Professional Documents
Culture Documents
ON
ANTI-MONEY LAUNDERING AND
COMBATING THE FINANCING OF TERRORISM
1- INTRODUCTION
7
Money Laundering is the conversion or transfer of property, knowing that such
property is the proceeds of offence, for the purpose of concealing or disguising the illicit
origin of the property or of helping any person who is involved in the commission of the
offence to evade the legal consequences of his or her action.
Financing of Terrorism shall mean the willful provision of financial or other services
with the intention that such services be used or in the knowledge that they are or may be
used, in full or in part, for the purpose of supporting terrorism, terrorist acts or terrorist
organizations.
Generally, the process of money laundering comprises three stages, during which there
may be numerous transactions that could alert a bank to the money laundering activity:
i- Placement : the physical disposal of benefits of the offence or criminal conduct.
ii- Layering : the separation of benefits of the offence or criminal conduct from
their source by creating layers of financial transactions designed to
disguise the audit trail.
iii- Integration : the provision of apparent legitimacy to benefits of the offence or
criminal conduct. If the layering process succeeds, integration
schemes place the laundered funds back into the economy so that
they re-enter the financial system appearing as normal business
funds.
(2)
1- INTRODUCTION
7
This operating manual is solely aimed at enhancing the full adherence and
ensuring all domestic and international financial transactions of ACLEDA Bank Plc.
are not involved in money laundering or financing of terrorism. More importantly, we
can evade the regulatory sanctions, and maintain good reputation of the bank on a
timely and due basis in a full compliance with the existing policies, and other related
regulations.
The Law on Banking and Financial Institutions of 1999
The Law on the Anti-Money Laundering and Combating the Financing of
Terrorism of March 24, 2007
Prakas on Anti-Money Laundering and Combating the Financing of
Terrorism of May 30, 2008
ACLEDA Bank's policy on Anti-Money Laundering and Combating the
Financing of Terrorism approved by the Board of Directors on October 02,
2009.
To fully comply with the policies and relevant regulations, all personnel of ACLEDA
Bank must follow and implement the following procedures on Anti-Money
Laundering and Combating the Financing of Terrorism.
If you have answered “no” to any of the above, please provide area of business excluded, including
name, location and contact details.
.................................................................................................................................................................
.................................................................................................................................................................
1. Institution Name:
3. Address:
Registered Office:
4. Website address:
5. Contact Name:
Contact Telephone:
Email address:
Do you have a “physical presence” or are you a regulated affiliate of an entity Yes
No
6. with a “physical presence”?
Ownership Structure
0B
10. Please attach a list of the executive and non-executive directors of the main
Board of Directors.
Policies and Procedures
2B
Section A
Do you have a policy and procedures for prevention of money laundering and
11. terrorist financing? If no, when will you expect to have it? Yes
No
........................................................................................................................
If yes, does this policy apply to all of the operations covered by this Yes
No
12.
questionnaire?
If requested, are you prepared to provide ACLEDA BANK Plc. with a copy of Yes
No
13. the policy?
14. Do you verify the identity of all customers prior to providing accounts? Yes No
Please confirm that you provide banking services only to other banks/financial Yes
No
16. institutions with a “physical presence”?
Section B
7B
Do you have an employee training program for prevention of money laundering Yes
No
17. and terrorist financing requiring all staff to undertake training?
Do you have a policy and procedures for independent audit or testing of your Yes
No
18. anti-money laundering compliance?
If so, how frequently are these audits/tests conducted?
................................................................................................................................
Do you have a Money Laundering Reporting Officer responsible for co- Yes
No
19. ordinating / monitoring compliance?
If Yes, Please provide name and address
................................................................................................................................
If no, to any question in Section B please provide comment if applicable.
................................................................................................................................
Reminder: Have you attached lists of beneficial owners (and nominees), your directors and
your highest level of executive management - refer Questions 9 and 10 (if applicable)?
Name :...........................
Title :...........................
Date :........./........./.......
