Anti Money Laundering & Terrorism Financing (AML & CFT)

Combating Money Laundering & Terrorism Financing has become a global challegein the international Financial System of World Economy. Funds from the illicit drug trade and other crimes are laundered through Banks and Financial Institutions. Criminals are using banking system to disguise the source of funds, Instruments and other valuables illegally earned. It is, therefore, emphasized to combat money laundering and terrorism financing in order to deny safe heaven to drug-dealers, criminals and their ill-gotten resources.

To combat Money Laundering  activities the gobernment of Bangladesh was enacted prevention of Money Laundering Act-2002, on April 07, 2002 which was suspended and updated by Prevention of Money Laundering Act-2012. The government has also enacted new "Anti-Terrorism Act-2012 in response to global AML / CFT regime and standard. 

Bangladesh Bank identified five core risks areas of banking- " Prevention of Money Laundering" is one of them. They prepared guidance note for each of the five core risks and advised to put in place an effective risk management system based on their guidelines in line with the nature, size of the business and organizational structure.

 

Q. 1.   Definition of Money-Laundering  as per MLP act- 2012?.

Answer: Money laundering is the process by which proceeds from a criminal activity are disguised to conceal their illicit origin. It is the criminal practice of processing Ill-gotten or dirty Money through a series of transaction by using Banking channel which turning the dirty money in to clean money.  

Q. 2.   Definition of Financing of terrorism as per AT Act-2013?.

Answer: Financing of Terrorism is the financial support in any form of Terrorism or of those who encourage, plan or engage in Terrorism. Generally Terrorist Financing refers to carrying out of transactions involving funds that are owned by terrorist or that have been or are intended to be, used to assist the commission of Terrorist acts. With the adoption of UN Security Council Resolution (UNSCR) 1267 and 1373, the efforts to combat terrorism was started by the international financial community for deterring, detecting and disrupting terrorism globally. 

or Terrorist Financing refers to the processing of funds to sponsor or facilitate to terrorist activities. 

Q. 3.  What are the background/initiative about Money Laundering Prevention (PLM)?

       a. International  initiatives on AML/CFT:

·         The Globalization of Markets to barrier the organized crime.

·         In 1986, The USA enactment of Money laundering control act 1986.

·         The Vienna Convention, adopted in December 1988 to combat money laundering.

·         In 1989 the G-7 formed FATF (Financial Action Task Force)

·         Basel Committee on banking supervision 1988 formed statement of principles.

·         To combat terrorist financing FATF formed Non-Cooperative Countries and Territories (NCCT) took 15 jurisdictions.

·         International convention for suppression of the financing of terrorism (09 December, 1999 )

·         UNO started transnational organized crime convention in 2000. It also called Palermo Convention.

·          Core principles for effective supervision developed by Bassel Committee in 1997.

·         Formed FIU(Financial intelligence Unit) in 1995.

·         International organization of securities Commissions (IOSCO) formed in October, 1992.

·         13 banks in the world adopted a Wolfberg Anti-Money Laundering Principles in the conference of Switzerland.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      

       b. Bangladesh Initiatives on AML/CFT:

·         Bangladesh is founder of Asia Pacific Group on money laundering in 1997 and implement FATF 49 recommendations and promulgated Money Laundering Prevention Act (MLPA), 2002 which come into force in 30 April, 2002.

·         After 9/11 Bangladesh Government formed a central & regional taskforce on 27 January, 2002.

·         To implement MLPA, Bangladesh Bank established a separate department named Anti-Money Laundering Department(AMLD) in July, 2002

·         Bangladesh issued Guidance notes titled “ Guidance Notes on prevention of Money laundering  in 2003 for banks.

·         On may 16, 2007 FIU was established in BB for analyzing, receiving and disseminating STR and CTR related transactions

·         Self assessment and independent testing procedure system were introduced for banks march 24, 2008.

·         A rigorous Customer due Diligence(CDD) procedure as KYC, TP risk grading etc  

·         To address the short comings of the MLPA 2002 to meet international standard enacted Money laundering prevention Ordinance in 2008 which was replaced by MLPA, 2009.

·         To combat terrorism financing Bangladesh enacted Anti Terrorism Act(ATA), 2009.

·         Bangladesh Financial Intelligence Unit (BFIU) has performed both acts.

·         BFIU has developed National Strategy for Anti Money Laundering and combating financing of terrorism  2011-2013 and the strategy papers contains 12 strategies.

