Revised Compliance & KYC AML

COMPLIANCE & KYC/AML POLICY
Prepared by: Compliance Division

Approved in BOD meeting held dated August 29, 2016
1
Revision History
Prepared on: July 2009
1st Updated in: April 2010
2nd Updated in: March 2013
3rd Updated in: November 2013
4th Updated in: June 2016
2
Approval Sheet
3
TABLE OF CONTENTS
SECTION CONTENTS PAGE

NO.
A COMPLIANCE POLICY 6-9
1. Introduction- What is Compliance

2. Purpose
3. Objectives
4. Role & Scope of Compliance Function
5. Role of Board of Directors (BOD) & Senior Management
6. Maintenance and updating of the Compliance Policy
7. Role & Responsibilities/Regulatory Requirement of Compliance
Officers
8. Reporting Lines
9. Authorities & Independence of Compliance
10. Relationship with Internal Audit & Regulatory Bodies
11. Framework to Follow
12. Compliance Testing for SBP/Regulatory Requirements
13. Applicability on Banks Subsidiaries/Associates
B KNOW YOUR CUSTOMER/ANTI MONEY LAUNDERING POLICY 10-33
1. Objectives
2. Purpose
3. Definition of Money Laundering
3.1 Placement
3.2 Layering
3.3 Integration
4. Scope
5. Responsibilities
6. AML & KYC General Policies
7. Account Opening & Customer Profiling (KYC/CDD)
8. Customer Due Diligence
8.1 Bank would do due diligence when
9. Risk Categorization
10. Timing of Verification
11. Enhanced Due Diligence
11.1 Third Party Mandate Holders
11.2 Use of Personal Accounts for Business Purposes
11. 3 Housewife Accounts
12. Simplified Due Diligence (SDD)
13. CDD Measures for Occasional Customers/Walk-in Customers and
Online Transactions
13.1 Transactions with non-account holders
13.2 Transactions made by Non- account holders on behalf of Customer
account
14. Account of Politically Exposed Persons (PEPs)
15.Accounts of NGOs/NPOs/Trusts/Societies/Clubs/Associations/Charities
16. Foreign Currency Account- Maintenance & Monitoring
16.1 Individual Accounts- Opening Maintenance and Monitoring
16.2 Entity Accounts- Opening Maintenance and Monitoring
4
17. Review and Monitoring of Transactions

17.1 Self-Monitoring
17.2 Direct Monitoring of Daily Transactions by Compliance Division
17.3 Quarterly Compliance Certificate by Branches
17.4 Reporting of Transactions
17.5 Updating Customer Profile
18. Record Keeping
19. Correspondent Banking
20. Wire Transfers/ Fund Transfer
21. Trade Finance Transaction & Related AML Risk
21. 1 Screening of Transaction
21.2 Sanctioned Countries
21.3 Review & Monitoring- Trade Related Activities & Remittance
(Commercial & Home)
22. Advances- Granting Loans/Extending Facilities & Due Diligence
22.1 Suspicious Activity in Credit Transactions
23. Hold Mail Accounts
24. High Risk Customers
25. Unacceptable Customers
26. Employee Due Diligence
27. Review of Products and Services
28. Tax Evasion
29. Tipping of
30. AML Training and Awareness
31. Audit
32. Insider Trading
Annexure Annex-A KYC Form Individual/Joint Account 34-65
Annex-B- KYC Form Business Account
Annex-C- Customer Risk Profiling Form
Annex-D- Guide for Risk Profiling
Annex-E- Rules for filling Risk Profiling Form
Annex-F- EDD Form
Annex-G- Examples of suspicious transactions
Annex-H Key Definitions- Meaning & Interpretation
Annex-I- Minimum Documents to be obtained from various type of

customers/account holders under AML/CFT regulations
Annex-J-Specific High Risk Elements and Recommendation for EDD
Annex-K- General High Risk Scenarios/Factors
Annex-L -General Low Risk Scenarios/Factors
5
SECTION-A COMPLIANCE POLICY
1) Introduction-What is Compliance
Compliance means Respecting and adhering to all the regulations and supervisory
expectations
relevant to a financial institution. Compliance is concerned with the legality and integrity with
which a business is conducted throughout the Bank. In other words, compliance within the bank
is
to ensure that the bank conducts its business with full regards to all applicable regulatory
requirements and at the highest ethical standards. Good compliance can enhance reputation
through improved services and efficient implementation of new business initiatives.
Non Compliance with regulations can create a negative image and expose the bank to punitive
actions by the regulators. Therefore, non-compliance can lead towards reputational and
regulatory
risk.
2) Purpose:
The purpose of this policy is to outline objectives of compliance policy, role of compliance
function, definition of compliance, roles and responsibilities of compliance officers, reporting
line,
independence of compliance function, relationship with internal audit & regulatory bodies, and
requirements of SBP & other relevant laws & regulations.
3) Objectives:
Following are the main objectives of the compliance policy:

Ensuring Banks compliance to all the relevant laws and regulations
Ensuring that the Banks business is conducted with highest levels of integrity and ethical
standards
4) Role and Scope of Compliance Function
The Compliance function is an integral part of internal control. The role of compliance function is
to advise Senior Management on compliance of rules and regulations; provide guidance in this
respect throughout the organization. Identify, measure and assess compliance risk along with
monitoring, testing and reporting at appropriate levels.
It is to be understood that compliance is not a function merely confined to the Compliance

Division
rather it is the duty of each employee of the Bank to ensure compliance with all the internal
/external directives/laws. Accordingly, every staf is responsible for the identification and
reporting
of non-compliance with regulations for his/her area of activity. The simple principle is that staf
must know and remain within the law and comply with internal policies and procedures, which
have been developed to ensure that a satisfactory system of internal controls is in place to
attain the
business objectives. All staf must keep themselves abreast of the requirements and ensure
compliance with aspects related to their work. Staf must never act in a manner that can be
detrimental
5) to the
Role of Board of Banks reputation.
Directors (BOD) & Senior Management
The Banks Board of Directors, being the apex body is responsible for ensuring that an
appropriate
policy is in place to manage the banks compliance risk. The Board will oversee the
implementation of the policy, ensuring that compliance issues are resolved efectively and
expeditiously by senior management with the assistance of the compliance function.
The Banks senior management is responsible for the efective management of the banks
compliance risk and reporting of any compliance failure to Board of Directors on regular basis.
The responsibility of senior management is to ensure that the compliance policy entails
responsibility for ensuring that appropriate remedial or disciplinary action are taken if breaches
are
identified. Moreover, senior management will also be responsible to oversee if sufficient
resources
are provided to the Compliance Division in order to smoothly discharge its responsibilities.
6) Maintenance and Updating of the Compliance Policy
The basic responsibility of maintaining and updating this policy resides with the Head of
Compliance & Control, The review and updating of this policy shall be an on-going
process to ensure continuous alignment of the Banks businesses with the Bank-wide
strategy and the internal and external dynamics in which the Bank operates. Such
factors
shall include the developments, changes and trends required by laws applicable within
the

