aml guidelines 2011

IFIC Bank Ltd. Prevention of Money Laundering

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TABLE OF CONTENTS

CHAPTER – 1 DEFINITION 1 1.1 Money Laundering means 1 1.2 Reporting organization means the following organizations 1 1.3 Suspicious or unusual transaction means 1 1.4 Property means 1 1.5 Predicate Offence means 2 CHAPTER – 2 WHY AND HOW TO COMBAT MONEY LAUNDERING 2 CHAPTER – 3 THE OFFENCE OF MONEY LAUNDERING AND PUNISHMENT 2 3.1 Punishment for violation of freezing/attachment order 2 3.2 Divulging of information 3 3.3 Obstruction or non co-operation in investigation, failure to report or

supply of information 3 3.4 Providing False Information to Banks/ Financial Institutions 3 3.5 Investigation, Prosecution etc. 3 3.6 Offence committed by company etc. 4 3.7 Protection against proceedings undertaken in good faith 4 CHAPTER – 4 RESPONSIBILITY OF REPORTING ORGANIZATIONS IN PREVENTING

MONEY LAUNDERING 4 CHAPTER – 5 INSTITUTIONAL POLICY 5 CHAPTER – 6 SENIOR MANAGEMENT COMMITMENT 5 CHAPTER – 7 THE STANDARDS 6 7.1 Scope and Implementation 6 7.2 Retrospective Application 6 7.3 Branch Managers Obligations 6 CHAPTER – 8 INTERNAL CONTROLS 7 8.1 Training and Awareness 7 8.2 Monitoring 8 8.3 Development of Software Profile System 8 8.4 Branch Managers Certifications 8 CHAPTER – 9 CUSTOMER ACCEPTANCE POLICY 8 CHAPTER–10 IDENTIFICATION AND VERIFICATION OF CUSTOMERS ACCOUNT 9 10.1 Customer Identification 9 10.2 Bank should Focus on 10 10.3 Monitor Funds Transfer activities to track Money Laundering 10 10.4 Tracking of Large – Value Funds Transfers 10 10.5 Monitor activity not consistent with the Customer’s Business 11 10.6 Monitor unusual characteristics or activities in the customers account 11 10.7 Record Keeping 11 CHAPTER–11 GUIDELINE ON KNOW YOUR CUSTOMER (KYC) PROCEDURES 11 11.1 KYC Policies tailored to the bank’s operation 11 11.2 Risk categorization – Based on Activity/ KYC Profile 12 11.3 Customer other than Account holder(s) 13 11.4 Transaction Monitoring Process 13 11.5 Suspicious Activity Reporting Process 14 CHAPTER–12 CASH TRANSACTION REPORT (CTR) 16 CHAPTER–13 STRUCTURING OF CASH TRANSACTION 16 CHAPTER–14 QUARTERLY REPORT TO BE SUBMITTED TO THE CEO/BOARD 16

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TABLE OF CONTENTS

CHAPTER–15 CORRESPONDENT BANKING RELATIONSHIP 17 CHAPTER–16 NON-PROFIT ORGANIZATIONS & NGO SECTOR 17 CHAPTER–17 CROSS-BORDER WIRE TRANSFER 17 CHAPTER–18 SELF-ASSESSMENT 17 CHAPTER–19 INDEPENDENT TESTING PROCEDURE 17 CHAPTER–20 RESPONSIBILITIES 18 Annexure–A Know Your Customer (KYC) Profile 19 Annexure–B KYC Requirements for High Net Worth Customers 22 Annexure–C Source of Fund Verification 23 Annexure–D Transaction Profile 24 Annexure–E Details of walk-in/one-off customers in respect of FDD/FTT/PO and others 25 Annexure–F Training on Money Laundering & its Prevention 26


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1. DEFINITION

1.1. Money Laundering means:

As per stipulations contained in Section 2 (K) of the Money Laundering Prevention Act, 2009 (Act No.08 of 2009) in Bangladesh “Money Laundering” means:

i) transfer, conversion, remitting abroad or remit or bring from abroad to Bangladesh the proceeds or properties acquired through commission of a predicate offence for the purpose of concealing or disguising the illicit origin of the property or illegal transfer of properties acquired or earned through legal or illegal means.

ii) to conduct, or attempt to conduct a financial transaction with an intent to avoid a reporting requirement under this Act.

iii) to do or attempt to do such activities so that the illegitimate source of the fund or property can be concealed or disguised or knowingly assist to perform or conspire to perform such activities.

1.2. Reporting organization means the following organizations:

i) Banks ii) Financial Institutions iii) Insurance companies iv) Money changers v) companies or organizations remitting or transferring money vi) Other business organizations approved by Bangladesh Bank

vii) Stock Dealer and Stock Broker, viii) Portfolio Manager and Merchant Bank, ix) Security Custodian, x) Asset Manager, xi) Non Profit Organization/Institution xii) Non Government Organization and

xiii) Such other organizations as the Bangladesh Bank with the approval of Government may notify from time to time.

1.3. Suspicious or unusual transaction means:

i. a transaction that substantially deviates from the usual norm by which that transaction is usually conducted, or

ii. there is reasonable cause to believe that the transaction is related to any proceeds of crime.

1.4. Property means:

i. any kind of assets, whether tangible or intangible, movable or immovable, however acquired; or

ii. cash, legal documents or instruments in any form, including electronic or digital, evidencing title to, or interest in, such assets.

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1.5. Predicate Offence means: The offences from which the proceeds derived from committing or attempt to

commit the following offences:

i. corruption and bribery; ii. counterfeiting currency; iii. counterfeiting documents; iv. extortion; v. fraud; vi. forgery; vii. illicit arms trafficking; viii. illicit dealing in narcotic drugs and psychotropic substances; ix. illicit dealing in stolen and other goods; x. kidnapping, illegal restraint, hostage-taking; xi. murder, grievous bodily injury; xii. woman and child trafficking; xiii. smuggling and unauthorized cross-border transfer of domestic and foreign currency; xiv. theft or robbery or dacoity; xv. trafficking in human beings and illegal immigration; xvi. dowry; xvii. Terrorism and Terrorist Financing; xviii. Counterfeiting and Piracy of Products ; xix. Environmental Crime; xx. Sexual Exploitation; xxi. Taking market advantage through transactions by using price sensitive information of the

capital market before it becomes public and trying to control or manipulate the market to gain personal advantage (Insider trading and market manipulation) ;

xxii. Organized Crime and xxiii. any other offence which Bangladesh Bank with the approval of the Government and by

notification in the Official gazette declares as predicate offence for the purpose of this Act.

2. WHY AND HOW TO COMBAT MONEY LAUNDERING

Money laundering has potentially devastating economic, security, and social consequences. Money laundering is a process vital to making crime worthwhile. It provides the fuel for drug dealers, smugglers, terrorists, illegal arms dealers, corrupt public officials, and others to operate and expand their criminal enterprises. Money laundering diminishes government tax revenue and therefore, indirectly harms honest taxpayers. It also makes government tax collection more difficult.