U
If you have answered “no” to any of the above, please provide area of business excluded, including
name, location and contact details.
.................................................................................................................................................................
.................................................................................................................................................................
1 Institution Name:
3 Address:
Registered Office:
Principal place of business:
Location of Headquarters:
4 Website address:
5 Contact Name:
Contact Telephone:
Email address:
Do you have a “physical presence” or are you a regulated affiliate of an entity Yes
No
6 with a “physical presence”?
Section A
Do you have a policy and procedures for prevention of money laundering and
7 terrorist financing? If no, when will you expect to have it? Yes
No
........................................................................................................................
If yes, does this policy comply with the Law and Prakas on Anti-Money Yes
No
8 Laundering and Counter the financing of Terrorism?
If requested, are you prepared to provide ACLEDA BANK Plc. with a copy of Yes
No
9 the policy?
Do you have an employee training program for prevention of money laundering Yes
No
12 and terrorist financing requiring all staff to undertake training?
If so, how frequently?
................................................................................................................................
Do you have a policy and procedures for independent audit or testing of your Yes
No
13 anti-money laundering compliance?
Do you have a Money Laundering Reporting Officer responsible for co- Yes
No
14 ordinating / monitoring compliance?
If "Yes", Please provide name, title, contact number, and address
...............................................................................................................................
...............................................................................................................................
...............................................................................................................................
Name :...........................
Title :...........................
Date :........./........./.......
U
First Verifier
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First Verifier
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First Verifier
AML
Second Verifier
First Verifier
AML
Second Verifier
First Verifier
AML
Second Verifier
First Verifier
AML
Second Verifier
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APPLICATION FOR PURCHASE OF FOREIGN CHEQUES
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Date:
eQ`aHKNnI :
Account Name
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Account No.
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Amount of Cheques
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, AML
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Authorised Signature
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Recommended by: Approved by:
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APPLICATION FOR PURCHASE OF INDIVIDUAL
TRAVELLER CHEQUES MORE THAN $1,000.00 TO $5,000.00
eQ`aHGtifiCn :
Customer Name:
Total:
For Branch
eKarBCUnelaknaykhirJ0b3TanBaNiC9km`
To: Senior Vice President & Head, Trade Finance Division
Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al
Address: ACLEDA Bank, Headquarters
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:
eQ`aHGtifiCn :
Customer Name:
Total:
For Branch
eKarBCUnelaknaykRbtibt1iRbtibt1ikar
To: Senior Vice President & Head, Operation Division
Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al
Address: ACLEDA Bank, Headquarters
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:
eQ`aHGtifiCn :
Customer Name:
Total:
For OPD
eKarBCUnelaknaykhirJ0b3TanBaNiC9km`
To: Senior Vice President & Head, Trade Finance Division
Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al
Address: ACLEDA Bank, Headquarters
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:
eQ`aHGtifiCn :
Customer Name:
Total:
For OPD
eQ`aHKNnI :
Account Name
elxKNnI :
Account No.
TwkRVk'\nmUlb3TanbR>t :
Amount of Cheques
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, AML
ht/elxaGtifiCn
Authorised Signature
sMrab'FnaKar
For Bank's use only
lk&xN@bBa(|lTwkRVk': P7amÔ /p1l'CUnbn8ab'BIVnTijcMnYn,,,,,,,,\f^
Approved for credit* immediately / after...........days.
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Recommended by: Approved by:
AML
Accounts that appear to act as pass through accounts with high volumes of credits
and debits and low average monthly balances.
Customers who wish to maintain a number of trustee or client accounts, which do
not appear consistent with the type of business, including transactions, which
involve nominee names.
The opening by the same person of multiple accounts into which numerous small
deposits are make that in aggregate are not commensurate with the expected income
of the customer.
Any individual or company whose account shows no normal personnel banking or
business related activities, but is used to receive or disburse large sums which have
no obvious purpose or relationship to the account holder and/or his business (e.g. a
substantial increase in turnover on an account).