Q. 4.  What are the Stage of Money Laundering?.

There are three stage of Money Laundering. These are below:

Ø  Placement ‑ the physical disposal of the initial proceeds derived from illegal activity.

Ø  Layering ‑ Separating illicit proceeds from their source by creating complex layers of financial transactions 

                      designed to disguise the audit trail and provide anonymity.

Ø  Integration ‑ the provision of apparent legitimacy to wealth derived criminally.  If the layering process has  

                      succeeded, integration schemes place the laundered proceeds back into the economy in such a way     

                      that they re‑enter the financial system appearing as normal business funds.  

Q. 5. What are the reason for Money Laundering?.

Criminals engage in money laundering for three main reasons:

First, money represents the lifeblood of the organization that engages in criminal conduct for financial gain for purchasing the services of corrupt officials to escape detection and further the interests of the illegal enterprise, and pays for an extravagant lifestyle. To spend money in these ways, criminals must make the money they derived illegally appear legitimate.

Second, a trail of money from an offense to criminals can become incriminating evidence. Criminals must hide the source of their wealth or alternatively disguise ownership or control to ensure that illicit proceeds are not used to prosecute them.

Third, the proceeds from crime often become the target of investigation and seizure. To shield ill-gotten gains from suspicion and protect them from seizure, criminals must conceal their existence or, alternatively, make them look legitimate.

Q. 6. What are the Link between Money Laundering and Terrorist Financing?.

Money laundering is the process of concealing the illicit origin of proceeds of crimes. Terrorist financing is the collection or the provision of funds for terrorist purposes. In the case of money laundering, the funds are always of illicit origin, whereas in the case of terrorist financing, funds can stem from both legal and illicit sources. The primary goal of individuals or entities involved in the financing of terrorism is therefore not necessarily to conceal the sources of the money but to conceal both the funding activity and the nature of the funded activity.

Similar methods are used for both money laundering and the financing of terrorism. In both cases, the actor makes an illegitimate use of the financial sector. The techniques used to launder money and to finance terrorist activities/terrorism are very similar and in many instances identical. Although laundering criminal proceeds and financing terrorism may use similar methods, their objectives are completely different- ie Launderers engage in this activities for personal gain or to acquire property etc. On the other hand persons involved in terrorist activities for any political, social change or any ideology. An effective AML/CFT framework must therefore address both risk issues: it must prevent, detect and punish illegal funds entering the financial system and the funding of terrorist individuals, organizations and/or activities.

Q. 7. Why we must combat Money Laundering?

While money laundering and the financing of terrorism can occur in any country, they have particularly significant economic and social consequences for countries because those markets tend to be small and, therefore, more susceptible to disruption from criminal or terrorist influences. Money laundering and terrorist financing also have significant economic and social consequences for countries with fragile financial systems because they too are susceptible to disruption from such influences. Ultimately the economy, society and security of countries used as money laundering or terrorist financing platforms are all imperiled. The magnitude of these adverse consequences is difficult to establish, however, since such adverse impacts cannot be quantified with precision, either in general for the international community, or specifically for individual country.

From the view point of Banking activities prevention of ML & TF has three dimensions-

a.  Ethical - taking part in the prevention of crime.

b. Professional  - ensuring that the Bank is not involved in recycling the proceeds of crime that would call  

  into question its reputation, integrity and if fraud is involved, its solvency.

c.  Legal - complying with laws and Regulations that impose a Series of specific obligations on financial

  institutions and their employees.

Money Laundering & Terrorist Financing shall also be combated for considering the following socioeconomic aspect:

·   Enhanced crime & corruption

·   Loss of revenue

·   International Consequences and Foreign Investment

·   Weakened Financial Institutions

·   Undermining the legitimate private sector

·   Reputation of the institution

·   Weakened Privatization Efforts

·   Social Costs.

Q. 8. Who are the Reporting Organization under AML & CFT?.

Reporting Organization:  All  Bank, Insurance co. , Financial Institute, Business Institute recommended by Bangladesh Bank,  Corporate organization, Superannuation, Stock Dealer & Stock  Broker,  Port folio Manager and Merchant Banker, Security Custodian, Asset Management, Non profit Organization, NGO, Real state Developer, Layer, Notary, Trustee,  Credit Union, Money Lender, Money changer etc.  

Q. 9.  What are the Offence of Money Laundering and punishment?:

a)       Punishment for violation of an order  for  freezing or attachment.