In order to combat Money Laundering Bank should at all times pay particular attention to the

fundamental principle of good business practice-‘know your customer’ (KYC). Having a sound knowledge of a customer’s business and pattern of financial transactions and commitments is one of the best methods by which Bank and its Officials will recognize attempts at money laundering.

3. THE OFFENCE OF MONEY LAUNDERING AND PUNISHMENT

(1) For the purpose of this Act Money laundering shall be treated as an offence

(2) Any person engaged in money laundering or abetting or aiding or conspiring in the commission of such offence shall be punished with imprisonment for a term not less than six months but which may extend to seven years and in addition to this property involved with the offence shall be forfeited in favor of the state.

3.1. Punishment for violation of freezing / attachment order:

Whoever contravenes the freezing order or an order of attachment passed under this ordinance shall be punished with imprisonment of either description for a term which may extend to one year or with fine, upto taka five thousand or both.

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3.2. Divulging of information:

(1) No person shall, for the purpose of frustrating the investigation or making adverse influence over the investigation, divulge any information relating to investigation or other related information to any person agent or news media.

(2) Any person, organization, agent or entity authorized under this Act during the period of

his/her service contract period or after retirement will refrain himself/herself from using, publishing or divulging information collected, received, retrieved and known by himself/herself except for the purpose of the Act.

(3) Whoever contravenes the provision of sub-section (1) and (2), shall be liable on

conviction to imprisonment of either description for a term, which may extend to two years, or fine upto Taka ten thousand or both.

3.3. Obstruction or non co-operation in investigation, failure to report or supply of information:

(1) whoever- i. obstructs or refuses to assist the concerned Officer engaged in investigation under this

Act or ii. fails to comply without reasonable ground with a reporting obligation or fails to supply

information contemplated under this Act, shall be guilty of an offence under this Section.

(2) Whoever contravenes the provision of sub-section (1) shall be liable on conviction to

imprisonment for a term which may extend to one year, or a fine upto Taka five thousand or both.

3.4. Providing False Information to Banks / Financial Institutions:

(1) Nobody knowingly shall provide false information concerning the source of funds or the identity of any account holder or the beneficial owner or nominee.

(2) A person who contravenes the provision of Sub-section (1) shall be liable on conviction for an imprisonment of either description which may extend to 1 year and / or a fine up to Taka fifty thousand or both.

3.5. Investigation, Prosecution etc.:

Under this Act,

i. The offences under this Act considered as the scheduled offences of Anti-Corruption Commission Act, 2004 (Act V of 2004), will be investigated by Anti-Corruption Commission or by an Officer empowered by Anti-Corruption Commission for this purpose.

ii. The Offences will be prosecuted by the Special Judge court as appointed under Criminal Law Amendment Act. 1958 (Act XL of 1958).

iii. If any conflict arises regarding investigation, prosecution and other related provisions, etc. of this Act, the provision of Anti-Corruption Commission Act, 2004 and Criminal Law Amendment Act. 1958 shall prevail.

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3.6. Offence committed by company, etc.:

(1) If any offence under this Act committed by a company, every proprietor, director, manager, secretary, or other Officer or representative who is directly involved with the offence shall be deemed to be guilty of such offence:

Provided that if any person as aforesaid is not able to prove that such offence has been

committed without his knowledge or he has used due diligence to prevent such offence, Explanation:- In this section-

(a) “Company” means any statutory body, partnership concern, association, commercial organization or organization formed with one or more than one person;

(b) “Director” means any partner or member of the Board of Directors, by whatever name it is called.

(2) Registration of any company, if found engaged in money laundering activity either directly

or indirectly, shall be liable to be cancelled.

3.7. Protection against proceedings undertaken in good faith: No suit, prosecution either civil or criminal or other legal proceedings shall lie against

government or any government officials or any reporting organizations if any person is affected or likely to be affected due to the proceedings done in good faith under this Act.

4. RESPONSIBILITY OF REPORTING ORGANIZATIONS IN PREVENTING MONEY

LAUNDERING:

(1) For the purpose of preventing and identifying money laundering reporting organizations shall - (a) keep, during the operation of accounts, the correct and full information of identification of

its clients and

(b) in case of closed account of any client, keep previous records of transactions of such account for at least five years from the date of closure.

(c) provide, from time to time, the records kept under clause (a) and (b) to Bangladesh Bank time to time on demand from Bangladesh Bank.

(d) inform proactively and immediately Bangladesh Bank, facts on suspicious / unusual / doubtful or transactions likely to be related to money laundering.

(2) If any reporting organizations violate the directions mentioned in sub-section (1) Bangladesh

Bank shall take the following actions:

(a) Bangladesh Bank may impose a fine of not less than Taka ten thousand and such fine may extend to Taka five Lac upon the defaulting reporting organizations.

(b) Bangladesh Bank may cancel the registration of the company or cancel the license in addition to the fine mentioned in sub-section (a) .The Bangladesh Bank shall inform the permit or license authority of the reporting organizations regarding their failure to keep and furnish information under sub-section (1) so that the concerned authority may, in accordance with the relevant law or rule or regulation framed there under, take necessary action against the concerned reporting organizations for their failure or negligence.

(3) Bangladesh Bank will collect the penalty money imposed under subsection (2) in its self

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5. INSTITUTIONAL POLICY

In order to protect Banks reputation and to meet its legal and regulatory obligations, it is essential that Bank should minimize the risk of being used by Money Launderers. With that end in view it will be an obligatory responsibility for all Bank Official, customers and management of the Bank to realize and combat the situation on this critical risk issue.

5.1 Establish clear lines of internal accountability, responsibility and reporting. Primary responsibility for the prevention of money laundering rests with the nature of business which must ensure that appropriate internal controls are in place and operating effectively and that bank Officials are adequately trained. The business is supported in meeting this responsibility by the Legal and Compliance function and by Bank Investigations.

5.2 Given its importance in reputational and regulatory terms, the effectiveness of the money laundering prevention regime across all businesses should form part of the governance oversight responsibilities of all branch managers.

5.3 Document, implement and maintain, procedures and controls which interpret Bank Policy and Bank Standards for each business in the context of applicable laws and regulations and corporate ethical standards. Compliance with such procedures and controls and with Bank Policy and Bank Standards will be effectively monitored.

5.4 Establish an effective ‘Know Your Customer’ Policy for the Branch Manager which will contain a clear statement of management’s overall expectation matching local regulations and establishing specific line of responsibilities. Detailed guideline on Know Your Customer (KYC) procedures are given at page # 11, Serial # 11 of this guidelines.

5.5 Co-operate with any lawful request for information made by government agencies during their investigations into money laundering.

