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Key Areas Sr#

Banking Operations & Business KYC_AML Policy and Procedures.

Banking Operations & Business 1


Banking Operations & Business KYC/AML Measures at the time of Account Opening
Banking Operations & Business 3

Banking Operations & Business 4

Banking Operations & Business 5

Banking Operations & Business 6

Banking Operations & Business 7

Banking Operations & Business 8

Banking Operations & Business 9

Banking Operations & Business 10

Banking Operations & Business 11

Banking Operations & Business 12

Banking Operations & Business 13

Banking Operations & Business 14

Banking Operations & Business 15

Banking Operations & Business 16

Banking Operations & Business 17


Banking Operations & Business KYC_AML Monitoring
Banking Operations & Business 18
Banking Operations & Business 19
Banking Operations & Business 20
Banking Operations & Business 21
Banking Operations & Business 22

Banking Operations & Business 23

Banking Operations & Business 24

Banking Operations & Business 25

Banking Operations & Business 26

Banking Operations & Business 27

Reporting of CTR/STR

Banking Operations & Business 28

Banking Operations & Business 29


Banking Operations & Business 30
Banking Operations & Business Account Maintenance
Banking Operations & Business 31
Banking Operations & Business 32
Banking Operations & Business 33
Banking Operations & Business 34

Banking Operations & Business 35

Banking Operations & Business 36

Banking Operations & Business 37

Banking Operations & Business 38

Banking Operations & Business 39

Banking Operations & Business 40

Banking Operations & Business 41

Banking Operations & Business 42


Banking Operations & Business Asaan Accounts Operations
Banking Operations & Business 43
Banking Operations & Business 44
Banking Operations & Business 45
Banking Operations & Business 46

Banking Operations & Business 47


Banking Operations & Business High Risk Accounts:

Banking Operations & Business 47

Banking Operations & Business 48

Banking Operations & Business 49

Banking Operations & Business 50


Banking Operations & Business Cash Counter & Vault Management

Banking Operations & Business 58

Banking Operations & Business 59

Banking Operations & Business 60

Banking Operations & Business 61

Banking Operations & Business 62

Banking Operations & Business 63

Banking Operations & Business 64

Banking Operations & Business 65


Banking Operations & Business 66
Banking Operations & Business 67

Banking Operations & Business 68


Banking Operations & Business Zakat, Tax & Charges
Banking Operations & Business 70
Banking Operations & Business 71
Banking Operations & Business 72

Banking Operations & Business 73


Banking Operations & Business 74

Banking Operations & Business 75


Banking Operations & Business 76
Banking Operations & Business Remmitence
Banking Operations & Business 77
Banking Operations & Business 78

Banking Operations & Business 79


Banking Operations & Business Cheque Books
Banking Operations & Business 80
Banking Operations & Business 81

Banking Operations & Business 82

Banking Operations & Business 83

Banking Operations & Business 84

Banking Operations & Business 85

Banking Operations & Business 86


Banking Operations & Business 87
Banking Operations & Business ATM Operations.
Banking Operations & Business 118
Banking Operations & Business 119
Banking Operations & Business 120
Banking Operations & Business 121
Banking Operations & Business 122
Banking Operations & Business 123
Banking Operations & Business 124
Banking Operations & Business 125
Banking Operations & Business 126
Advances Advances_ Loans
Advances 51

Advances 52

Advances 53

Advances 54

Advances 55
Advances 56

Advances 57

Advances 58
Service Quality Service Quality
Service Quality 95

Service Quality 96

Service Quality 97

Service Quality 98

Service Quality 99
Service Quality 100
Service Quality 101

Service Quality 102

Service Quality 103

Service Quality 104

Service Quality 105

Service Quality 106


Service Quality 107
Service Quality 108
Service Quality 109
Service Quality 110
Service Quality 111
Gernal Area Adimin & Security
Gernal Area 88

Gernal Area 89

Gernal Area 90

Gernal Area 91

Gernal Area 92
Gernal Area 93
Gernal Area 94
Gernal Area Miscellaneous

Gernal Area 112

Gernal Area 113


Gernal Area 114
Gernal Area 116
Gernal Area 117

Sr#
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2
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4
Description Score

