Client Account Review Program

### Client Account Review Program

At Urjadata Solar Renewable Energy Pvt Ltd, we understand the importance of maintaining transparency, security, and compliance in all our financial dealings. To ensure that our operations align with international standards and regulatory requirements, we have developed a comprehensive Client Account Review Program. This program is designed to periodically review client accounts for large or unusual transactions, helping us identify and mitigate potential risks.

#### Key Components of Our Client Account Review Program:

**1. Comprehensive Policies and Procedures:**
We have established detailed policies and procedures to guide the review of client accounts. These guidelines ensure consistency, transparency, and compliance with regulatory standards. Our policies are regularly updated to reflect changes in regulatory requirements and industry best practices.

**2. Periodic Account Reviews:**
Our program includes a systematic process for periodically reviewing all client accounts. These reviews are conducted at regular intervals to identify large or unusual transactions that may indicate potential risks or suspicious activities.

**3. Manual and Automated Processes:**
We leverage both manual and automated processes to conduct account reviews. Our advanced automated systems use sophisticated algorithms to flag transactions that deviate from established norms, while our trained compliance team performs detailed manual reviews to ensure accuracy and thoroughness.

**4. Risk-Based Approach:**
Our review process is tailored to the risk profile of each client. High-risk accounts and transactions receive enhanced scrutiny, while lower-risk accounts are monitored according to standard procedures. This risk-based approach ensures efficient allocation of resources and effective risk management.

**5. Large Transaction Monitoring:**
We specifically monitor accounts for large transactions that exceed predefined thresholds. These transactions are flagged for further review to determine their legitimacy and to identify any potential money laundering or financial crime risks.

**6. Unusual Transaction Detection:**
Our systems and procedures are designed to detect unusual transaction patterns, such as sudden increases in transaction volume, atypical transaction types, or transactions involving high-risk jurisdictions. Identified anomalies are escalated for further investigation.

**7. Enhanced Due Diligence (EDD):**
For accounts that exhibit large or unusual transactions, we perform enhanced due diligence (EDD). This process involves gathering additional information, verifying the source of funds, and seeking explanations from the client to ensure the legitimacy of the activities.

**8. Documentation and Record Keeping:**
We maintain comprehensive records of all account reviews, including documentation of identified transactions, investigation outcomes, and any actions taken. Our meticulous record-keeping practices provide a clear audit trail and support regulatory compliance.

**9. Continuous Monitoring and Improvement:**
Our Client Account Review Program is dynamic and continuously evolves to address emerging risks and regulatory changes. We regularly review and refine our processes to enhance their effectiveness and ensure they remain aligned with best practices.

**10. Client Communication:**
We believe in maintaining open communication with our clients. If a review identifies the need for additional information or clarification, we engage with the client to address any concerns and ensure mutual understanding.

#### Commitment to Integrity and Compliance

Urjadata Solar Renewable Energy Pvt Ltd is dedicated to upholding the highest standards of integrity, security, and compliance. Our Client Account Review Program plays a critical role in safeguarding our clients and our business from financial crimes and ensuring adherence to regulatory requirements.

For more information about our policies and procedures, please contact our Compliance Team at [contact email or phone number].

Manish Patel – Founder and CMD
Urjadata Solar Renewable Energy Pvt Ltd (A GoI Recognized Startup DIPP98030)
Foodgod Farmer Producer Company Limited (A GoI Recognized Startup DIPP105083)
President – Kusum Kisan Urja Surksha Samiti (Reg No. 06/09/08/14238/22)
DGCA Certified Remote Pilot
DRP (District Resource Person) – MOFPI, PMFME Scheme
Retd. G.M. John Deere U.S.A.
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