If any person violation of an order for freezing or attachment under section 5, he will be imprisoned  for at least three years maximum or fined for at taka equal of freezing or attachment assets or he will be punished with both.

b)       Punishment for divulging information.

a.        If any person divulging information, he will be imprisoned  for at least two years maximum or fined for at least taka  fifty thousand maximum or he will be punished with both.

b.       Punishment for obstruction or non-cooperation in investigation, failure to submit report or obstruction in the supply of information.

c.        If any person obstruction or non-cooperation in investigation, failure to submit report or obstruction in the supply of information, he will be imprisoned  for at least one year maximum or fined for at least taka  twenty five thousand maximum or he will be punished with both.

              c)        Punishment for providing false information.

a.        If any person provide false  information, he will be imprisoned  for at least three years maximum or fined for at least taka  fifty thousand maximum or he will punished with both.

              d)       Investigation and trial of an offence.

a.        If any person  Investigation and trail of an offence, he will be imprisoned  for 5-14 years  or fined for any amount of taka  or he will punished with both.

Q. 10. Offence of terrorist financing and punishment?.

   a. Terrorist financing offence.

 Offence:- As per section 7 of Anti Terrorism Act 2012 (Amendment) of Government of Bangladesh , The   

 terrorist offence is :

·                   If any person provides or instigate anybody to provide money, service, or any other property to other with  

              intention that they would be used or there are sufficient grounds to believe that they would be used or they can be 

              used in full or in part in order to carry out a terrorist act, he will commit the offence of financing of terrorism.

·      

                   If any person receives money, service or any other properties with intention that they would be used or there are 

             sufficient grounds to believe that they would be used or they can be used in full or in part in order to carry out a  

             terrorist act, he will commit the offence of financing of terrorism.

·        

                   If any person arranges for money, service or any other properties with intention to utilize them or there are            

             sufficient grounds to believe that they would be used or can be used to carry out a terrorist offence of terrorist 

             financing, he will commit the offence of financing of terrorism.

      

     Penalties:-As per Anti Terrorism Act 2012 (Amendment) all terrorist financing offences are cognizable and

     non-bail able. The  offence of Terrorist financing is punishable by terms of a minimum imprisonment for 4 years and 
     maximum 20 years  and its additional punishment is twice the offence asset or 10 lac taka which is higher applicable 
     under section 7.

    In case of any entity its additional punishment is thrice the offence asset or 50 lac taka which is higher applicable and  CEO, Chairman of the entity will be punishable by terms of a minimum imprisonment for 4 years and maximum 20 years and its additional punishment is twice the offence asset or 20 lac taka which is higher applicable under section 18.

    Bangladesh Bank is also empowered to impose maximum fine 25 lac taka on any banks for noncompliance of any   
    instructions/circulars issued by them in pursuant sections 16(3) and also empowered to fine the CEO/ Chairman for 
    Tk. 25.00 Lac  under section 16(4)and cancel the license under section 16(5).

     b. Membership/  Supporter  of band Organization.   

        Membership-If any person Membership of band Organization, he will be imprisoned  for maximum six month  or fined for any amount of  taka  or he will punished with both.

Supporter - If any person supported of band Organization, he will be imprisoned for maximum (Two-seven) years and fined for any amount of taka.

    c. Amendments of Terrorist Financing ACT:- Anti Terrorist Act effected from 11 June, 2008 named Anti 
    terrorism Act, 2009 and its amendment bears 2012 and newly amendment bears in 2013. Anti Terrorism Act, 
    2009and Anti Terrorism (Amendment)-2012 would not cancelled and it bearing some amendment/correction which 
    established Anti Terrorism Financing Act(Amendment)-2013. Anti Terrorism Act 2009 the sub section 2 under 
    section 1 and section 6,7,11,12,15,17,18,20,23 are replaced. And correction/ replacement are also made in section 
    1,2,5,9,10,13,14,16,19,21 etc.  

