
The end-Client can execute his transactions through the Provider, in case the Provider is a Trading Member of the Exchange, or through any other Trading Member with whom the Provider has a Member-Client relationship.
Trading Members are required to issue the contract note to the Provider giving details of the CLCODE in the same. This enables the Provider to track end-Client level details.
Yes. A CLCODE can be deactivated and modifications in the end-Client details be carried out, subject to verification by INDIA ICC, upon providing the required details as per Application Form and supporting documents as per Annexure 1 of INDIA ICC Circular ref no. 20180611-2
Yes. A Provider can seek services from more than one Clearing Member.
No. An end-Client is required to clear and settle his transactions through any one Clearing Member of INDIA ICC with whom the Provider has a Member Client agreement.
Yes. Each Clearing Member associated with a Provider is required to submit an undertaking as per Annexure-2 of INDIA ICC Circular ref no. 20180611-2.
The Clearing Members are required to ensure the following for the CLCODEs serviced by them:
  • Confirm trades entered for the CLCODEs using the confirmation facility as provided by Exchange/Clearing Corporation to clearing members from time to time.
  • All trades confirmed by Clearing Members shall form part of the obligations of Clearing Member and he shall be responsible for all obligations arising out of such trades.
  • Trades that are not confirmed by the Clearing Member (Unconfirmed trades) shall be considered as trades pertaining to the Trading Member executing such trades and shall form a part of the obligations of the Clearing Member who clears and settles trades for such Trading Member.
Margin computing and reporting in the SNA structure is done as follows:
  • Margins shall be computed at the end-Client level of the Provider
  • Margins shall be grossed up at and collected from Provider. The Clearing Member shall be required to collect all applicable margins from Provider
  • Margin reporting shall be done by the Clearing Member at the level of the Provider
  • Short / non-reporting of Client margin by clearing members shall be considered as violation and will attract relevant penal actions.
  • Margins will be levied on the Clearing Member of the Trading Member, who has executed trades using the CLCODE of the end-Client of the Provider till it has not been confirmed by the Clearing Member mapped to the CLCODE.
Yes. Margin is payable by the end-Client to the Provider.
Yes. However, the margins may be funded by the Provider subject to there being a clearly defined bilateral agreement between Provider and the end-Client listing the same.
The position limits are monitored at end-Client level by the clearing corporation.
The position limits applicable as per relevant Exchange/Clearing Corporation circulars will be applicable for the clients of the Provider.
The Files being currently generated for TMs / CMs would also have the records of end-Clients. Thus, the respective designated TM and the CM would be able to check the end-Client level details in these files.

The end-of-session Margin Report for Clearing Members will contain the margin of end-Clients of each Provider which shall be grossed up at Provider level. Other end-of-session reports for Clearing Members such as Trade Report, Position file, margin file etc. shall contain information at the CLCODE level
The relevant SEBI circulars are as below:

  • SEBI/HO/MRD/DRMNP/CIR/P/2018/83, dated May 24, 2018
  • SEBI/HO/CIR/P/2017/79, dated July 11, 2017
  • IMD/HO/FPIC/CIR/P/2017/003, dated Jan 04, 2017


The relevant INDIA INX circulars are as below:

  • Circular ref. no. 20200512-01, dated May 12, 2020
  • Circular ref. no. 20180611-01, dated Jun 11, 2018
  • Circular ref. no. 20180524-02, dated May 24, 2018


The relevant INDIA ICC circulars are as below:

  • Circular ref. no. 20180611-02, dated June 11, 2018
  • Circular ref. no. 20180524-01, dated May 24, 2018