5.6 Support governments, law enforcement agencies and Bangladesh Bank in their efforts to combat the use of the financial system for the laundering of the proceeds of crime or the movement of funds for criminal purposes.

5.7 Report money laundering issues to Head Office Management on a regular basis. The Branch Manager responsible to combat Money Laundering shall determine and communicate the content, format and frequency for management reporting.

6. SENIOR MANAGEMENT COMMITMENT

6.1 The most important element of a successful anti-money-laundering program is the commitment of senior management, including the Chief Executive Officer and the Board of Directors, to the development and enforcement of the anti-money-laundering objectives which can deter criminals from using their facilities for money laundering, thus ensuring that they comply with their obligations under the law.

6.2 Senior management must send the signal that the corporate culture is as concerned about its reputation as it is about profits, marketing, and customer service. As part of its anti- money laundering policy the Bank will communicate clearly to all employees on an annual basis a statement from the Chief Executive Officer that clearly sets forth its policy against money laundering and any activity which facilitates money laundering or the funding of terrorist or criminal activities. Such a statement should evidence the strong commitment of the Bank and its Senior Management to comply with all laws and regulations designed to combat money laundering.

The statement of compliance policy is: 6.2.1 That all employees of the Bank are required to comply with applicable laws and

regulations and corporate ethical standards.

6.2.2 That all activities carried on by the Bank must comply with applicable governing laws and regulations.

6.2.3 That complying with rules and regulations is the responsibility of each individual in the Bank in the normal course of their assignments. It is the responsibility of the individual to become familiar with the rules and regulations that relate to his or her assignment. Ignorance of the rules and regulations is no excuse for non-compliance.

6.2.4 That the statement should direct Officials to a compliance Officer or other knowledgeable individuals when there is a question regarding compliance matters.

6.2.5 That a certification that Official will be held accountable for carrying out their compliance responsibilities.

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7. THE STANDARDS

7.1 Scope and Implementation: The Bank will document, implement and maintain procedures and controls which interpret

Bank Policy and Bank Standards for each business in the context of applicable law and regulations. Compliance with such procedures and controls and with Bank Policy and Bank Standards will be monitored effectively.

7.1.1 These Standards are designed to help the business meet its responsibilities in relations to the prevention of money laundering.

7.1.2 The Standards are based on Banks Policy, the Money Laundering Prevention Act, 2009 and circulars/guidelines issued by Bangladesh Bank / IFIC Bank, Head Office from time to time. They are approved by the senior management of the Bank and are subject to regular review. They cover the following three core areas of money laundering prevention:

A. Internal Controls B. Reporting Suspicious Transactions C. Training and Awareness

7.1.3 The Standards set out minimum mandatory requirements for all business as required under Banks Policy. Such requirement may be enhanced where applicable law or regulation sets a more demanding requirement for a particular aspect of money laundering prevention. If, in exceptional circumstances, a business is unable to apply a particular standard, the issue should be referred to Head Office for necessary guidance.

7.1.4 The Standards cover all aspects of bank business activities from business relationships and the processing of transactions, through to the provision of advice to customers. Businesses must also consider the application of the Standards in relation to, for example, joint venture activities, subsidiary operations and outsourced services – particularly when cross border issues are involved.

7.2 Retrospective Application:

7.2.1 The Standards apply to both new and existing business relationships. Where necessary, therefore, remedial action on customer identification and due diligence must be undertaken for existing accounts, no matter how long the relationship has been in operation. Remedial work must be done as soon as possible. Where significant numbers of accounts are involved work plans for remedial action should prioritise those relationships considered to represent higher risks.

7.2.2 The progress of remedial projects should be reported to Head Office, Senior Management.

7.3 Branch Managers Obligations:

The Branch Managers shall be primarily responsible for the prevention of Money Laundering. They shall effectively reciprocate for the development, implementation, maintenance and monitoring of procedures and controls that meet the requirements of Bank Policy, Bank Standards and Rules and regulations under Money Laundering Prevention Act, 2009.

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8. INTERNAL CONTROLS

8.1 Training and Awareness: The senior management of the Bank will raise awareness on money laundering prevention

and train Banks Officials about what money laundering is the recognition of suspicious transactions, the requirement of applicable rules and regulations, Banks Policy and Standards on the prevention of money laundering, and the procedures and control in each jurisdiction.

8.1.1 The Need for Employees Awareness: All employees of the Bank must be aware of their own personal statutory

obligations and that they can be personally liable for failure to report information in accordance with internal procedures. All employees must be trained to co-operate fully and to provide a prompt report of any suspicious transactions.

8.1.2 It is, therefore, important that the Bank will introduce comprehensive measures to ensure that all employees and contractually appointed agents (if any) are fully aware of their responsibilities.

8.1.3 Education and Training Programs All employees should be educated in the process of the “know your customer”

requirements for money laundering prevention purposes. The training in this respect should cover not only the need to know the true identity of the customer but also, where a business relationship is being established, the need to know enough about the type of business activities expected in relation to that customer at the outset to know what might constitute suspicious activity at a future date. All employees should be alert to any change in the pattern of a customer’s transactions or circumstances that might constitute criminal activity.

8.1.4 New Employees New employee of the Bank will be provided training on Prevention of Money

Laundering, Combating Financing of Terrorism and Regulatory requirement in their foundation course.

8.1.5 Refreshers’ Training Bank will arrange refreshers’ training for its employees to make them updated with

Prevention of Money Laundering laws, Combating Financing of Terrorism and regulatory requirement.

8.1.6 In House Discussion Branch will arrange in house discussion on regular basis to update the employees of

the Branch on Prevention of Money Laundering laws, Combating Financing of Terrorism, Circulars issued by Bangladesh Bank and Head Office from time to time.

8.1.7. Training Records In order to demonstrate that it has complied with the regulations concerning

employees training, Bank will maintain records which includes:

Head Office level: (i) details of the content of the training programs provided; (ii) the names of employees who have received the training; (iii) the date on which the training was delivered; (iv) the results of testing carried out to measure employees understanding of the

money laundering requirements; and (v) an on-going training plan. Branch level: (i) details of the content of the training programs provided; (ii) the names of employees who have received the training; (iii) the date on which the training was delivered;

The Bank will continue to devote considerable resource to establish and maintain employees’ awareness of the risks of money laundering and terrorism financing, and their competence to identify and report relevant suspicions in this area. The Bank is dedicated to a continuous program of increasing awareness and training of employees’ at all appropriate levels in relation to their knowledge and understanding of AML issues, their respective responsibilities and the various controls and procedures introduced by the Bank to deter money laundering and financing of terrorism.

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8.2 Monitoring: A ‘Central Compliance Unit’ shall be setup at Head Office to ensure implementation of Prevention of Money Laundering Act as well as Bangladesh Bank’s directives where one Senior Executive will be posted as Convenor. At bank branches, separate cell should be setup under direct control and supervision of Branch Manager for prevention of possible money laundering as per guidelines issued by Bangladesh Bank from time to time under intimation to Head Office ‘Central Compliance Unit’.