  

Q. 11. What are the Power and responsibilities of Bangladesh Bank (AML/CFT)? The powers of Bangladesh bank are, in summery

·   To Supervise and monitor the activities of banks, Financial Institutions and other institutions for combating   money laundering & terrorist financing

• To Call for reports relating to money laundering / terrorist financing from banks, Money Changers, Financial Institutions and other institutions engaged in financial activities, analyze such reports maintain those data and take appropriate actions thereof.
• To Provide training to employees of banks, Financial Institutions and other institutions engaged in financial activities on prevention of money laundering / terrorist financing and arrange meeting, seminar for them.
• To Call for any other information or report regarding any transactions deem to be believed that is involved with money laundering /terrorist financing.
• Suspension or stoppage of transaction of any suspected account for thirty days. It can be extended up to 60 days for proper inquiry.
• To create and keep record data –base of Suspicious Transactions
• To inspect activities of the Bank and supervision thereof.
• To assist / inform Law enforcing Agencies in case of Suspicious Transaction for its enquiry /investigation etc.
• Issuance of necessary instructions for combating money laundering& terrorist financing from time to time to the reporting agencies/Banks
• Monitoring the reliability of information or reports submitted by the concerned agencies and on site examination of reporting institutions if required.
• In no cases Law Enforcement Agency is allowed to enter in any File or Document without the consent of CEO of he bank or prior permission of Bangladesh Bank

Q.12. What are the responsibilities of the reporting organization(AML/CFT)?

Ø  To collect and preserve correct and detail Customer information

Ø  To preserve record/information minimum 5 years of all accounts from the date of closing A/c relationship.

Ø  To report STR to Bangladesh Bank at their own initiative without delay.  

Q.13.  What are the Customer  Acceptance Policy?.

              1. Financial Institutions should develop clear customer acceptance policies and procedures:

 In preparing such policies, factors such as customers’ background, country of origin,  public

 or high profile position, linked accounts, business activities or other risk indicators should be considered.

2. Financial Institutions should develop graduated customer acceptance policies and procedures that require more extensive due diligence for higher risk customers. For example, the policies may require the most basic account-opening requirements for a working individual with a small account balance. It is important that the customer acceptance policy is not so restrictive that it results in a denial of access by the general public to banking services, especially for people who are financially or socially disadvantaged. On the other hand, quite extensive due

diligence would be essential for an individual with a high net worth whose source of funds is unclear. Decisions to enter into business relationships with higher risk customers, such as public figures or politically exposed persons , should be taken exclusively at senior management level.

                a. Customer identification & verification.

Customer identification is an essential element of KYC standards. For the purposes of this

Guidance Notes, a customer includes:

                   i.            the person or entity that maintains an account with the bank or those on whose behalf an account is maintained (i.e. beneficial owners);

                 ii.            the beneficiaries of transactions conducted by professional intermediaries; and

                iii.            any person or entity connected with a financial transaction who can pose a significant

                  reputational or other risk to the bank

Q. 14. What is Customer Due Diligence?.

Customer due diligence & KYC is an essential element of the effort to prevent the financial system from being used to commit / perpetrate money laundering and terrorist financing. Banks are ultimately responsible for verifying the identity for their customers. In this regard, Banks must avoid the acceptance of anonymous accounts or accounts in fictitious names. If Banks maintain numbered accounts, they must ensure compliance with the guideline. The customer due diligence undertaken by the Bank shall at least comprise the following:

• Identity and verify the customer.

• Identity and verify beneficial ownership and control of such transaction.

• Obtain information on the purpose and intended nature of the business relationship/transaction and

• Conduct on going due diligence and scrutiny, to ensure the information provided is updated  and relevant.

Q. 15. KYC, Mini KYC, Risk Categorization,  KYE, TP?.

KYC- KYC means Know Your Customer that refers to collect the detail information of customer through interview  with required papers before opening the Account by Account Opening Officer.

Mini KYC-Mini KYC means  Mini Know Your Customer that refers to collect the detail information of customer through interview with required papers before opening the Account(specials scheme, Fixed deposit & other Account)  by Account Opening Officer.  Also  We collect Mini KYC( detail information) from customers for online transaction as per Bangladesh Bank order and for any transaction of CTR amount ( ten lac to above).

Risk Categorization- When opening accounts, the concerned staff/Officer must assess the risk that the accounts could be used for “money laundering”, and must classify the accounts as either High Risk or Low Risk. The risk assessment may be made using the KYC Profile Form given in Annexure D in which following seven risk categories are scored using a scale of 1 to 5 where scale 4-5 denotes High Risk, 3- Medium Risk and 1-2 Low Risk:

·          

                     Occupation or nature of customer’s business.

·                            Net worth / sales turnover of the customer

·                            Mode of opening the account

·                           Expected value of monthly transactions

·                           Expected number of monthly transactions

·                           Expected value of monthly cash transactions

·                           Expected number of monthly cash transactions  .   

KYE-KYE stands for  Know Your Employee  that refers to know the employee and their work environment of the Bank .

TP- TP stands for Transaction Profile that refers to filled up the Transaction profile (amount  of per transaction &  total amount of monthly transaction- cash & transfer)  for create risk level.