banking industry.
The Board of Directors is the approving authority. The President & CEO shall be
authorized to allow interim approval of any proposed changes in this policy and their
implementation, only in cases where the changes do not require any material
amendments
to the bank-wide strategy and are required to be efected promptly. However, any such
changes shall be subject to subsequent ratification by the Board of Directors.
As a policy, this document, in its entirety, shall be reviewed and updated, after every two
years since the last review date. However, in case of any internal/ external change the
policy will be reviewed and updated earlier.
7) Roles and Responsibilities/ Regulatory Requirement of Compliance Officers
The role and responsibilities of Compliance Officers are governed by Regulation G-1 (D) of
Prudential Regulations for Corporate and Commercial Banking. Compliance Division at SMBL
has been entrusted with the following responsibilities:
Ensuring Compliance relating to

(a) SBP Prudential Regulations.
(b) Relevant provisions of existing laws and regulations.
(c) Guidelines for KYC.
(d) Anti money laundering laws and regulations.
(e) Timely submission of accurate data / returns to regulator and other agencies.
(f) Monitor and report suspicious transactions to President / Chief Executive Officer of
the bank and other related agencies.
Receipt of all SBP Circulars and ensuring circulation to relevant divisions/functions and
compliance thereof,
Compliance of the directives of the Board/ President & CEO,
Conducting training for the staf at all levels during branch reviews/visits on compliance issues
especially on KYC and AML,
Reviewing bank wide policies/SOPs and other documents ensuring compliance with regulatory
requirements and best industry practices.
The Compliance Officers will (i) serve as a contact point between President/Chief Executive
Officer and senior management, with regard to functioning of the compliance program (ii)
provide
assistance to branches and other departments of the bank on Compliance related matters and
issues,
and (iii) act as liaison with State Bank of Pakistan concerning the issues related to compliance.
In order to discharge its aforementioned responsibilities efectively, Compliance Division will

perform the following functions to proactively manage the compliance risk;
Provide guidance to Divisional/ Departmental Heads ensuring that their respective
policy/procedure manuals and SOPs are in line with regulatory requirements and sufficiently
address internal control requirements;
Assist the management in identifying and assessing potential compliance issues regarding
new
products/ business development;
Provide guidance, advice and educate the staf on compliance issues whenever required;
Monitor Compliance by:
o Performing sufficient and representative compliance testing, including post checks;
o Making inquiries into compliance incidents, and carrying out further investigations as
appropriate;
Undertake of-site reviews at appropriate frequencies to assess compliance of regulatory rules
and customers activities against their respective KYCs. Further, On-Site visits to branches
shall be conducted by Regional Compliance Unit as per their approved plan;
Maintain regular liaison with Internal Audit Division and review reports from internal and
external auditors/regulatory agencies in order to ensure that the activities of compliance
function remain relevant to and address changing requirements;
Use the of-site and on-site reviews to assess the training needs based on which training
programs will be developed. Records of the training conducted by Compliance Division will
be shared with the Training Department for their record and perusal whenever required by
them;
Communicate with Senior Management/ Divisions/Group Heads on compliance matters;
In conjunction with HR, prepare an annual training plan and arrange and conduct training
accordingly. Training plans will also be developed in conjunction with HR for new staf to
ensure that training relevant to their area of activity includes topics relating to Compliance. In
particular, these would cover KYC/AML and regulatory reporting requirements.
Reporting the compliance issues and suspicious transaction to the President & CEO/ Board and
relevant authorities
Liaise with the SBP on compliance issues/matters.
8) Reporting Lines
As per the requirements of the Prudential Regulations, Compliance Division of a Bank should
have
a direct reporting line to the President & CEO. In compliance of the spirit of the PR, Compliance
Division of Summit Bank Limited works under a dedicated Head who reports directly to the
President & CEO.
9) Authorities & Independence of Compliance
The Head of Compliance & Control shall:

Have full access to all records and documents of the Bank required in performance of his / her
duties;
Be independent from influence from any quarter within the Bank. Any attempt to influence
findings of a compliance incident will be reported to Board of Directors immediately;
Obtain clarifications on any statutory/ regulatory issue from concerned authorities. He/she
shall also obtain, as necessary, legal opinion on the matters of interpretation and
implementation of the regulations;
Seek assistance, with the consent of the President & CEO, from the external auditors or
consultants in carrying out his/her duties;
Coordinate with IT in the development of MIS Reports for the Compliance function;
Have unrestricted access to the Board of Directors in case of need;
10) Relationship with Internal Audit & Regulatory Bodies
Compliance Division will maintain a close liaison with the Internal Audit Division (IAD). The
periodic internal audit reports of branches and diferent divisions shall be perused to assess
potential compliance issues and to suggest remedial actions to the relevant quarters through
consultation. Similarly findings of the compliance testing will also be shared with IAD. IAD will
also conduct independent audit of the Compliance Division to assess efficacy of the compliance
program.
Compliance Division will also liaise with the regulatory authorities especially State Bank of
Pakistan in replying to any queries / requests for information. Any ambiguity/queries raised by
diferent quarters within the Bank will also be taken up by the Compliance Division with the
relevant regulatory authority to seek clarifications.
11) Framework to Follow
Compliance is an important mechanism that supports efective governance. Compliance with