KYC_AML Policy and Procedures. 100


Whether KYC/AML policy and procedures are communicated down the line to the new
100
inducted branch officials and staf has good knowledge of the same?
KYC/AML Measures at the time of Account Opening 100
Whether it is ensured that branch obtain updated copy of CNIC/SNIC/NICOP/Passport etc. at
10
the time of account opening?
Whether it is ensured that the updated Consolidated List(negative list) UNSC is accessible
down the line in branch & branch screen each customer from UNSC saction or any other list 10
share by the Head office before account opening?
Whether it is ensured that branch obtain and affix photo on AOF & SS card where customer
5
has thumb impression or shaky signatures?
Whether it is ensured that before opening of accounts or starting operation in the accounts,
10
branch verify CNIC /NICOP/ POC from NADRA Verisys?
Whether it is ensured that before opening of account branch is in practice to obtain NADRA
10
Verisys through Boi-matric?
In case of Nadra verification is not done on same day whether branch complete the
verification within five "5" working days for regular account and within 3 working days for 5
Asaan A/C from the date of account opening?
Whether it is ensured that branch did not allow debit Transaction until Nadra verification is
5
completed?
Whether it is ensured accounts are not opened with suspected,Fake and cancelled CNIC's? 5

Whether it is branch obtain CNIC copy of customer blood relative where Nadra remarks
5
required Further proof of customer address?
Whether it is ensured that accounts are not opened on expired CNIC , without NADRA token? 5
In case where accounts are opened with Nadra Token, whether branch obtain copy of updated
5
CNIC within 90 days from the date of account opening?
Whether it is ensured that copy of CNIC attached with the A.O.F are dully attested/ Original
5
seen by the relevant branch official?
In case of a salaried person, whether it is ensured that branch obtain, in addition to CNIC, an
attested copy of his service card, or any other acceptable evidence of service, including, but 5
not limited to a certificate from the employer.
In case the CNIC does not contain a photograph, Whether it is ensured that branch obtain
following:
(i) A duly attested copy of either driving license, service card, Nikkah Name, birth certificate,
Educational degree/certificate, pension book, insurance certificate. 5
(ii) A photograph duly attested by gazetted officer/Nazim/Administrator/bank officer.
(iii) A copy of CNIC without photograph duly attested by the same person who attested the
photograph.
Whether it is ensured that branch not allow opening of anonymous or numbered accounts or
10
accounts in the names of fictitious persons?
KYC_AML Monitoring 100
Whether branch Manager review KYC/AML Mointoring report for Rs.0.5 Million or above
10
on daily basis?
Whether branch Manager review log change report on daily basis? 10
Whether branch Manager review KYC breaches on monthly basis and revise/update customer
10
KYC/CDD profile where needed.
Whether it is ensured that KYC/ of Top 100 depositors is updated? 10
Whether it is ensured that Personal / individual accounts are not being used for charity
10
purpose / collection of donation.

Whether the branch ensure that the documents, data or information collected under CDD
10
process is kept up-to-date and relevant by undertaking reviews of existing records?

Whether branch take all reasonable measures to verify the identity of the beneficial owner
10
during the course of establishing a business relationship or conducting transactions.

Whether it is ensured that Personal / individual accounts are not being used for large number
10
of business transactions?

Whether branch obtain copy of CNIC and Walk-in-customer form (regardless of threshold)
10
for online deposits/fund transfers/Withdrawal conducted by walk-in-customer or third party?

Whether it is ensured that branch obtain copy of CNIC from walk in customer for cash
10
transactions above Rupees one million?
Reporting of CTR/STR 100

Whether it is ensured that All cash transactions equal to Rs. 2 million or above are being
25
reported to compliance department for onward submission to Financial Mointoring Unit?

Whether branch report suspicious transactions to compliance department for onward


50
submission to Financial Mointoring ?
Whether it is ensured that branch is not involve in structuring? 25
Account Maintenance 100
Whether it is ensured that account opening form, SSC are properly filled,contains all
10
necessary information and authorized by the branch Manager,?
Whether it is ensured that branch upload SS cards on regular basis. 5
Whether it is ensured that no single account is opened without initial deposit. 5
Whether it is ensured that the Letter of thanks is dispatched on very next working day to
10
verify the validity of customer's address other than asaan accounts?
Whether it is ensured that term and conditions are provided to customers at the time of
10
account opeing with proper acknowledgement of customer?
Whether branch obtain fresh/valid copy of Customer's CNIC at the time of dormancy removal
10
with customer request form?
Whether it is ensured that Dormant/inoperative accounts are reactivated and transactions are
5
allowed after proper verification & approval by C.P.U?