8.3 Development of Software Profile System: In order to facilitate detection of money laundering, Bank should develop Software

incorporating parameters for generating KYC profile & TP. The IT Division will develop automated systems and processes for classifying customers on the basis of the risk matrix provided by Bangladesh Bank under new KYC Profile & TP for monitoring transactions with the transaction profile provided by the customers. These new systems will improve our ability to detect unusual transactions, help the authorities to identify and respond to new money laundering techniques.

8.4 Branch Managers Certifications: Each Branch Manager shall certify that he/she maintains customer profiling applying due

diligence KYC. The Branch Manager will further certify that all Officers and Members of the Officials of the Branch are aware of Money Laundering Prevention Act, 2009, Bank standards of best practice, Bangladesh Bank Circulars/ Guidelines and Head Office Circulars/ Instructions issued from time to time and necessary care taken for following them meticulously. The Branch Manager will also certify that he/she and his/her members of the Officials have read and understood the ‘Guidelines on Prevention of Money Laundering’ issued from Head Office and standards of best practice with ‘Know Your Customer’ (KYC) procedures.

9. CUSTOMER ACCEPTANCE POLICY

9.1 Senior Official below the rank of Branch incumbent will consider the matter relevant to prospective customer details in the light of following indicators/factors:-

i) Customers’ background ii) Country of origin iii) Public or high profile position iv) Linked accounts v) Business activities vi) Politically exposed person vii) High net worth whose source of fund un-cleared

9.2 Considering the above dominating factors if the prospective customer falls within low risk

category the above official may advise the concerned account opening Officer to open the account with the approval of Branch Incumbent. Transparent Identification of customers is essential in these cases.

9.3 If the prospective customer falls under the purview of medium risk category, the above official must consult with the Branch Incumbent before opening the account. Having due approval of the Branch Incumbent, the concerned Officer may open the account.

9.4 If the prospective customer happens to be the within high risk category the above official should refer the matter to Branch Incumbent. If the Branch Incumbent is satisfied that risk factors are not present and Bank will be at a safer position, branch may consider opening the account. However, utmost caution has to be exercised.

9.5 Enhanced due diligence will be exercised for opening accounts of Politically Exposed Persons (PEPs) in line with the AML Circular of Bangladesh Bank. The account activity of the PEP’s accounts will be monitored so that any changes may be detected, and consideration can be given as to whether such change suggests corruption or misuse of public assets. This includes close scrutiny of receipts of large sums not consistent with the occupation or business of the PEPs.

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9.6 Especial care to be taken for general public to provide banking services, especially for people who are financially or socially disadvantaged as the customer acceptance policy should not so restrictive that it results in a denial of access by the above category people.

9.7 No account shall be opened of non-face to face customers.

9.8 No account will be opened without having name, address, signature etc.

9.9 The Bank will be cautious before establishing relationship with Respondent Banks which are maintaining relationship with Shell Banks.

10. IDENTIFICATION AND VERIFICATION OF CUSTOMERS ACCOUNT

A meaningful anti-money laundering compliance program of the Bank should include identification and verification of customers at account opening. Accordingly, the Branch must ensure to:

- Verify the identity of any person seeking to open an account to the extent reasonable and practicable;

- Maintain records of the information used to verify a persons identity, including name, address and other identifying information; and

- Consult lists of known or suspected terrorists or terrorist organizations provided to the financial institution by the regulators/government agency to determine whether a person seeking to open an account appears on any such list.

The following options are recommended for a branch to consider in developing customer identification process:

10.1 Customer Identification:

A. Branch should not keep anonymous accounts or accounts in obviously fictitious names: they should be required (by Law, by regulations, by agreements between supervisory authorities and Banks or by self-regulatory agreements among Banks) to identify, on the basis of an Official or other reliable identifying document, and record the identity of their clients, either occasional or usual, when establishing business relations or conducting transactions (in particular opening of accounts, entering into fiduciary transactions, renting of lockers, performing large cash transactions).

In order to fulfill identification requirements concerning legal entities, branch should, when necessary, take measures: i. To verify the legal existence and structure of the customer by obtaining either from a

public register or from the customer or both, proof of incorporation, including information concerning the customer’s name, legal form, address, directors and provisions regulating the power to bind the entity.

ii. To verify that any person purporting to act on behalf of the customer is so authorized and identify that person.

iii. No account should be opened without satisfactory identification and proper introduction. In fact before account opening an experienced officer should interview the customer to assess his need for opening an account, selection of a particular Bank or Branch, his business, employment etc.

iv. Customer residence (permanent and present) or place of business to be carefully considered. If it is not in the area served by the bank or branch, then customer’s opening an account at that location may need some questioning.

v. Thanking the customer for opening the account and the introducer for introducing the account by sending letters to verify address should be done without fail.

vi. The source of funds used to open the account shall be known and commensurate with the account opener’s details.

vii. For large accounts, asking the customer for a prior bank reference may be prudent. Bank may write a letter to the Bank asking about the customer.

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B. Customer Profiling: i. Obtaining and document the customer’s basic background information.

ii. Try to use this information to evaluate the appropriateness and reasonableness of the customer’s transaction activity.

iii. Determine the source of the customer’s funds.

C. KYC Profile should Disclose: i. The customer’s expected transaction trends (monthly or annually),

ii. The source of wealth and

iii. Net income

D. KYC Profile should be upgraded/ updated by: i. Regular reviews of transaction activity and balance fluctuation reports;

ii. Newspapers and magazine articles, financial statements, brochures, industry activities relating to the customer;

iii. Periodical discussions with the client relating to their business activities including future plan of the business for the next 12 months.

10.2 Bank should Focus on:

- High risk customers;

- Source of significant funds; and

- Transactions which are inconsistent with the transaction profile.

- Client borrowing should be monitored in the course of business by the responsible Officer of advances department to ascertain repayments or settlement of loans or loan draw down is in line with the client business activities.

10.3 Monitor Funds Transfer activities to track Money Laundering:

- Sending or receiving frequent or large volume of Swift/Telegraphic transfers to and from domestic and offshore institutions.

- Depositing funds into several accounts, usually in amounts below the banks track able threshold, and then consolidating into a master account and transferring them outside of the country.

- Instructing the bank to transfer funds abroad and to expect an equal incoming Swift/Telegraphic transfer from other sources.

- Regularly depositing or withdrawing large amounts by Swift/Telegraphic transfers to, from, or through countries that are known sources of narcotics or whose bank secrecy laws facilitate the laundering of money.

- Receiving Swift/Telegraphic transfers and immediately purchasing monetary instruments prepared for payment to a third party.