regulatory requirement and the organizations own policies are a critical component of efective
risk management. For this purpose, a Compliance Program has been developed that defines the
roles, responsibilities and activities to be performed by Compliance Division. The Compliance
Division has been divided into four units:
Regulatory Compliance
Anti- Money Laundering
Regional Compliance
Compliance Risk Management
Roles and responsibilities of each unit have been defined in detail in the Compliance
Program.
12) Compliance Testing for SBP/Regulatory Requirements
Compliance Division will conduct on-site visits of branches as per their schedule approved on
quarterly basis. Further, of-site monitoring will also be performed as per the Compliance
Program
approved by the Management.
13) Applicability on Banks Subsidiaries/Associates
This Compliance policy will also be applicable on Banks subsidiaries/ Associates. In this regard,
our subsidiary Summit Capital (private) Limited will be required to develop their own SOPs/
policy in line with Banks Compliance Policy ensuring their business and related
policies/documents do not contradict banks AML/ KYC policy and procedures. Accordingly, the
subsidiary will also be required to get their Compliance Policy duly approved by their BOD.
Moreover, it would be the responsibility of the Management of subsidiary to ensure that the
policy
is reviewed timely and updated as per the regulations and parent companys compliance policy.
SECTION-B KYC/AML POLICY
1. Objectives
To protect itself from the increasing danger of organized criminal activity and anti-money
laundering, it is essential for the Bank to have clearly laid down policies on Know Your
Customer
(KYC) and Anti- Money Laundering (AML). Through the implementation of these policies and
procedures, the Bank will have an adequate system of controls for efective prevention of anti-
money laundering and will be able to ensure that there is consistency in treatment of our
customers.
Money launderers need the worlds banking systems to launder the proceeds of their crimes and
all
banks in all countries are vulnerable. Cash based societies and countries without fully
comprehensive anti-money laundering programs (comprising legislation, regulation and
financial
sector procedures) are especially attractive to the launderers.
Thus, our own degree of vigilance must reflect these potential vulnerabilities. Cash payments
arising from drug related crimes are by no means the only risk. Fraud, for example, does not
generate any cash, but the extensive proceeds still need to be laundered. Corruption by various
individual\ls and companies including public officials inevitably involves fraud or theft and
handling the proceeds of large scale corruption can produce a serious reputational risk for the
bank.
In addition, preventative measures put in place by International Financial Institutions over the
past
decade have resulted in the need for criminals to use more complex routes to gain access to the
financial system, rather than placing their cash directly into the bank. It must be stressed that
all of
the banks products and services are at risk from being used by criminals to launder the
proceeds
2. Purposeof
their crime.
The main purpose of this policy is to outline the SBP requirements on KYC/AML, the
responsibilities of branchs staf and Compliance Officers with regards to transaction monitoring/
reporting. This policy also defines the system for customer identification, record keeping,
monitoring and internal & external reporting of suspicious or unusual transactions.
3. Definition of Money Laundering
Money Laundering is defined as the process by which criminals attempt to conceal the true
origin
and ownership of the proceeds of their criminal activities. If undertaken successfully, it also
allows
the perpetrator(s) to maintain control of those proceeds and, ultimately, provides a legitimate
cover
The first step in the laundering process is for criminals to attempt to get the proceeds of their
for their source of income.
crimes into a bank or other financial institution, sometimes using a false identity. They can then
transfer the proceeds to other accounts, here or abroad, or use it to buy other goods or
services.
It eventually appears to be like any legally earned money and becomes difficult to trace back to
its
criminal past. The criminals can then invest or spend it or, as often the case is, use it to fund
more
criminal activities.
The laundering process is often described as taking place in three
stages:-
3.1 Placement
Placement being the first stage is the means by which funds derived from a criminal activity are
introduced into the financial system, either directly or through using other retail businesses.
This can be in the form of large sums of cash or a series of smaller sums. Initial proceeds of
drug
trafficking or street sales of drugs are always in cash. During this initial phase, the money
launderer introduces the illegal proceeds into the financial system. Often, this is accomplished
by
placing the funds into circulation through financial institutions, casinos, shops and other
businesses, both domestic and international. This phase can involve transactions such as:
Breaking up large amounts of cash into smaller sums and depositing them directly into a
bank account.
Transporting cash across borders to deposit in foreign financial institutions, or to buy high-
value goods such as artwork, antiques, and precious metals and stones that can then
be resold for payment by check or bank transfer.
3.2 Layering
The aim of the second stage is to disguise the transaction through a succession of complex
financial transactions with the purpose of erasing as quickly as possible all links with its
unlawful
origin. The funds may be converted into shares, bonds or any other easily negotiable asset or
may
be transferred to other accounts in other jurisdictions.
This second stage involves converting the proceeds of the crime into another form and creating
complex layers of financial transactions to disguise the audit trail, source and ownership of
funds.
This phase can involve transactions such as:
Sending wire transfers of funds from one account to another, sometimes to or from other
institutions or jurisdictions.
Converting deposited cash into monetary instruments (e.g.travelers checks).
Reselling high-value goods and prepaid access/stored value products.
Investing in real estate and legitimate businesses.
Placing money in investments such as stocks, bonds or life insurance.
Using shell companies or other structures whose primary intended business purpose is to
obscure the ownership of assets.
3.3 Integration
Complex integration schemes then place the laundered funds back into the economy through
real
estate, business assets, securities and equities, in such a way that they re-enter the financial
system
appearing as normal business funds that have been legitimately earned.
The largest amount of criminal money that needs to be laundered comes from the sale of illegal
drugs, primarily heroin, cocaine and cannabis.
Third stage entails using laundered proceeds in transactions that apparently appear normal in