Whether it is ensured that branch not give statement of accounts to any unauthorized person,
deliver statement of account, where an account has become dormant as per bank’s approved
policy, till such time the account is reactivated or new address is made available/obtained, 10
deduct “Service Charges” from the Dormant accounts; and charge amount mentioned in the
Schedule of Charges for each duplicate/ additional statement of account?

Whether branch makes efforts to obtain fresh copy of CNIC of those customers who's CNIC's
10
are expired?( IS MIS maintained for all customers ID card expiry)
Whether amount in the deceased accounts is paid to the beneficiaries after obtain succession
10
certificate issued by the Court ( Where applicable)
Whether it is ensured that branch close accounts after proper authorization/account closing
10
request/memo etc.. and records of closed accounts is available in the branch?
Whether branch ensure the clousre of duplicate account. And follow the guidelines issued by
5
the Head Office?
Asaan Accounts Operations 100
Whether it is ensured that branch provides asaan account opening facility to low income
20
people?
Whether it is ensured that branch did not open Asaan Accounts for other than indvidual
20
account ie Business/Communinty/Local Organization accounts ?
Whether it is ensured that branch open all assan accounts under "Low" risk category? 20
Whether it is ensured that branch does not open Asaan Accounts for the customer having
20
Expected Monthly turnovers of Rs.0.5 M?
Whether terms and condition of the asaan account openeing forms are provided to the
20
customers?
High Risk Accounts: 100

Whether it is ensured that Branch obtain prior Approval from Head Banking Operation for
High Risk Accounts list of High Risk Accounts is provided in KYC/AML procedures. 25

Whether it is ensured that branch conduct Enhance due dillegence at the time of account
25
opening and during the courese of transactions where applicable.
Whether it is ensured that branch obtain approval from the bank’s senior management to
establish or continue business relations where the customer or a beneficial owner is a PEP or 25
subsequently becomes a PEP;
Whether branch ensured that Government accounts are not opened in personal names of
25
individuals?
Cash Counter & Vault Management 100
Whether keys to access strong room and vault are in possession of Teller and BOI/BM
Further, list of names of custodians and back up custodians has been maintained at the 10
branch?
Whether cash found sorted (Sorted, Unsorted, Re-issuable, Soiled, Defective) as per
instructions with proper record (statement) thereof and affixing the relevant stamp on it. 5
Further, branch issue only sorted cash to general public?
Whether any transfer of keys from one custodian to another is authorized by BM and entry for
same is made in the key register and none of key holders should have access to the other key 10
holder's keys even at different times?
Whether physical cash kept in vault and ensure that it agrees with the cash balance book &
5
General Ledger?
Whether Ultra Voliat or Fake note detection machine / Verification Marker is available in the
10
branch?
Whether it is ensured that all cash transactions, cash receipt/payment is performed in cash
10
counter and recorded in the system on real time basis?
Whether it is ensured that Branch has not been using strong room / vault for other purposes
10
like record room, kitchen, stationery store etc.?
Whether it is ensured that branch have been preparing and maintaining the prescribed
10
statement of daily closing cash balances?
Whether it is ensured that vault keys are not in custody of a single person? 10
Whether it is ensured that vault keys are not in the custody of employee who has resigned and
10
serving notice period
Whether it is ensured that at the end of day if cash exceeds branch insurance limit it is
10
communicated to the concerned officer for insurance coverage?
Zakat, Tax & Charges 100

Whether WHT_FED Rates are updated in the system and properly dedected by the Branch 20

Whetehr WHT tax is correctly deducted for Filler & non filer. 10
Whether it is ensured that no Extra charges are deducted from the customer account? Or
15
charges Deducted from customer account due to banks own mistake?
Whether it is ensured that charges deducted from the customer accounts are reflected in
15
his/her bank statement of account?
Whether it is ensured that charges are properly deducted from the customer account as per
10
current SOC's.
Whether Copy Acknowledgment of CZ-50 form for Saving accounts and TDR is available in
15
the branch?
Whether Zakat deducted due to system issue is reversed to the customer account. 15
Remmitence 100
Whether it is ensured that inward/outward clearing register is updated? 33
Whether it is ensured that branch did not issue Bankers cheques of more then Rs. 50,000
33
without instrument I.e cheque.
Whether Cheque return Register is updated and cheques are returned to the customer with
34
proper acknowledgement/cheque return memo?
Cheque Books 100
Whether it is ensured that branch lodge cheque book request on the same day when customer
10
is requested.
Wheteher it is ensured that cheques book register is updated. 15

Whether it is ensured that cheque books issued to customers after getting acknowledgment
10
with proper authorization and at the same time it is activated in the system?