10.4 Tracking of Large – Value Funds Transfers: To curtail money laundering activities, the branch should focus on the identification and

documentation of currency based transactions. It is recommended to provide complete information about the parties to a funds transfer. The information could include, to the extent practical, complete originator and beneficiary information for payment orders sent through all funds transfers systems. Branch should include the following information, to the extent possible, in the text of every payment order:

- Name, address and account number of the applicant;

- The beneficiary’s name, address and account number, if available.

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10.5 Monitor activity not consistent with the Customer’s Business: - Corporate account(s) where deposits or withdrawals are primarily in cash rather than

cheques.

- A customer who operates a retail business and does not make substantial drawings against cheque deposited. This may indicate that the customer has another source of cash.

- Accounts with a large volume of deposits in demand Draft, Pay Order and/or Swift/Telegraphic transfer, when the nature of the account holders business does not justify such activity.

- Accounts that show frequent large cash transactions for a business that generally does not deal in large amounts of cash.

- Retail deposits of numerous cheques but rare withdrawals for daily operations.

- An account that sends and receives Swift/Telegraphic transfer without an apparent business reason or when inconsistent with the customers business or history.

10.6 Monitor unusual characteristics or activities in the customers account:

- An account holder or customer that has frequent deposits of large amounts of cash deposit.

- Client or in-house company accounts, such as trust accounts, escrow accounts, etc. that show substantial cash deposits.

- An account opened in the name of a Money Exchanger that receives Swift/Telegraphic transfers and/or structured deposits.

- A customer who purchase a number of Demand Draft, Pay Orders or Travelers Cheques for large amounts just under a specified threshold or without apparent reason.

10.7 Record Keeping: Branch should maintain, all necessary records on transactions, both domestic or

international as per Bangladesh Bank Circular in force, to enable them to comply swiftly with information requests from the competent authorities. Such records must be sufficient to permit construction of individual transactions (including the amounts and types of currency involved if any) so as to provide, if necessary, evidence for prosecution for criminal behaviour.

Branch should keep records on customer identification (e.g. copies or records of official identification documents like National ID Cards, Passports, Identity Cards, Driving Licenses or Other Documents acceptable to the Bank), account files and business correspondence for minimum 5 (five) years even after the account is closed.

These documents should be available to domestic competent authorities in the context of relevant criminal prosecutions and investigations.

11. GUIDELINE ON KNOW YOUR CUSTOMER (KYC) PROCEDURES

11.1.1 A KYC policies tailored to the bank’s operation: - Helps detect suspicious activity in a timely manner, - Promotes compliance with all banking laws, - Promotes safe and sound banking practices, - Minimize the risk that the bank will be used for illicit activities, - Reduces the risk of government seizure and forfeiture of a customers loan collateral when

the customer is involved in criminal activity, and - Protects the banks reputation.

Generally, a branch should never establish a relationship with a customer until it knows the customers true identity. If a potential customer is unwilling to provide the necessary information, the relationship should be reconsidered. However, the unwilling customer shall be impressed upon by the branch manger to provide such information. If the bank has established a customer relationship, it should be alert for any unusual business transactions.

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11.1.2 Before opening an account due diligence is required to be performed on all prospective clients. This process should be completed by fulfilling the documentation requirements (Account Application, Bank References, Source of funds and Identification for example) and also a ‘Know Your Customer’ (KYC) profile which is used to record a client’s source of wealth, expected transaction activity at it’s most basic level.

11.1.3 Once the identification procedures have been completed and the client relationship is established, Branch should monitor the conduct of the relationship/account to ensure that it is consistent with the nature of business stated when the relationship/account was opened. Branch do this firstly by their Officer being diligent, reporting suspicious transactions undertaken by the customer, updating the client’s KYC profile for any significant changes in their lifestyle (e.g., change of employment status, increase in net worth) and by monitoring the transaction activity over the client’s account on a periodic basis.

11.1.4 KYC profile must contain the basic information about the customer like, Name, Address, Tel/Fax Numbers, line of business, Annual sales. If the customer is a Public Figure, the account is to be treated as High Risk Account.

11.1.5 The KYC Profile information will also include the observations of the Officer of the Branch when they visit the customer’s business place like, the business place is owned or rented, the type of clients visited, by what method is the client paid (cheque or cash). The Officer will record his observations and sign the KYC Profile form.

11.1.6 In the case of high net worth Accounts, the information will include net worth of the customer, source of funds etc. Branch should complete the profile form (see ‘Annexure-D’) for high net worth customers falling under the following criterion: a) New Customers whose initial deposit is more than Tk. 50 Lacs (initial means

within one month of A/c opening) b) Existing customers whose total AUM (Asset under Management) grow to> Tk.

50 Lacs for 3 consecutive months.

11.1.7 The KYC Profile leads to Risk Classification of the Account as High/Low Risk.

11.2 Risk categorization – Based on Activity/KYC Profile :

11.2.1 When opening accounts, the concerned 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-F’ 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

11.2.2 The risk scoring of less than 14 indicates low risk and 14 or more than 14 would indicate high risk. The risk assessment scores are to be documented in the KYC Profile Form (see ‘Annexure-A’). However, management may judgmentally override this automatic risk assessment to “Low Risk” if it believes that there are appropriate mitigators to the risk. This override decision must be documented (reasons why) and approved by the Branch Manager, and Branch AML Compliance Officer.

Officer’s assessment or customer Provided

KYC Profile

Risk Classification

Frequency of Monitoring and Review

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11.2.3 KYC Profiles and Transaction Profiles (see ‘Annexure-A and D’) must be updated and re-approved at least annually for “High Risk” accounts (as defined above). There is no requirement for periodic updating of profiles for “Low Risk” transactional accounts. These should, of course, be updated if and when an account is reclassified to “High Risk”, or as needed in the event of investigations of suspicious transactions or other concern.

11.2.4 If a person deposits or withdraws money from an account which is maintained with other branch through on line banking the branch must obtain details of depositor/ withdrawer on reverse side of the deposit slip/cheque/instrument.

11.3 Customer other than Account holder(s):

As per AML circular # 2 dated 17.07.2002 and our Head Office circular # 49 dated 28.08.2002 Branch should requires to obtain satisfactory evidence for identification of applicants who do not maintain account with branch for conducting one off transactions (see ‘Annexure-E’).

11.4 Transaction Monitoring Process:

11.4.1 Appropriate monitoring program for the activities and transactions routed through the customers account should be instituted. Depending on the type and nature of the account, Branch may fix/set a specific threshold covering the following account activities to identify the client activities that do not appear commensurate with the client’s business activities.

- Large Cash transactions including cash deposits & withdrawals on any particular day.

- Large volume credit turnover or month-end credit balance of the same threshold.

- Remittance monitoring.