order
to create the perception of legitimacy. The launderer, for instance, might choose to invest the
funds
in real estate, financial ventures or luxury assets. By the integration stage, it is exceedingly
difficult
to distinguish between legal and illegal wealth. This stage provides a launderer the opportunity
to
increase his wealth with the proceeds of crime. Integration is generally difficult to spot unless
4. Scope
there
are great disparities between a persons or companys legitimate employment, business or
investment ventures
These policies and a persons
and procedures are in wealth or a companys
compliance income
with Anti Money or assets. Regulations,
Laundering
reporting of suspicious transactions etc. applicable in the country. They are applicable to Head
Office and all branches / booths of the bank, which need to ensure compliance with these
policies
and procedures.
5. Responsibilities
Adherence to the Anti-money laundering policies and procedures is the responsibility of the
Management who has delegated this responsibility to Head of Compliance & Control. The Head
of
Compliance & Control shall act as the Reporting Officer for all money laundering cases and shall
ensure monitoring and compliance with these policies and procedures. Compliance Division will
perform compliance of-site testing of KYC/AML practices, on an ongoing basis, to ensure that
these policies are being complied with at branches in letter and spirit through adequate sample
or
complete checking depending on the volume of transactions. Further, onsite testing will be
performed by Compliance Division to review the performance of branches. The schedule and
visits
to branches shall be planned in accordance with the latest Internal Audit Rating/Compliance
Rating,
The SBP Observations
detailed andand
plan for of-site branch size.
on-site reviews is covered in the Compliance Program
separately,
which is derived from the Compliance Policy of the Bank.
Prudential Regulations (PR) on Anti Money Laundering and Combating the Financing of
Terrorism (AML/CFT) Regulations issued by State Bank of Pakistan make it mandatory for every
Commercial Bank / Financial Institution to put in place procedures to combat Money Laundering.
A Commercial Bank would render itself liable for imposition of heavy penalties by SBP if these
regulations are not strictly complied with. It is obligatory on SMBL, its management and staf to
follow the procedures strictly as outlined in these prudential regulations as well as Anti-Money
Laundering Act of 2010 and any subsequent amendments.
There are personal obligations on every member of management and staf that:
It is an ofence to assist anyone whom you know, or suspect to be, laundering money
generated
illegally. In the financial sector, assistance can be provided by, for example, opening a bank
account, accepting deposits, making transfers/payments, advancing a loan, issuing/accepting
letters of credit.
If you know or suspect that a transaction is related to any illegal activity, you must report it in
order to get protection against a charge of knowingly assisting a criminal to launder the
proceeds of his/her crime.
In the case of drug trafficking or terrorist financing, if you form a suspicion of money
laundering in the course of your employment or business activity, you must report it, even if
you are not handling the transaction or funds in question, otherwise you will be alleged for the
ofence of collusion.
Suspicious transactions should be reported if there is a reasonable suspicion that the
transaction
in question has not been able to justify its economic sense and/or appeared to be derived
from
or derived from an illegal source. However, it is important to understand that any information
regarding reporting or investigation of transaction forwarded to the customer is a criminal
ofence and the person responsible will have to bear serious legal consequences.
The procedures bank has developed to combat Money Laundering include:
Awareness raising and training of staf.
The verification of new client identification and know your customer (KYC) and his business.
Retention of records as per regulatory requirement.
Recognition and reporting suspicions of money laundering.
Physical verification of customers business on sample basis. Moreover,, where proof of
business is not applicable e.g. Sole Proprietorship, partnerships, etc; physical verification
would be mandatory in all such cases.
The bank is not committing an ofence if it does not know or suspect that funds relate to drugs,
terrorism or other serious crime. However, if upon investigation it is proved that transaction(s)
were / are conducted in connivance with a staf or were in knowledge of the staf, the respective
person(s)/staf will be held responsible.
The bank is committing an ofence if it knows or suspects that someone is involved in any
serious
crime and the staf:
Assists them to obtain control or retain their proceeds, or
Gives them any help in investing or transferring those proceeds, or
Advises them that the Bank is suspicious of their activities.
In practice of course, the bank staf is not likely to know and may not realize or suspect that
there
was anything suspicious about a transaction, until it is all over and the customer has gone away.
If
that happens, the staf's duty is clear. Staf must report their suspicion as and when
identified/raised; they will not be penalized that they were not suspicious earlier.
If staf does not report their suspicion and the funds are related to drugs or terrorism, the staf
will
have committed an ofence of failure to report. If staf does not report their suspicion concerning
any criminal money, whether relating to drugs, terrorism, or any other serious crime including
transactions apparently placed and layered to evade tax, they may also need to defend an
action
against the bank for deliberately assisting the criminal.
If transaction is found to be suspicious, the branch management i.e. Operations Manager/branch
Manager (OM/BM) etc. must report it to AML Unit- Compliance Division.. The AML Unit will
immediately scrutinize and if deemed fit, report to Financial Monitoring Unit (FMU) after making
consultation with Business Head (if necessary). The Compliance Division may also approach
senior management for their expertise & guidance.
6. Anti-Money Laundering (AML) & Know Your Customer (KYC) General Policies
In accordance with SBP regulations for the prevention of Anti-Money Laundering and KYC, the
following guidelines will be adopted:
All the documents prescribed in the Prudential Regulations (updated from time to time)
would
be obtained from each customer desirous of opening an account with the Bank. For this
purpose, branches are strictly advised to follow the SOP for account opening and any other
instructions given by the Management. Every possible efort should be made to ensure
genuineness of the customer including verification of identity documents/customers
antecedents through independent sources i.e. Verisys/biometric and personal visits to
validate
customers source of income by Bank officials where desirable