Whether Cheque books are shredded within defined time period as define in operations
15
manual?
Whether it is ensured that Unused / un delivered stock of cheque books is not in the custody
15
of a single officer?
Whether it is ensured that cheques lost/stolen are updated in the system and customer request
10
is available in the branch?
Whether it is ensured that unused cheque books are collected from the customer at the time of
15
closing of account and same is marked cancelled, attached with the AOF?
Whether it is ensured that post dated or stale cheques are not accepted? 10
ATM Operations. 100
Whether it is ensured that branch is in practice to balance the ATM on daily basis? 10
Whether it is ensured that branch maintained the proper register of Captured Cards? 10
Whether it is ensured that branch replenish the ATM with sorted cash? 10
Whether it is ensured that ATM has UPS backup in case of power failuer? 10
Whether it is ensured that branch returned the captured cards of customers after proper
15
verification?
Whether it is ensured that ATM is operated by two Key custodian? 10
Whether it is ensured that ATM Combination code is under sealed envelop and the same is
10
placed in vault?
Whether it is ensured that Compliant / Suggetion boxes are available in ATM cabin? 15
Whether it is ensured that 24/7 helpline is installed in ATM cabin to resolve day to day
10
operational issues?
Advances_ Loans 100
Whether Terms and Conditions (Finance Agreements) of loans are communicated to the
15
customers and properly acknowledged
Whether it is ensured that branch provides repayment schedules to all borrowers at the time of
10
disbursment with proper acknowledgement.
Whether loan application forms are properly filled and all allied documents are properly
15
attached?
Whether branch obtained the eCIB of each customer before disbursement of loan to customer
10
and obtain fresh eCIB of repeated loans.?
Whether it is ensured that record of pre and post disbursement verifications of BM/OM/RM &
15
CO is maintained as required under credit manual?
Whether branch ensure proper handing/taking over of portfolio in case of
removal/termination/transfer/resignation/permanent injury/death of a MFO and record the all 10
particulars of handing/taking of portfolio on standard format?
Whether it is ensured that key fact sheet is provided to the customers with proper
10
acknowledgement and branch maintin its record?
Whether Financial literacy Booklet is available in the branch and also given to borrowers 15

Service Quality 100


Does all staff reach office before banking time and ready for all banking services at scheduled
5
time?
Are proper signage poster, hangings, signboard displayed and are in straight, clean &
5
presentable form?
Does staff sitting arrangement is well organized for optimal use of space while sparing ample
5
space to client areas / client meeting rooms?
Does Staff desk bear only relevant papers / documents and after office hours’ keep security
5
documents under lock & key?
Is unnecessary pasting of notices are made on walls and overcrowding the material in branch /
5
unit?
Does SBP license properly framed and displaced at prominent place in branch / unit? 5
Are Back up arrangement like UPS & Generator available in the branch & are in working
5
condition with sufficient backup time?
Does the staff attend phone calls promptly? With proper greeting and resolving customer
5
queries in an efficient manner?
Does the branch staff possess adequate knowledge of bank products & sound enough to attend
10
customer queries adequately?
Are senior citizens (Old age) given priority based on humanitarian grounds (separate counter
10
if any)?

Is turn around time defined in the branch? And customer are dealt without any delay at
5
counter/desk? What is Maximum time taken for dealing a customer taken by branch official?

Is there any undue delay in dealing customer queries ? BM/BOI involved in the pertaining
5
issue?
Does the staff behave in orderly manner and don't use offensive language in branch? 5
Does the staff smoke in branch during working hours? 5
Are customers’ complaints timely resolved by Branch Manager /BOM? 5
Is follow up for Loan recovery are made as per ethical standards set in Credit Manuals? 5
Is turnaround time for loan processing is observed or are there any cases where undue delay
10
was noted?
Adimin & Security 100
Whether branch is equipped with latest security equipment e.g. CCTV cameras, Burgular
15
alarm system and Armed Guard are available 24 hrs in the branch?
Whether CCTVcovers the vault operations, Cash Counter, Main Banking Hall and Gold
15
valuation is under coverage?
Whether Compliant Box is available in the branch to facilitate the customers in lodging
complaints, and is located at place which is easily identifiable and accessible to all customers, 15
e.g. on a main customer service counter?
Whether branch keep the loan documents in strong room/ vault or fire proof steel file
15
cabinets/almirah as required?
Whether it is ensured that the fixed assets moved from one branch/office to another
15
branch/office is reported to HO?
Whether branch is comply with the service quality management process 10
Whether SOD/EOD is properly and timely performed by the branch? 15
Miscellaneous 100

Whether it is ensured that the terms and conditions of the banking services are
a) written in English and Urdu languages;
20
b) provided at the time of or before the contract for an ongoing banking service is made
except where it is impracticable to do so, the same be provided later on as early as possible.