11.4.2 Branch is to monitor on an ongoing basis the relevant activities in the course of the business relationship. The nature of this monitoring will depend on the nature of the business. The purpose of this monitoring is for Branch to be vigilant for any significant changes or inconsistencies in the pattern of transactions. Inconsistency is measured against the stated original purpose of the accounts i.e. the declared Transaction Profile (TP) of the Customer. Possible areas to monitor are: a. Transaction type b. Frequency c. Unusually large amounts d. Geographical origin/destination e. Changes in account signatories

11.4.3 It is recognized that the most effective method of monitoring of accounts is

achieved through a combination of computerized and human manual solutions. A corporate compliance culture, and properly trained, vigilant Officer through their day-to-day dealing with customers, will form an effective monitoring method as a matter of course. Computerized approaches may include the setting of “floor levels” for monitoring depending on the amount. Different “floor levels” or limits may be set for different categories of customers.

11.4.4 Every Business and every individual will have normally certain kind of transaction in line with their business/individual needs. This will be declared in a Transaction Profile (TP) at the time of opening account from the customer. Ideally any deviation from the normally expected TP should be reviewed with human judgment and interaction with customer. Such reviews may result in changing the expected profile or closing the customer account.

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11.4.5 It may not be feasible for some Branch or specific Branches of having very large number of customers to track every single account against the TP where a risk based approach should be taken for monitoring transactions based on use of “Customer Categories” and “Transaction Limits” (individual and aggregate) established within the branch. The Customer Category is assigned at account inception– and may be periodically revised and is documented on the Transaction Profile. Transaction Limits are established by the business subject to agreement by BAMLCO. The Customer Categories and Transaction Limits are to be maintained either in the manual ledgers or in computer systems.

11.4.6 On regular basis Branch must prepare an exception report of customers whose accounts showed one or more individual account transaction during the period that exceeded the “transaction limit” established for that category of customer based on Anti-Money Laundering risk assessment exercise.

11.4.7 Manger/ BAMLCO/ Operations Officer or other designated Officer will review and sign-off on such exception report of customers whose accounts showed one or more individual account transaction during the period that exceeded the “transaction limit” established for that category of customer. The concerned Officer will document their review by initial on the report, and where necessary will prepare internal Suspicious Activity Reports (SARs) with action plans for approval by the relevant Branch Manager and review with the BAMLCO. A copy of the transaction identified will be attached to the SARs.

11.4.8 BAMLCO will review the SARs and responses from the Operations Officer or other concerned Officer. If the explanation for the exception does not appear reasonable then the Branch Manager should review the transactions prior to considering submitting them to the CAMLCO.

11.4.9 If the BAMLCO believes the transaction should be reported, then the BMLCO will supply the relevant details to the CAMLCO.

11.4.10 The CAMLCO will investigate any reported accounts and will send a status report to Bangladesh Bank on any of the accounts reported. No further action should be taken on the account until notification is received from Bangladesh Bank.

11.4.11 For any change in the TP of a customer, the Operations Officer is responsible for documenting the reasons why the transaction profile has been changed and should amend the KYC profile accordingly.

11.5 Suspicious Activity Reporting Process:

11.5.1 Branch should record in-writing all internal procedures so that, in the event of a suspicious activity being discovered, all Officers are aware of the reporting chain and the procedures to follow. Such procedures should be periodically updated to reflect any regulatory changes.

11.5.2 Branch should ensure that Officer will report all suspicious activities to their BAMLCO, and that any such report be considered in light of all other relevant information by the BAMLCO, or by another designated person, for the purpose of determining whether or not the information or other matter contained in the report does give rise to a knowledge or suspicion.

11.5.3 Where Officer continues to encounter suspicious activities on an account, which they have previously reported to the BAMLCO, they should continue to make reports to the BAMLCO whenever a further suspicious transaction occurs, and the BAMLCO Should determine whether a disclosure in accordance with the regulations is appropriate.

11.5.4 All reports of suspicious activities must reach the CAMLCO at Head Office and only the CAMLCO should have the authority to determine whether a disclosure in accordance with the regulation is appropriate. However the Manager can be permitted to add his comments in the suspicious report indicating any evidence as to why he/she believes the suspicion is not justified.

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11.5.5 Reporting of Suspicious Transactions: Detailed procedures on reporting of suspicious activities are given as follows:

i) There is a statutory obligation on all Officers to report suspicions of money laundering. The Act contains the requirement to report to the Bangladesh Bank. Actual reporting should be made in accordance with an internal reporting procedure to be established by a financial institution for the purposes of facilitating the operation of the reporting obligation.

ii) In line with accepted practice, some businesses may choose to require that such unusual or suspicious transactions be drawn initially to the attention of supervisory management to ensure that there are no known facts that will negate the suspicion before further reporting on to the Anti Money Laundering Compliance Officer or an appointed deputy.

iii) Each Branch has a clear obligation to ensure: • that each relevant employee knows to which person they should

report suspicions, and • that there is a clear reporting chain under which those suspicions

will be passed without delay to the Chief Anti Money Laundering Compliance Officer.

iv) Once Officers have reported their suspicions to the appropriate persons in accordance with an established internal reporting procedure they have fully satisfied the statutory obligations.

v) Branch must refrain from carrying out transactions which they know or suspect to be related to money laundering until they have apprised the Bangladesh Bank. Where it is impossible in the circumstances to refrain from executing a suspicious transaction before reporting to the Bangladesh Bank or where reporting it is likely to frustrate efforts to pursue the beneficiaries of a suspected money laundering operation, the Branch concerned shall apprise it to CAMLCO immediately afterwards. CAMLCO will apprise the Bangladesh Bank immediately. While it is impossible to spell out in advance how to deal with every possible contingency, in most cases common sense will suggest what course of action is most appropriate. Where there is doubt, the advice of the Branch Anti Money Laundering Compliance Officers may be sought.

vi) Chief Anti Money Laundering Compliance Officer (CAMLCO) will have the responsibility for communicating reports of suspicious transactions to the Anti-Money Laundering Department of Bangladesh Bank and who will provide the liaison between the Branch and the Bangladesh Bank.

vii) The CAMLCO has a significant degree of responsibility and should be familiar with all aspects of the legislation. He/she is required to determine whether the information or other matters contained in the transaction report he/she received give rise to a knowledge or suspicion that a customer is engaged in money laundering.

viii) He/She must steps to validate the suspicion in order to judge whether or not a report should be submitted to Bangladesh Bank. In making this judgment, the CAMLCO should consider all other relevant information available within the financial institution concerning the person or business to which the initial report relates. This may include a review of other transaction patterns and volumes through the account or accounts in the same name, the length of the relationship, and referral to identification records held. If, after completing this review, the CAMLCO decides that there are no facts that would negate the suspicion, then he/she must disclose the information to Bangladesh Bank.