Transactions will only be undertaken with customers whose identity and business are either
known or can be verified
Transactions will only be processed that make sense in relation to the business of the
customer.
In case the business place is not verifiable through an independent and authentic source,
physical verification of the business place must be conducted.
All transactions will be routinely scrutinized for any suspicious activity
The AML Unit-Compliance Division should be immediately informed by the branches, of all
suspicious activity, which will be fully investigated by them.
Thebranchesarerequiredtoemailallsuspiciousactivitieson
Complianceamlunit@summitbank.com.pk.
AML Unit Head will coordinate with Head of Compliance & Control in all investigations and
report to the Senior Management/P & CEO and relevant regulatory authorities.
Personal accounts should strictly never be used for business transactions.
Staf will be adequately trained in the key aspects i.e.
o Know your customers identity and business.
o Ensure that transactions make economic as well as logical sense.
o Know what to do when a situation of suspicious transactions arises.
o Know how the situation will be reported and investigated.

o Know the consequences for not reporting or being involved in money laundering
activities.
Adequate procedures for the verification of the identity of all new customers shall be applied
and
documents should be obtained as stipulated in SBP Prudential Regulation (copy attached-
annexure
I), and any other subsequent changes made in relevant SBP regulations and account opening
SOP
of the Bank. Efective internal audit shall be carried out to ensure policies and procedures are
7. Account Opening and Customer Profiling (KYC/CDD)
being
complied with.
Keeping our bank's slogan in sight Committed to You, anybody without the discrimination of
religion, race, cast, creed, profession can open an account with SMBL provided the bank can
reasonably determine legal customer's identity and legitimate source of income through
including
but not limited to documents, references or personal visits. Account opening procedures
detailing
types and requirements for various types of customers as circulated by the Country Operations
through Manuals /SOPs as amended from time to time would be adopted which at present
includes:
Personal attendance/contact with the customer.
Proper introduction (Optional)
Scrutiny of original identification documents.
Completion of standard application form.
Verification of any photograph where applicable.
Approval of account opening by Operations/Branch Mangers
Verification of address of the account holder through sending letter of thanks for all customer
accounts.
Issuance of cheque books/starter cheque books strictly in accordance with the SOPs
Completion of documentation formalities for various types of customers as per the SOP on
account opening.
8. Customer Due Diligence
Customer due diligence or CDD in broader terms includes;

