### Purpose
The purpose of this document is to outline Urjadata Solar Renewable Energy Pvt Ltd’s Anti-Money Laundering (AML) procedures to ensure compliance with international standards, including those set forth by the Basel Committee on Banking Supervision, the Financial Action Task Force (FATF), and other relevant regulatory bodies.
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### Policy Statement
Urjadata Solar Renewable Energy Pvt Ltd is committed to preventing the misuse of its operations for money laundering or terrorist financing. The company adheres to the highest standards of AML compliance and implements robust measures to detect, prevent, and report suspicious activities.
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### AML Procedures
**1. Customer Due Diligence (CDD):**
– **Identification and Verification:**
– Obtain and verify customer identification information prior to establishing a business relationship.
– For individuals: full name, date of birth, address, and identification number.
– For businesses: entity name, registration number, registered address, and identification of directors and beneficial owners.
– **Risk Assessment:**
– Conduct a risk assessment to determine the level of AML risk associated with each customer.
– Classify customers into different risk categories (low, medium, high) based on factors such as geographic location, nature of business, and transaction patterns.
– **Enhanced Due Diligence (EDD):**
– Apply Enhanced Due Diligence for high-risk customers, including obtaining additional information and conducting more rigorous verification procedures.
**2. Transaction Monitoring:**
– Implement automated systems to monitor transactions for suspicious activity.
– Establish thresholds for transaction amounts and types that require further review.
– Regularly review and update monitoring parameters to reflect changing risk landscapes.
**3. Record Keeping:**
– Maintain records of all customer identification information, transactions, and due diligence measures.
– Ensure records are kept for a minimum period of [X years], as required by law and best practices.
**4. Reporting Suspicious Activity:**
– Establish clear procedures for reporting suspicious activities to the appropriate authorities.
– Ensure that all employees are aware of their obligation to report and the process for doing so.
– Maintain confidentiality and protect the identity of individuals reporting suspicious activities.
**5. Training and Awareness:**
– Provide regular training to all employees on AML laws, regulations, and internal policies.
– Ensure employees understand how to identify and report suspicious activities.
– Update training programs regularly to incorporate changes in laws and emerging risks.
**6. Internal Controls and Audits:**
– Develop and implement internal controls to ensure compliance with AML policies and procedures.
– Conduct regular internal audits to assess the effectiveness of AML controls and identify areas for improvement.
– Report audit findings to senior management and take corrective actions as needed.
**7. Cooperation with Regulatory Authorities:**
– Fully cooperate with regulatory and law enforcement authorities in investigations related to money laundering and terrorist financing.
– Provide timely and accurate information as required by authorities.
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### International Standards Compliance
**1. Basel Committee on Banking Supervision:**
– Adhere to the Basel Committee’s AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) guidelines.
– Implement robust risk management frameworks and internal controls in line with Basel standards.
**2. Financial Action Task Force (FATF):**
– Comply with the FATF Recommendations on AML/CFT.
– Conduct regular self-assessments to ensure adherence to FATF standards and implement necessary changes.
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### Governance
**1. Compliance Officer:**
– Appoint a dedicated Compliance Officer responsible for overseeing the implementation and effectiveness of AML procedures.
– The Compliance Officer will ensure ongoing compliance with regulatory requirements and internal policies.
**2. Senior Management Oversight:**
– Ensure senior management is actively involved in overseeing the AML program.
– Regularly update senior management on AML compliance status, risk assessments, and any significant issues.
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### Enforcement and Disciplinary Actions
**1. Enforcement:**
– Enforce AML policies and procedures across all levels of the organization.
– Conduct regular reviews and updates of policies to reflect changes in regulatory requirements and risk environments.
**2. Disciplinary Actions:**
– Take appropriate disciplinary actions against employees who fail to comply with AML policies and procedures.
– Actions may include termination of employment and reporting to relevant authorities.
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By adhering to these AML procedures, Urjadata Solar Renewable Energy Pvt Ltd aims to uphold the highest standards of integrity and contribute to the global fight against money laundering and terrorist financing.
21 July 2024