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ix) The determination of whether or not to report implies a process with at

least some formality attached to it. It does not necessarily imply that the CAMLCO must give reasons for negating, and therefore not reporting any particular matter, but it clearly would be prudent for internal procedures to require that written reports are submitted and that he/she should record his/her determination in writing. Clearly in cases where there is a doubt it would be prudent for the CAMLCO to make a report to the Bangladesh Bank.

x) It is therefore imperative that the CAMLCO has reasonable access to information that will enable him/her to undertake his/her responsibility. In addition, the reference in the above sub-section ix) to “determination” implies a process with some formality. It is important therefore that the CAMLCO should keep a written record of every matter reported to him, of whether or not the suggestion was negated or reported, and of his reasons for his decision.

xi) The CAMLCO will be expected to act honestly and reasonably and to make his determinations in good faith. Provided the CAMLCO or an authorized deputy does act in good faith in deciding not to pass on any suspicions report, there will be no liability for non-reporting if the judgment is later found to be wrong.

xii) Care should be taken to guard against a report being submitted as a matter of routine to Bangladesh Bank without undertaking reasonable internal enquiries to determine that all available information has been taken into account.

xiii) STR to be submitted in the prescribed format directly to the General Manager, Money Laundering Department, Bangladesh Bank, Head Office, Dhaka under sealed cover note mentioned on the cover “‡Mvcbxq STR”.

xiv) Executives/Officers of the Bank will not divulge any information pertaining to STR submitted to Bangladesh Bank in any circumstance so that the activities of inquiry will not hamper.

xv) All employees of the Bank for doing any act in good faith in connection with Prevention of Money Laundering are protected by the law.

12. CASH TRANSACTION REPORT (CTR) As per Bangladesh Bank directives branch will submit Cash Transaction Report (CTR) for

deposit & withdrawal of Cash for such amount as determined by Bangladesh Bank from time to time within stipulated dateline.

13. STRUCTURING OF CASH TRANSACTION As per Money Laundering Prevention Act, structuring is an offence. If a customer intends to

conduct such transaction to avoid reporting requirement is called structuring. Branch officials should be vigilant to detect structuring.

14. QUARTERLY REPORT TO BE SUBMITTED TO THE CEO/BOARD As per Bangladesh Bank directives CAMLCO will submit report to the CEO/Board in connection

with steps taken by CCU, progress of its implementation and details suggestive report in this regard on Quarterly basis.

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15. CORRESPONDENT BANKING RELATIONSHIP Correspondent Banking relationships sometimes create a risk that the other Bank’s customers may be using that Bank to launder funds. It is not necessarily possible to conduct due diligence on that Bank’s customer base and as such, these relationships require additional care and attention to guard against becoming unwilling participants in this activity. The following controls need to be implemented for establishing correspondent banking relationships:-

a. No relationship to be established with Shell Banks that have no physical presence in any country.

b. The Bank will keep sufficient information about a respondent institution to understand fully the nature of their business.

c. The Bank will be satisfied with the respondent institution’s anti-money laundering and terrorist financing controls.

d. Before establishment of relationship, the Bank will know whether the respondent institutions have customers who are based in countries classified by FATF as “high risk” and if so, whether they maintain enhanced due diligence on such customer(s).

e. The Bank will not allow third parties to use its Correspondent Bank account(s) i.e. in the form of “payable through account”.

f. The Bank may review correspondent banking relationship as and when required. 16. NON-PROFIT ORGANIZATIONS & NGO SECTOR Accounts of Charities, Non-Profit Organizations, Non Government Organizations to be treated as

high risk accounts and Enhanced Due Diligence (EDD) will be performed for opening and operating such accounts to prevent money laundering.

17. CROSS-BORDER WIRE TRANSFER

a) All cross-border wire transfers will be accompanied by accurate and meaningful originator information.

b) Information accompanying cross-border wire transfers will contain the name and address of the originator and where an account exists, the number of that account. In the absence of an account, a unique reference number, as prevalent in the country concerned, will be included.

c) Where several individual transfers from a single originator are bundled in a batch file for transmission to beneficiaries in another country, they may be exempted from including full originator information, provided they include the originator’s account number or unique reference number as at (b) above.

18. SELF-ASSESSMENT

This policy requires that appropriate and timely self-assessments, tests, audits and evaluations be conducted to ensure that the Bank is in compliance with the regulations. Each and every branch shall asses their performance on quarterly basis according to AML Circular of Bangladesh Bank. The shortcomings identified to be overcome and complied within next quarter.

19. INDEPENDENT TESTING PROCEDURE As per AML Circular of Bangladesh Bank, testing on Prevention of Money Laundering is to be

conducted on the branches by the internal audit personnel of ICC. While conducting the same, they should also look into whether the directives of Bangladesh Bank issued from time to time in this respect are followed meticulously by the branches

Mentionable that Compliance of AML is the responsibility of each employee of the Bank. Therefore, all guidelines related to AML be updated as and when required and circulated and ensured that all employees are aware of the Anti-Money Laundering Act internal guidelines and other policies and procedures.

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20. RESPONSIBILITIES The Bank shall establish clear lines of internal accountability, responsibility and reporting

system. The details of the individual responsibilities of the Bank are as under:

Function Role/ Responsibilities Account opening Officer

Perform due diligence on prospective clients prior to opening an account.

Be diligent regarding the identification (s) of account-holder. Ensure all required documentation is completed satisfactorily. Complete the KYC/CDD Profile for the new customer.

Operations Officer Obtain documentary evidence of large cash deposits. Ensure that all control points are completed prior to transaction

monitoring. Ongoing diligence on transaction trends for clients. Update customer transaction profiles in the ledger/system.

Risk Management Officer/ Credit Officer/ Internal Control Officer.

Perform AML risk assessment for the Business. Perform periodic quality assurance on the AML program in the

Branch. IT In-charge of the Branch

Ensure that the required reports and systems are in place to maintain an effective AML program.

BAMLCO Manage the transaction monitoring process. Ongoing monitoring of customer’s KYC/CDD profile and

transaction activities. Report any suspicious activity to Branch Manager and if

necessary the CAMLCO. Provide AML training to Branch employees. Communicate updates in AML laws and internal policies to all

employees. Submit Branch returns to CAMLCO on regular basis.

Branch Manager Ensure that the AML program is effective within the Branch. Overall responsibility to ensure that the Branch has an AML

program in place and that it is working effectively. CAMLCO Overall responsibility to ensure that the Bank has an AML

program in place and that it is working effectively. Implement and enforce Bank’s AML policies. Report suspicious clients to Bangladesh Bank on Bank’s behalf.

Chief Executive Officer (CEO)/ MD

Overall responsibility to ensure that the Bank has an AML program in place and that it is working effectively.

Appropriate disciplinary action will be initiated against the delinquent Official for

violation of this Policy.

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“Annexure-A”

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“Annexure-B”

List of Questions to be used when obtaining source of wealth

KYC REQUIREMENTS FOR HIGH NET WORTH CUSTOMERS.