identifying the customer and verifying the customers identity on the basis of documents, data
or information obtained from customer and/or from reliable and independent sources;
identifying, where there is a beneficial owner who is not the customer, and taking adequate
measures, to verify his identity so that the bank is satisfied that it knows who the beneficial
owner is, including, in the case of a legal person, trust or similar legal arrangement, measures
to understand the ownership and control structure of the person, trust or arrangement;
The Bank shall verify identities of the customers (natural persons) and in case of legal
persons,
identities of their natural persons from relevant authorities or where necessary using other
reliable, independent sources and retain on record copies of all reference documents used for
identification and verification. The verification shall be the responsibility of the bank for which
the customer shall neither be obligated nor the cost of such verification be passed on to the
customers and/or beneficial owners.
understanding and, as appropriate, obtaining information on the purpose and intended nature
of
the business relationship; and
monitoring of accounts/transactions on ongoing basis to ensure that the transactions being
conducted are consistent with the banks knowledge of the customer, their business and risk
profile, including, where necessary, the source of funds and, updating records and data/
information to take prompt action when there is material departure from usual and expected
activity through regular matching with information already available with bank..
8.1 Bank would do due diligence when;

Establishing business relationship,
Establishing correspondent banking relationship with other bank and opening of Nostro/Vostro
Accounts;
Conducting occasional transactions above Rupees one million whether carried out in a single
operation or in multiple operations that appear to be linked;
Carrying out occasional wire transfers (domestic / cross border) regardless of any threshold;
There is suspicion of money laundering / terrorist financing; and
There is a doubt about the veracity or adequacy of available identification data of the
customer.
There is transaction in the account which does not commensurate with the customers profile.
Following minimum due diligence measure will be taken according to Regulation-1 of Prudential
Regulations for AML/CFT;
It is prohibited to open and maintain anonymous accounts or accounts in the name of fictitious
persons or numbered accounts.
All reasonable eforts shall be made to determine identity of every prospective customer. For
this purpose, minimum set of documents are to be obtained by the branches from various
types
of customers / account holder(s), at the time of opening account, as prescribed in attached
Annexure-I and Prudential Regulations for AML/CFT.
Bank shall identify the beneficial ownership of accounts/ transactions by taking all reasonable
measures.
For all customers, bank would determine whether the customer is acting on behalf of another
person, and should then take reasonable steps to obtain sufficient identification data to verify
the identity of that other person. All eforts shall be properly recorded/documented and
considered as integral part of Customers Due Diligence and filed with the account opening
documents.
Where the customer(s) has requested to open a joint account, the CDD of all the joint account
holders shall be performed as required for an individual account.
For customers that are legal persons or for legal arrangements, bank will take reasonable
measures to (i) understand the ownership and control structure of the customer (ii) determine
that the natural persons who ultimately own or control the customer. This includes those
persons who exercise ultimate efective control over a legal person or arrangement. The
identity of all natural persons who are acting on behalf of the legal person shall be verified
and
properly documented (at least CNIC duly marked original seen and their Nadra Verisys).
Further, authority of such persons who act on behalf of the customer shall be verified through
documentary evidence including specimen signature of the persons so authorized.
Reasonable measures should be taken to verify the identity of the beneficial owners of the
account. The bank should identify the ownership structure (ultimate beneficial owner) i.e. the
natural persons who ultimately owns the account and perform necessary due diligence to
verify
the details provided to the bank by the customer.
The Bank shall obtain in writing from the customer, the purpose and intended nature of
business relations desired from the account.
Understanding the nature and purpose of customer relationships to develop customer risk
profile (refer section 9 below).
Government accounts would not be opened in the personal names of the government
official(s). Any such account, which is to be operated by an officer of the Federal / Provincial /
Local Government in his / her official capacity, shall be opened only on production of a special
resolution / authority from the concerned administrative department duly endorsed by the
Ministry of Finance or Finance Department of the concerned Government.
Account of Autonomous entities and armed forces including their allied offices may be opened
on the basis of special resolution/authority from the concerned administrative department or
highest executive/management committee of that entity duly endorsed by their respective
unit
of finance.
However, while opening an account, any rules/regulations or procedures as laid down in the
governing laws of such entity relating to opening and maintaining an account shall be taken
in
to account.
The branches should perform Enhanced Due Diligence (EDD) while establishing relationship
with NGOs/NPOs/Trust/Charities/ Societies/ Foundation etc. The branch will also conduct
Customer Due Diligence (CDD) of its authorized signatories, members of its governing
bodies,
trustees, directors, beneficial owner, etc.
It shall not be allowed to use personal accounts for business purposes except
proprietorships,
small businesses and professions where constituent documents are not available and the
branches are satisfied with KYC profile of the account holder, purpose of relationship and
expected turnover of the account keeping in view financial status & nature of business of
that
customer.
In case branches are not able to satisfactorily complete required CDD measures, account
shall
not be opened or any service provided and consideration shall be given if the circumstances
are
suspicious so as to warrant the filing of an STR. If CDD of an existing customer is found
unsatisfactory, the relationship should be treated as high risk and reporting of suspicious
transaction be considered as per law and circumstances of the case.
9. Risk Categorization
The customer risk profiling should be done after considering their source of income,
geographical
place of business, nature of counter parties with whom they are involved in business, age of
business, etc. The risk categorization should be based on the following broader scale:
Prohibited Customers: Countries subject to economic sanctions or designated as state
sponsors of terrorism, such as Sudan, South Sudan, North Korea, Cuba, Myanmar, Syria, Iran
are prime candidates for prohibited transactions as per latest FATF directives. Further any
customer having any link or relationship with Israel (direct or indirect) is also prohibited.
Prohibited customers also include shell banks, unacceptable customer (refer section 25 of
this
policy). Further, the companies with of-shore presence should also be treated as a
prohibited
category. Moreover, while assessing the customers risk profile, due weightage should be
given to the geographical circumstances as well. For example, during the course of due
diligence if it is transpired that the counter customers i.e. suppliers/buyers belong to any
prohibited area, such relationship should be avoided. Moreover, the existing customer base
should also be reviewed at the time of KYC/CDD in the same respect.
Regulations/guidelines in this regard issued from time to time will also be followed
accordingly.
High-Risk: The risks here are significant, but are not necessarily prohibited. To mitigate the
heightened risk presented, the bank should apply more stringent controls to reduce the risk,
such as conducting enhanced due diligence and more rigorous transaction monitoring.
Countries that are noted for corruption or drug trafficking are generally deemed high risk.
High
risk customers may include Politically Exposed Person (PEPs); high-risk products and
services
may include correspondent banking and private banking. (Refer section 11 and 24 of this
policy)
Medium-Risk: This category has more risk of money laundering than low- or
standard-
risk category and merit additional scrutiny, but do not rise to the level of high-
risk.
Low- or Standard-Risk: This represents the baseline risk of money laundering; normal
business rules apply. FATF member countries and domestic retail customers are frequently,
but not always, considered to be standard- or low-risk.
The rationale of reaching to a certain risk level, apart from the Customer Risk Profiling (CRP)
form may also be documented in the KYC/CDD form or CRP form so as to present the logical
reasoning.
10. Timing of Verification
Verification of the identity of the customers and beneficial owners shall be completed before
business relations are established including verification of CNIC/NICOP/POC from NADRA
wherever required for customers under these regulations.
Branches may accept initial deposit at the time of submission of necessary documents by their
prospective customers (individual natural persons only) subject to the following and as
documented in the Account opening and Maintenance SOP;
(a) Initial deposit receipt will be issued with Disclaimer that account shall be opened after
completing necessary due diligence including NADRA verification through Verisys or bio-metric
technology.
(b) A temporary account number shall be generated which will be validated after completion of
due diligence process.
(c) The Initial deposit will be credited to customers designated account only.
(d) No transaction in the account, issuance of cheque book/ATM Card or any other instrument is
allowed until completion of verification of identity of the customer. However, in case, the
biometric thumb impression of customer (verified from NADRA) is taken by the bank, the
account
may be activated instantly subject to satisfactory due diligence.
The branches will maintain a list of all such customers/accounts where the business relationship
needed to be closed on account of negative verification.
Branches shall guide the customers to visit relevant branch to get refund of initial deposit in
case of
negative NADRA verification. In this reference, the guidelines documented in the Account
Opening & Management SOP must be adhered to.
At the time of reviewing the KYC form, the supplementary documents with the AOF should also
be reviewed and if found expired, valid documents should be obtained and verified accordingly.
The same should be attached in customers file and records to be updated for audit purposes.
11. Enhanced Due Diligence (EDD)
EDD would be applied to all the high risk customers according to the risk profiling guidelines
given in Annexure-D. High risk elements identified by SBP and recommended actions for EDD
are
given in Annexure-J and Annexure-K.
To elaborate, EDD will be performed as per assigned total risk ratings of 141 points and more or
on the following professions/account category mandatorily:
PEP, NGO (Non-governmental Organization), NPO (Nonprofit Organization), Charity, Trust,
Club, Society, Association, Welfare Organization, Arms & Ammunition, Exchange Companies
and Correspondent Banks.
Housewife accounts
Proprietorships and self-employed individuals/ professionals
Landlords
Foreign Nationals-A person who is not a naturalized citizen of the country in which they are
living.
Money Service-A money services business (MSB) - businesses that transmit or convert
money.
Internet Payment Processors-Internet payment processing is an online service provider that
connects an electronic shopping card or virtual terminal/POS to an electronic payment
processor.
Non- resident- Accounts of individuals, firms or companies residing in countries outside