Q. 16. Review & update of KYC, TP, Structuring Monitoring?.

KYC- Account transactions to be monitored on regular basis with the declared segregation of risk as per KYC. In line with the monitoring processing process , Bank shall review the KYC at least once in a year on considering the merits of the accounts. Any deviation from the existing KYC, that shall be reviewed with human judgment and interaction with customer . Such reviews may result in changing the existing KYC more than once or as and when needed. This review may also result in closing the customer account.

TP-  Account transactions to be monitored on regular basis with the declared segregation of risk as per TP. In line with the monitoring processing process , Bank shall review the TP on quarterly basis  on considering the merits of the accounts. Any deviation from the existing TP, that shall be reviewed with human judgment and interaction with customer . Such reviews may result in changing the existing TP more than once or as and when needed. This review may also result in closing the customer account.

Structuring monitoring- Account transactions to be monitored on regular basis with the declared segregation of risk as per TP. In line with the monitoring processing process , Bank shall monitoring on daily  basis  on considering the merits of the accounts. If any transaction seems to be suspicious as avoid  CTR transaction limit then it will be carry the structuring  indicator.  Such monitoring  prevention money laundering that occurred terrorist not only our country but also allover the world.

 17. What is CTR Reporting?.

The guided by Bangladesh Bank,  AMLD Circular # 8, Bank will submit daily cash transaction activities in cash mode of all account (except “deposit” in govt. A/c) beyond an upper  threshold  as fixed by them from time to time . Cash remittance or Online deposit in the account will be included in this reporting . So in time cash transaction reporting to be ensured by the branches with proper monitoring of transaction profile and nature of transaction.

Q. 18. What are the Red flag or Indicators of Suspicious Transaction?.

Substantial increases in cash deposit of any individual or business without apparent cause, especially if such deposits are subsequently transferred within a short period out of the account or to a destination not normally associated with the customer.

-Customers who deposit cash by means of numerous credit slip so that the total of each deposit is unremarkable but the total of all the credits is significant.

-The pattern of the transactions conducted by the customer changed.

customer who seek to exchange large quantities of low denomination notes for those of higher denomination

- Customer whose deposits contain counterfeit notes or forged instruments.

- Large cash deposits using ATM facilities, thereby avoiding direct contact with the Bank.

Q. 19. STR Reporting?.

Regularly with proper monitoring of “ Transaction Profile” and nature of transactions. Branch will ensure reporting of suspicious transaction to HO-CAMALCO with their justifications as abnormal transaction in the proper way as an on going process. Tracing out suspicious/abnormal transaction is not a panic for the Bank but a safe guard of bank interest. In this connection our Head Office is working on software base reporting /monitoring system for avoiding manual hazards and which will be communicated well in time.

Q.20.  Self Assessment process and Independent Testing procedures?.

a. Self Assessment process :

Each financial institution should establish an annual self-assessment process that will assess how effectively the financial institution's anti-money laundering procedures enable management to identify areas of risk or to assess the need for additional control mechanisms. So the self-assessment should conclude with a report documenting the work performed, who performed it, how it was controlled and supervised and the resulting findings, conclusions and recommendations. The report should provide conclusions to three key questions:

·                             Are anti-money laundering procedures in place?

·                             Are anti-money laundering procedures being adhered to?

·                             Do anti-money laundering procedures comply with all policies, controls and statutory requirement.

              b. Independent Testing procedures:

Testing is to be conducted at least annually by the financial institution's internal  audit,  personnel, compliance department, and by an outside party such as the institution's external auditors. The tests include:

·                              interviews with employees handling transactions and interviews with their supervisors to determine their        

                      knowledge and compliance with the financial institution's anti-money laundering procedures;

·                             a sampling of large transactions followed by a review of transaction record retention forms and suspicious  

                     transaction referral forms;

·                            a test of the validity and reasonableness of any exemptions granted by the financial institution; and

             A test of the record  keeping system according to the provisions of the Act.

            

            Any deficiencies should be identified and reported to senior management together with a request for a response  

            indicating corrective action taken or to be taken and a deadline.