A. Source of Wealth Type of source of wealth: Business Ownership Profession *

Top executive Investments *

Inheritance Other

Instructions: Please refer to the list of questions to be used when obtaining source of

wealth you may need to choose more than one category for a business owner with inherited wealth

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B. Notes of Face-to-face meeting with customers.

C. Annual Review of Customer Profile. Profession – E.g. Physician, lawyer, engineer, accountants and sports professional etc. Investments –Someone who buys and sells assets of any type: real estate, securities,

companies, royalties and patents etc. Prepared by: Name: Date:

Account Officer/ Relationship Manager

Reviewed by: Name: Date:

Branch Manager/Branch Operations Head

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“Annexure-C”

Source of Fund Verification

List of Questions to be used when obtaining source of wealth Wealth Generated From Business Ownership

- Description and nature of the business and its operations - Ownership type: private or public? - What kind of company? - Percent of ownership? - Estimated sales volume? - Estimated net income? - Estimated net worth? - How long in business? - How was the business established? - Other owners or partners (yes/no)? - Names of other owners or partners? - Percent owned by other owners or partners? - Number of employees - Number of locations? - Geographic trade areas of business - Other family members in business? - Significant revenues from government contract or licenses?

Wealth Derived From Being a Top Executive

- Estimate of compensation? - What does the company do? (for example, manufacture, service……) - Position held (for example, President, CFO) - Length of time with company? - Area of expertise (for example, finance, production, etc…..) - Publicly or privately owned? - Client’s past experience (for example, CFO at another company…..)

Primary Source of Wealth was Through Inheritance

- In what business was the wealth generated? - Inherited from whom? - Type of asset inherited (For example: land, securities, company trusts…) - When were the assets inherited? - How much was inherited? - Percent ownership for a business that is inherited

Wealth Generated From a Profession (Physician, dentist, lawyer, engineer, entertainer, professional sports….)

- What is the profession, including area of specialty (example: arts – singer, construction – engineer)

- Source of wealth (Example: lawyer who derived wealth form real estate, Dr. running a cline..)

- Estimate of income Wealth Generated From Investments - Where did the source of wealth come from? (example, invested in shares, bonds,

etc.) - What do they currently invest in? (for example, real estate, stock market….) - What is the size of the investment? - Cite notable public transactions if any - What is the client’s role in transaction (example:takes positions, buy companies,

middle man) - Estimated annual income/capital appreciation? - How long has the client been an investor?

Note : This form must be renewed every year.

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“Annexure-D”

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“Annexure-E”

……………….. Branch Details of walk-in/one-off customers in respect of FDD/FTT/PO and others:

Name:

Date of birth: Nationality:

Father’s Name:

Mother’s Name:

Mailing Address:

Permanent Address:

Telephone (Office) #

Mobile #

Telephone (Res.) #

Other Identification:

(ID Card number,

Passport details & TIN etc.)

Other information (if any):

Value of Transaction:

FDD/FTT/PO #

Date: Signature:

Authorized Signature Authorized Signature

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“Annexure-F”

Training on ‘Money Laundering & its Prevention’

Considering the devastating economic, security and social consequences of Money Laundering through Banking channel and having due regard to the importance of Anti-Money Laundering steps; IFIC Bank Ltd. will pursue a training programme consisting of four modules as follows: 1. Module – I : Trainers training on “Money Laundering”. 2. Module – II : Course on Money Laundering. 3. Module – III : Workshops/Seminar on Prevention of Money Laundering. 4. Module – IV : Off the Desk Steps on Prevention of Money Laundering

Module – I : Trainers Training on “Money Laundering & its Prevention” Objectives : The main objectives of the program will be to: : make the participants (designated Officers of the branches/In-charge of

branches) aware about the Money Laundering Prevention Ordinance, 2008.

: help them realize the importance of the Ordinance and the duties and responsibilities vested on the bankers by the Ordinance.

: enable them to acquire required skill to act as trainers at Branch/ Head

Office level.

Outline : Money Laundering Prevention Ordinance, 2008 and its importance.

Bank’s obligation to implement Money Laundering Prevention Ordinance, 2008. Duties and responsibilities of the Officers to strictly follow the various provisions of the Ordinance. Bangladesh Bank and Bank’s guidelines on Prevention of Money Laundering. Procedure to Know Your Customers (KYC) and Business Associates. Internal controls to prevent Money Laundering Communication skill.

Duration : 02 (two) days Level of participants : Manager/ In-charge of Branches/ Designated Officers of all branches/

Head Office. Faculty : Executives/ Officers from Head Office & Branches, Guest speaker(s) from

Bangladesh Bank/ BIBM etc. Methods : Lecture/ Discussion/ Case study etc.

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Module – II : Short Course on “Money Laundering & its Prevention” Objectives : The main objectives of the course will be to: : help the participants understand and appreciate the various provisions

of Money Laundering Prevention Ordinance, 2008. : help them in appreciating the role, duties and responsibilities given to

them by the Ordinance.

: make them understand the various steps, circulars, etc. issued by

Bangladesh Bank, the Bank from time to time.

: enable them to acquire the skill to understand the Know Your Customers (KYC)

Outline : Money Laundering Prevention Ordinance, 2008 and its importance.

Bank’s obligation to implement Money Laundering Prevention Ordinance, 2008. Duties and responsibilities of the Officers to follow the various provisions of the Act. Bank’s guidelines on Prevention of Money Laundering. Procedure to Know Your Customer (KYC) and Business Associates. Internal controls to prevent Money Laundering.

Duration : 02 (two) days. Level of participants : Officers of all branches/ Head Office. Faculty : Executives/ Officers from Head Office & Branches, Guest speaker(s)

from Bangladesh Bank/ BIBM etc. Methods : Lecture/ Discussion/ Case study etc.

Module – III : Workshop/Seminar on “Prevention of Money Laundering” Objectives : The main objective of the Workshop/ Seminar will be to exchange

opinion about the problems of implementation of the various provisions of the Money Laundering Ordinance, 2008 and to find out solutions thereof.

Outline : General discussion on the problems faced by the branches and Head

Office in the implementation of the Ordinance. Cases of Money Laundering so far detected by the Bank and lesson therefrom, recommendations and future course of action.

Duration : 01 (one) day Level of participants : Manager/ In-charge of Branches/Designated Officers of all branches/

Head Office.

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Faculty Executives/Officers from Head Office & Branches, Guest speaker(s) from Bangladesh Bank/ BIBM etc.

Methods : Discussion/ Case study etc.

Module – IV : Off the Desk Steps on ‘Prevention of Money Laundering’ Objectives : The objective of this program will be to educate all Officers about the Consequences Money Laundering and steps undertaken to stop such activates. Outline : Circulation of Bangladesh Bank circulars, Bank circulars, paper

cuttings, write-ups, articles, research papers etc. on the subject. Duration : 01(one) day Level : All Officers Faculty : As above Methods : Discussion/Case study.

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