Whether it is ensured that branch staff mark their attendece in branch attendence register 20

Whetehr branch staff mark their leaves in ESS? 20


whether Updated banks policies and procedures are available in the branch 20
Whether it is ensured that account mainaitned with other banks are reconcilied ? 20

Summary
Area of Compliance Risk Risk Score
Banking Operations & Business 275
Adavnces 100
Service Quality 100
General Area 100
Total Score
Branch Comments if
Weight/Sub-Weight Compliance Status Risk Score
any

15 Non Compliant 1 15

15 Non Compliant 1 15

50 15 50

5 Non Compliant 1 5

5 Non Compliant 1 5

2.5 Non Compliant 1 2.5

5 Non Compliant 1 5

5 Non Compliant 1 5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

5 Non Compliant 1 5

25 10 25

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5


2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

10 Compliant 3

2.5 Non Compliant 1 2.5

5 Non Compliant 1 5

2.5 Non Compliant 1 2.5


25 12 25

2.5 Non Compliant 1 2.5

1.25 Non Compliant 1 1.25


1.25 Non Compliant 1 1.25

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

1.25 Non Compliant 1 1.25

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

2.5 Non Compliant 1 2.5

1.25 Non Compliant 1 1.25

25 5 25

5 Non Compliant 1 5
5 Non Compliant 1 5

5 Non Compliant 1 5

5 Non Compliant 1 5

5 Non Compliant 1 5

25 4 25

6.25 Non Compliant 1 6.25

6.25 Non Compliant 1 6.25

6.25 Non Compliant 1 6.25

6.25 Non Compliant 1 6.25

10 0 0

1 Compliant 0 0

0.5 Compliant 0 0

1 Compliant 0 0

0.5 Compliant 0 0

1 Compliant 0 0

1 Compliant 0 0

1 Compliant 0 0

1 Compliant 0 0

1 Compliant 0 0

1 Compliant 0 0

1 Compliant 0 0

25 0 0

5 Compliant 0 0

2.5 Compliant 0 0

3.75 Compliant 0 0

3.75 Compliant 0 0
2.5 Compliant 0 0

3.75 Compliant 0 0

3.75 Compliant 0 0
25 0 0
8.25 Compliant 0 0

8.25 Compliant 0 0

8.5 Compliant 0 0

25 0 0

2.5 Compliant 0 0

3.75 Compliant 0 0

2.5 Compliant 0 0

3.75 Compliant 0 0

3.75 Compliant 0 0

2.5 Compliant 0 0

3.75 Compliant 0 0

2.5 Compliant 0 0
25 0 0
2.5 Compliant 0 0
2.5 Compliant 0 0
2.5 Compliant 0 0
2.5 Compliant 0 0

3.75 Compliant 0 0

2.5 Compliant 0 0

2.5 Compliant 0 0

3.75 Compliant 0 0

2.5 Compliant 0 0

100 Compliant 0 0

15 Compliant 0 0

10 Compliant 0 0

15 Compliant 0 0

10 Compliant 0 0

15 Compliant 0 0
10 Compliant 0 0

10 Compliant 0 0

15 Compliant 0 0

100 10 62.5

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5

5 Non Compliant 1 5

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5

10 Non Compliant 1 10

10 Non Compliant 1 10

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5

5 Pertially - High Ins 0.5 2.5


5 Pertially - High Ins 0.5 2.5
5 Pertially - High Ins 0.5 2.5
5 Pertially - High Ins 0.5 2.5

10 Pertially - High Ins 0.5 5

50 Compliant 0 0

7.5 Compliant 0 0

7.5 Compliant 0 0

7.5 Compliant 0 0

7.5 Compliant 0 0

7.5 Compliant 0 0

5 Compliant 0 0
7.5 Compliant 0 0
50 Compliant 0 0

10 Compliant 0 0

10 Compliant 0 0

10 Compliant 0 0
10 Compliant 0 0
10 Compliant 0 0

Risk Score Percentage Risk Level


165 45% Medium
0 0% Very Low
62.5 63% High
0 0% Very Low
Very Low

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