Pakistan are termed a Non-Resident Accounts. All nationals of Pakistan and persons
domiciled
in Pakistan, who go out of Pakistan for any purpose such as employment, study, business
tour,
pleasure trip etc. are treated as Non-Resident, for so long as they remain outside Pakistan.
e- Money Issuers-Digital money or money stored on an electronic device or magnetically
stored money, which is issued against receipt of funds for the purpose of making payment
transactions.
Metal Dealers-who deal in metals, scrap metals etc.

Penny Stocks/Microcap Securities- The term "microcap stock" applies to companies with low
or "micro" capitalizations, meaning the total value of the company's stock or capital is
relatively on a lower side. They used to have low revenues and own assets that have
nothing to
do with the business.
Examples of such EDD (as given in AML/CFT Guidelines) measures may also include:
Obtaining additional information on the customer (occupation, volume of assets, address,

information available through public databases, internet, etc);
Reducing interval for updating and reviewing customer risk profile;
Reducing interval for updating the identification data of customer and beneficial owner;
Obtaining additional information on the intended nature of the business relationship;
Obtaining information on the reasons for intended or performed transactions;
Obtaining additional information on the sources of funds or sources of wealth of the
customer;
Obtaining the approvals of senior management to commence or continue the business
relationship (necessary for PEP, NGO, NPO, Charity, Trust, Club, Society, Association,
Welfare Organization, Exchange Companies, Arms & Ammunition, Correspondent Bank and
for other accounts, if deemed necessary by the branch);
Conducting enhanced monitoring of the business relationship, by increasing the number and
timing of controls applied and selecting patterns of transactions that need further
examination;
A signatory who is neither a beneficial owner nor a key principal may also be verified if they
were the principal contact with the bank, acting on behalf of directors or owners with whom
the bank had little or no direct contact; and
Documentary evidence may be sought to support transaction where possible, e.g. purchase
of
property etc.
11.1 Third Party Mandate Holders
An account holder may choose to grant a third party mandate to another person (individual or
corporate). It is necessary to establish the relationships between account holder and the
mandate
holder and also the reason for the mandate and the same should be documented in the KYC
form.
The identity of the mandate holder should be verified in the same manner as is used for the
account
holder. The branch must also complete a separate KYC/CDD form for the mandate holder as
well.
The Third Party Mandate Form should be signed and placed on the Customer File. Any change of
address of the account holder(s) must be notified directly by the account holder(s). Where a
Power
of Attorney exists, the original must be seen and copied by the branch for the file. A Third Party
Mandate must also be completed with full supporting documentation as mentioned above.
11.2 Use of Personal Accounts for Business Purposes
SBP has strictly prohibited use of personal accounts for business transactions. For small
businesses, proprietorships and professions where constituent legal documents are not
available to
prove his business, in such case the branch should document the same in the call report and
the
Business KYC Form mentioning the fact that the person is doing the business in his/her
individual
An undertaking shall also be obtained from the customer, stating that he/she does not have a
name.
documented business and neither he/she is maintaining a business account in any financial
institution.
Personal visit of the business place by the branch staf would be necessary in these cases. For
this
purpose, the importance of knowing the customer and intended use of the account becomes
even
more important. To this end the branch must satisfy itself that the transactions relate to the
legitimate business of the customer or there is a justifiable explanation for out of pattern
transactions. Branch also must document the explanation preferably through getting some
documentary evidence from the customer for the transaction otherwise appropriate notation
must
In
beorder
madetoincurtail thetransactions
the daily personal account
list of use
the for business
branch transactions,
by branch a threshold
or operations has been
manager.
introduced by the regulators whereby if average monthly credit turnover in any such account
exceeds Rs. 5Million or above, a new separate business account shall be opened for business
related transactions. Where the customer is maintaining registered business but using his/her
personal account for business transaction, branch should advise the customer for avoiding
business
transaction in the account. Incase if it still continues, branch should raise STR to the Compliance
Division on complianceamlunit@summitbank.com.pk with the subject as STR-Customer Name /
Account Number.
Further, personal accounts are strictly prohibited from being used for collection of charities and
donations.
11.3 Housewife Accounts:
Enhanced Due Diligence (EDD) shall also be applied on these accounts while establishing
relationship with the customer. In relation to housewife accounts, branches are required to
obtain a
self-declaration for source and beneficial ownership of funds and are also required to update
details
of funds providers if any, along with the customers profile. Furthermore, at the time of account
opening, during the due diligence process, it is established that the monthly credit turnover will
be
over the threshold as prescribed by the Management, branches are required to obtain fund
provider/
beneficial owners source of income document. In case, there is resistance from the customer in
providing
Moreover,the
therequired documentations
branch shall at thethe
properly monitor time of opening
transaction in the account,
such establishing
accounts and in casethe
during
relationship
the with such customers should be avoided.
course of business, it is observed that the monthly credit turnover exceeds the threshold as
prescribed by the Management in a housewife account, branch must also identify and verify
funds
provider(s) / beneficial owners source of income and keep all the required documents in record
for
audit purposes. In case of resistance from the customers end in providing the required details,
Furthermore,
branches are In case the
required to source of fundsfrom
seek guidance of the
thehousewife
business account
head. is from a profession/
customer,
that are marked as high risk in line with Banks Compliance AML/KYC Policy, the housewife
account shall be marked as High Risk.
12. Simplified Due Diligence (SDD)
As per SBP instructions, there may be circumstances where the risk of money laundering or
financing of terrorism may be low, for example where information on the identity of the
customer
and the beneficial ownership is publicly available. In such circumstances, SDD measures may be
applied provided there has been an adequate analysis of the risk by the bank. Examples of such
low
risk scenarios/factors are given in Annexure-L.
In respect of general low risk elements, Bank may perform such SDD measures as it considers
adequate to efectively establish the identity of the customer, a natural person appointed to act
on
behalf of the customer and any beneficial owner. The SDD measures should be in accordance
with
predefined criteria within AML/CFT policy of a bank and should commensurate with the low risk
factors e.g. the SDD measures could relate only to customer acceptance measures or to aspects
of
Examples of such SDD measures may include:
on-going monitoring.
Decreasing the frequency of customer identification updates;
Reducing the degree of on-going monitoring and scrutinizing transactions based on a
reasonable monetary threshold; and
Not collecting specific information (no exemption shall be presumed in respect of minimum
documents prescribed in Annexure-I of AML/CFT Regulations) or carrying out specific
measures to understand the purpose and intended nature of the business relationship,
but intended purpose and nature of account may be ascertained from the relationship
established or from the type of transactions.
However, at branch discretion if it is ascertained that an account is risker then the factors
mentioned above, in this case SDD shall not be applicable and instead CDD/EDD would be
conducted based on respective risk category.
13. CDD Measures for Occasional Customers/Walk-in Customers and Online Transactions
13.1 Transactions with Non-account holders
SMBL only does business with the customers known very well to the bank/branch. Therefore,
significant transactions with non-account holders should be discouraged. However, payment of
utility bills and statutory obligations like encashment of DSCs/SSC and sale /purchase of national
prize bonds etc. will be allowed for non-account holders. For other services such as purchase of
remittance instruments e.g. POs, DDs and MTs etc; risk based AML measures would be taken.
Transactions up to Rs. 25,000 may be allowed for all non-account holders after production of
CNIC. The CNIC copy shall be obtained and kept in records for all such transactions regardless of
any threshold. For transactions exceeding Rs. 25,000 but less than Rs. 100,000, the transaction
may
be allowed to the customer after getting a copy of the CNIC and filling out a walk-in customer
form. No transaction would be allowed exceeding Rs 100,000 without getting customers