Reluctance to provide normal information when opening and account, attempts to
reduce the level of information provided to the minimum or providing information
that is difficult or expensive for banks and financial institutions to verify.
Customers who appear to have accounts with several bank and micro finance
institutions within the same locality, but choose to consolidate monies from such
accounts on regular basis for onward transmission of the funds to another 3rd party
account.
Paying in large third party cheques endorsed in favour of the customer.
An inactive account containing a minimal sum suddenly receives a deposit or series
of deposits followed by daily cash withdrawals that continue until the transferred
sum has been removed.
Greater use of safe deposit facilities, which does not commensurate with the
customer profile.
Customer avoiding contact with employees of banks and financial institutions for
transaction.
Substantial increases in deposits of cash or negotiable instrument by a professional
firm or company, using client accounts or in-house company, or trust accounts,
especially if the deposits are promptly transferred between other client's company
and trust accounts.
Customers who decline to provide information that in normal circumstances would
make the customer eligible for credit or for other banking services that would be
regarded as valuable.
Large number of individuals making payment into the same account without an
adequate explanation.
High velocity of funds through an account, i.e. low beginning and ending daily
balances, which do not reflect the large volume of dollars flowing through an
account.
An account opened in the name of a money-changer that receives structured deposits
(e.g. constant amount of deposit regularly).
An account operated in the name of an off-shore company with structured
movement of funds.
6- Wire transfer
U
Deposits are followed within a short time by wire transfers of funds, particularly to
or through a location of specific concern (for example, countries designated by
national authorities, FATF non-cooperative countries and territories, etc.)
A business account through which a large number of incoming or outgoing wire
transfers take place and for which there appears to be no logical business or other
economic purpose, particularly when this activity is to, through or from locations of
specific concern.
A customer obtains a credit instrument or engages in commercial financial
transactions involving movement of funds to for from locations of specific concern
when there appears to be no logical business reasons for dealing with those
locations.
NATURAL PERSONS
10B
Reporting Bank:
18B
Name:
Branch:
Address:
Telephone:
Name:
Designation:
Report Reference:
Name:
ID/Passport No:
Birth Date:
Nationality:
Address:
Telephone:
Occupation:
Employment Details:
Employer's Name:
Address:
Telephone:
Type of A/C:
As at date:
Suspicious Transaction(s)
Amount
19BU Description of Transaction
(Dr/Cr) Date (E.g. Funds transfer, source of funds, destination, etc)
________________________________
(Signature of reporting officer)
Date:
COPERATIONS
12B
Reporting Bank:
Name:
Branch:
Address:
Telephone:
Name:
Designation:
Report Reference:
Contact Officer: (If different
from Reporting Officer)
Designation:
Customer's Particulars:
Name:
Country of Registration:
Registration Date:
Registration No.:
Address:
Telephone:
Name of CEO
As At date:
1- Name:
Birth Date:
ID/Passport No.:
Home Address:
**The reporting officer of the bank shall provide data on other authorised signatories, if any
Suspicious Transaction(s)
Amount Description of Transaction
Date
(Dr/Cr) (E.g. Funds transfer, source of funds, destination, etc)
________________________________
(Signature of reporting officer)
Date:
Reporting Bank:
Name:
Branch:
Address:
Telephone:
Name:
Designation:
Report Reference:
Contact Officer: (If different
from Reporting Officer)
Designation:
Customer's Particulars:
Name:
Country of Registration:
Registration Date:
Registration No.:
Address:
Telephone:
Name of Partnerships / Sole
proprietors / Trustees or
equivalent:
Business Relationship(s) with Customer
6B
Type of A/c:
As At date:
1- Name:
Birth Date:
Nationality:
ID/Passport No.:
Home Address:
Occupation:
Employer's Name:
(If applicable)
Address:
**The reporting officer of the bank shall provide data on other authorised signatories, if any
Suspicious Transaction(s)
Amount Description of Transaction
(Dr/Cr) Date (E.g. Funds transfer, source of funds, destination, etc)
________________________________
(Signature of reporting officer)
Date: