BANK OF INDIA INTER OFFICE MEMORANDUM Make Compliance Our Culture FROM ITo The Chief Executive | Authorised Dealer Branches US Center | India/Overseas 1 NY: COMP: VVP:179 Date: October 15, 2015 SUSPECTED MONEY LANUDERING PREVENTIVE MEASURES Preventing Money Laundering is always a Top Priority Area for any financial Institution in the present era. Our Bank is also having Robust BSA/AML policy guidelines in place which addresses the issue in depth. However, effective implementation of the policy and procedures can only safeguard the imagelinterest of the bank. Our Head Office has recently communicated & reiterated the importance & requirements of error free wire transfer vide Circular letter 2015-16-114 dated October 3, 2015. As we know that Money Laundering Risk Assessment essentially consists of four key elements viz. Threats, Vulnerability Consequence & Risk. Understanding & Mitigating Threat Environment & Vulnerabilities should always be our primary concern to avoid further vicious consequences and protect our Bank from reputation risk apart from financial implication, The matter has once again taken a serious mode when we fecently heard about the suspected money laundering activities from New Delhi Area._Itis reported that the money was sent to Hong Kong for import of Cashew & Rice and Hong Kong is not a big exporter of Agro Products. _ It clearly means that Due Diligence was not up to the mark and it is a failure on part of implementation (of laid down policy & procedure) at branch level. We are also well aware that one of our Indian Bank has been penalized by Hong Kong Government for violation of Anli Money Laundering Rules in the Recent Past and in depth investigation is going on in many banks from the authority concerned. On the above backdrop,we reiterate the importance of various terms viz. Know Your Customer, Know Your Customers Customer, Customer Due Diligence & Enhanced Due Diligence and expect strict observance. Branches should always try to ascertain/confirm, 1) the source of funds 2) the genuineness of remittance and 3) whether the volume/amount of remittance ‘commensurate with the business and activity of customer.All the branches are therefore advised to meticulously follow the guidelines conveyed vide above referred Head Office circular letter before remitting any wire transfer outside branch/country. Kindly note that wire transfers not supported by necessary information as stated in the above referred circular letter will not be entertained henceforth. wee (PK Pattanaik) Chief Executive cc: The General Manager — International Division The General Manager — Compliance Department The General Manager — Audit Department Mr. Govindrajan -- Asst. General Manager — International Division Head of the Forex Department /Division -- Correspondent Banks — for information please. of india