Q. 21.  What are the responsibilities of other employees of the Bank regarding AML & CFT?.

A brief description of the role and responsibilities of individual officer/executive involved in AML/CFT Program of the Bank is given below:

Officer	Role/Responsibilities
Account Opening Officer/Relationship Manager-	i.    To exercise due diligence in establishing the identity of customer prior to opening an account.         ii.    To collect and ensure correct & complete information.       iii.    To obtain as much information as possible on the customer that might help proper consideration of nature and type of accounts.       iv.    To ensure that all required documentations in respect of account opening are obtained        v.    To ensure that Transaction Profile is obtained and reviewed when transactions are being carried out.       vi.    To report to Branch Manager and concerned higher authority for any suspicious A/C opening, he deems necessary.
Customer Service Officer	i.    To support the Account Officer in respect of the above.         ii.    To perform the job of Account Officer in his absence
Operations Staff/Cash officer	i.    To ensure that all control points are taken into account prior to taking place of any transaction         ii.    To exercise ongoing due diligence in respect of trends of transactions on customers’ account.       iii.    To update customer transaction profiles in the ledger       iv.    To obtain documentary evidence of large cash transactions are being carried out.        v.    To monitor deposit and withdrawal nature of transaction to check the Structuring.       vi.    To observe suspicious movement / attitude of customer in the counter     vii.    To monitor and identify highly transacted account primarily and report thereof to BAMLCO

Q.22. What is Correspondent  Banking?.

Correspondent banking is defined as the provision by one bank (the correspondent) to another bank(the respondent bank) of credit, deposit, collection, clearing, payment or other similar services.

Q. 23. What are Records keeping regarding AML & CFT?.

Record keeping of AML-related Circulars, Guidelines, Documents & Files.

All AML related circulars/ Documents/ Papers/ KYC/TP/ Records of the customer identification and information to be kept in a proper way. All records of closed account/ transaction must be kept at least 5 years after closing the account for the audit trial and requirement of CentralBank or Any other regulatory authorities. Such documents, circulars, and files must be kept in a separate file cabinet. 

Q.24. What is the meaning UN Sanction list / banned list?.

The Sanction List / Banned List are 1. Al-Qaida, 2. Wkipedia, 3. Taleban 4. Haiti ( country ) 5. Harkatul Jihad, JMB, Jagroto Muslim Janata Bangladesh, Shahadat-E- Al Hikma Bangladesh, Hijbut tawhid, Islami Samaj, Ulama Anjuman al Baiyenat, Hijbut Tahrir, Islami Democratic Party, Touhidi  Trust. Tamir Uddin Bangladesh O Allahar Dall.

Q. 25. What isTrade Based Money Laundering?

           a. Inward foreign  remittance.

Remittance of fund of  foreign currency being received from abroad by export goods, labor etc is called inward foreign remittance.

         b. Out ward foreign remittance.  

Remittance of foreign currency being payment to abroad or one country to another country by import goods, labor etc is called outward foreign remittance.

         c. Over Invoicing / Under Invoicing.

Over invoicing :- With a view to transfer foreign in illegal way , The product price is quoted over the international market rate. It also made in import payment.

Under invoicing:- With a view to pay less import duty to the government, the product price is quoted under the international market rate. It also made in trading business as import payment. The rest amount of invoice price is paid through hundy.

Q.26. What is Account Opening  procedure according to Money Laundering Prevention Act?.

1.       Account opening form to be filled up.

2.       All required documents to be collect from the customer.

3.       Fill up KYC portion and transaction profile (TP) in Account Opening Form.

4.       Send thank you letter to customer’s address to verify address.

5.       Open the account in flora bank software.

6.       Cheque book can be issued after address of the customer has been confirmed.

Q. 27. What are the responsibilities of BAMLCO?.

To ensure that the all business activities of the branch are carried out in conformity with AML/CFT Program         and that an effective AML/CFT program is in place in the Branch. 􀂃 To ensure proper Record keeping of all Circulars,/ files documents. 􀂃 To monitor proper KYC procedure in account opening formalities 􀂃 To ensure periodical review of KYC and TP at least once in a year or as and when needed. 􀂃 To monitor and ensure segregation of Risk- based Customer classification –(high risk /highly transacted/ high         balance etc ) 􀂃 To implement effective monitoring process in line with the guideline. 􀂃 To report on suspicious transaction to CAMLCO through Branch Manager 􀂃 To report to CAMLCO on compliance issues and the need for any revisions to policies and procedures. 􀂃 To make officials of Branch aware of AML/CFT program 􀂃 To submit Branch returns to CAMLCO from time to time. 􀂃 To arrange Evaluation meeting on AML/CFT activities keeping minutes properly. 􀂃 To ensure judicious reporting of Self- Assessment Process 􀂃 To ensure inspection compliance.