Policy on Shell Banks
**1. Definition:**
– A shell bank is defined as a bank that does not have a physical presence in any country and is not affiliated with any regulated financial services group that is subject to effective consolidated supervision.
**2. Prohibition:**
– Urjadata Solar Renewable Energy Pvt Ltd strictly prohibits establishing or maintaining relationships with shell banks. This includes, but is not limited to, opening accounts, conducting transactions, or entering into any form of partnership with such entities.
**3. Due Diligence:**
– Prior to engaging in any financial relationship, a thorough due diligence process must be conducted to ensure that the counterpart is not a shell bank. This process includes verifying the physical presence of the bank and confirming its affiliation with a regulated financial services group.
**4. Monitoring and Reporting:**
– Continuous monitoring of existing relationships is required to ensure compliance with this policy. Any suspicion or evidence of a counterpart being a shell bank must be reported immediately to the Compliance Officer and appropriate actions should be taken, including terminating the relationship.
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#### Policy on Foreign Correspondent Banks
**1. Definition:**
– A foreign correspondent bank is a financial institution that provides services on behalf of another bank, typically involving transactions in foreign currencies.
**2. Establishing Relationships:**
– Urjadata Solar Renewable Energy Pvt Ltd may establish relationships with foreign correspondent banks only if they are reputable and subject to effective regulatory oversight in their home countries.
**3. Due Diligence:**
– Comprehensive due diligence must be performed before establishing a relationship with a foreign correspondent bank. This includes:
– Verifying the bank’s regulatory status and supervision.
– Assessing the bank’s Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) policies.
– Reviewing the bank’s financial health and reputation.
– Ensuring the bank does not have relationships with shell banks.
**4. Risk Assessment:**
– Conduct a risk assessment to determine the potential risks associated with the correspondent banking relationship. This includes considering the country of origin, the nature of the services provided, and the volume of transactions.
**5. Ongoing Monitoring:**
– Regular monitoring of the correspondent banking relationships must be conducted to ensure ongoing compliance with all regulatory requirements and company policies. This includes periodic reviews and updates of due diligence information.
**6. Record Keeping:**
– Maintain detailed records of all due diligence, risk assessments, and ongoing monitoring activities related to foreign correspondent banks. These records must be kept up-to-date and readily available for review by regulatory authorities.
**7. Reporting Suspicious Activities:**
– Any suspicious activities or transactions identified in the course of the relationship with foreign correspondent banks must be reported promptly to the Compliance Officer and relevant regulatory authorities in accordance with AML and CTF regulations.
**8. Termination of Relationships:**
– If a foreign correspondent bank fails to meet Urjadata’s compliance standards or is found to be involved in illicit activities, the relationship must be terminated immediately. Appropriate measures must be taken to mitigate any risks arising from such termination.
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#### Enforcement
**1. Training:**
– Regular training programs will be conducted for employees to ensure awareness and understanding of these policies.
**2. Compliance Officer:**
– The Compliance Officer is responsible for overseeing the implementation of these policies, ensuring adherence, and conducting audits to verify compliance.
**3. Disciplinary Actions:**
– Non-compliance with these policies will result in disciplinary actions, which may include termination of employment, depending on the severity of the breach.
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These policies are designed to ensure that Urjadata Solar Renewable Energy Pvt Ltd maintains the highest standards of integrity and compliance in all its financial dealings, thereby safeguarding the company’s reputation and adhering to regulatory requirements.
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21 July 2024
Manish Patel
CMD
Urjadata Solar Renewable Energy Pvt Ltd