account
opened and getting all the due diligence formalities completed as per the bank's policy.
For facilitating home remittances under various international tie-ups with reputable exchange
companies duly approved by senior management/SBP, over-the-counter cash payments of up to
Rs
500,000/- may be made to non-account holders after proper identification as per the bank's
procedures. President and/or Group Head Retail Banking are authorized to allow over the
counter
cash payments in excess of Rs. 500,000/- for home remittances.
In order to facilitate business such as pre-paid cards etc., SBP regulations and Banks policy for
Agent Management and Prepaid cards will be followed for meticulous compliance.
13.2 Transactions made by Non- account holders on behalf of Customer account
For transactions made by non-account holders in the customer accounts maintained at the
bank, it
is necessary to obtain the copy of CNIC, duly marked as Original Seen, after seeing the
original
CNIC and record them for MIS and future reference. This is also applicable for branches that
process transactions on behalf of other branches as well. In this regard following is applicable:
Banks shall:
(i) Obtain copy of CNIC while conducting cash transactions above Rupees 0.5 million;
(ii) Obtain copy of CNIC while issuing remittance instruments e.g. POs, DDs and MTs etc.
(iii) Obtain copy of CNIC (regardless of threshold) while conducting online transactions by
occasional customers/walk-in-customers (except deposits through Cash Deposit Machines or
cash
collection/management services). If transaction exceeds Rs. 100,000 the name and CNIC No.
shall
be captured in system and made accessible along with transaction details at beneficiarys
branch.
14. Account of Politically Exposed Persons (PEPs)
Politically exposed persons or PEPs are individuals who are entrusted with prominent public
functions either domestically or by a foreign country, or in an international organization, for
example Heads of State or of government, senior politicians, senior government, judicial or
military officials, senior executives of state owned corporations/departments/autonomous
bodies.
This does not intend to cover middle ranking or more junior individuals in the foregoing
categories; in relation to the above, the Branches Managers/Operations Managers shall make all
possible eforts to confirm whether the person is PEP or not PEP. However, in case he/she
recognizes that the subject person(s) is PEP at the time of account opening or during the
relationship, the same should be communicated to the Head of Business for approval / further
guidance.
Accounts of persons directly or indirectly i.e. related to any political party or activity shall be
categorized as PEP. As per FATF guidelines Once a PEP could always remain a PEP. This is
equally applicable for domestic as well as international personnel. Furthermore, in relation to
PEPs
and their close associates or family members, the bank shall obtain approval from the Head of
Business or his/her delegates and senior management (Senior management means the
officer(s)
not below the rank of Executive Vice President) to establish or continue business relations where
the customer or a beneficial owner is a PEP or subsequently becomes a PEP.
Further, before opening an account or continuing the relationship, the EDD shall be conducted
to
verify, by appropriate means, the sources of wealth or beneficial ownership of funds; as
appropriate; including Bank s own assessment to this efect; and conduct enhanced monitoring
of
business relations with the customer during the course of business relations.
15. Accounts of NGOs/NPOs/Trusts/Societies/Clubs/Associations/Charities
No account of any entity mentioned above shall be opened or continued without prior approval
from the Head of Business or his/her delegates and Senior Management (Senior management
means the officer(s) not below the rank of Executive Vice President). The approval shall mean
the
satisfaction with the purpose of account and that this account will be used for legitimate
purposes
and the transactions will be commensurate with the stated objectives of the entity. The branch
should perform Enhanced Due Diligence (EDD) while establishing relationship with
NGOs/NPOs/Trust/Charities/ Societies/ Foundation etc.
Further, required documents shall be obtained as prescribed in the SOP for account opening. In
this regard, CDD shall be performed of the entity, members of its governing bodies, its
signatories
and all the beneficial owners.
Further, details of all signatories and beneficial owners shall be entered in to the system so as to
ensure that they are not linked to any proscribed entities by filtering them through the OFAC
and/or Other lists and avenues available.
In case the customer brings account-opening form duly signed, his signature should be obtained
in
presence of Bank officer and compared with the one appearing in the form and CNIC. From the
information captured in the Account Opening Form (AOF)/Know Your Customer Form (KYCF),
the officers responsible for supervision of account opening procedures in the Bank will make an
initial assessment of customers risk profile.
In order to have efective monitoring, all accounts will be profiled as per Know Your Customer
Forms (KYCFs) Annexures A (Individuals/Joint Accounts) and B (Business Accounts). All
KYCFs have to be signed by the Operations Manager and Branch Manager. The profiling
exercise
will include assigning a risk profile to customers, based on the guidelines given at Annexure C.
The profiling will be based on customers nature of business, geographical area of business
operations, beneficial owner and source of funds etc. Various forms, guidance, explanatory
notes
mentioned in the policy may be updated by Compliance Division in consultation with all the
relevant divisions depending on the changing market/regulatory requirements.
Further, account of unregistered NGO/Trust/Welfare Association/Clubs/Societies/Foundation
should not be opened. Moreover, considering the overall global environment and risks involved
in
such accounts, following due diligence measures are suggested:
i. Continuing EDD, which involves physical visit of the customers place of business and
meet with the officials mentioned in the Banks record (at least once in six months)
ii. Ongoing monitoring of transactions to escalate any abnormality to Compliance AML Unit.
iii. Ensuring that no transaction whether debits or credits between an NGO/Trust/welfare/
Association/Club/Societies /foundation account and individual/other unrelated counter
parties are made.
16. Foreign Currency Accounts Maintenance & Monitoring
Foreign Currency Accounts shall be dealt strictly in compliance with Foreign Exchange Manual
and SBP Regulations. Following should be considered for meticulous compliance:
16.1 Individual Accounts Opening, Maintenance and Monitoring
During the monitoring of accounts, branch shall properly monitor personal foreign currency
accounts. It cannot be used for any commercial or business purpose. Further, in case of any
deposit
of foreign currency notes of more than USD 10,000 (or equivalent in other currencies) in a single
day, the account holder shall be required to present the original receipt of acquisition and
branch
shall keep the copy of receipt in its record. Branch should ensure that transactions undertaken
throughout the course of business relationship are consistent with the customer's profile,
purpose of
In case ofbusiness
account, any suspicions,
and riskaccounts should
profile and be of
source reported
funds. to AML Unit- Compliance Division. The
AML-CD will immediately scrutinize and if deemed fit, report to Financial Monitoring Unit
(FMU) after making consultation with President & CEO. The Compliance Division may also
approach senior management for their expertise &guidelines.
16.2 Entity Accounts - Opening, Maintenance and Monitoring
During the monitoring of accounts, branch shall properly monitor foreign currency accounts
maintained by corporate bodies/legal entities. Corporate Bodies/ Legal entities cannot generate
funds from the kerb market for deposit in their foreign currency accounts.
Branches need to ensure that no cash deposit in and withdrawal from foreign currency accounts
of
corporate bodies/legal entities are made. FCY accounts of Autonomous bodies/Public sector
entities cannot be opened without approval from Ministry of Finance and SBP. During the course
of relationship, branch shall ensure that the transactions are in compliance with regulatory
instruction
17. Review and Monitoring of Transactions
Compliance Division has implemented AML software, in which there are 10 monitors based on
pre-defined parameters/threshold and customer profile.
All the alerts generated on the AML Module must be reviewed and immediately responded i.e.
on
the same day. The comments by the branches must carry appropriate rationale to
support/justify the
transaction and their satisfaction on the customer. In case if there is non-satisfaction or the
branch
is unable to justify the transaction, comments on the AML Module must accordingly be made. If
there is a need to file STR, a separate email should also be forwarded on
complianceamlunit@summitbank.com.pk. with the subject STR
.
17.1
A Self-Monitoring
check of operations will be made on a monthly basis, jointly by Branch Manager and
Operations
Manager for accounts whose transactions volumes exceed the information captured in the KYC
form after allowing for a reasonable tolerance to ascertain that they are generally in line with
the
information captured in the KYCF. Foreign currency and Non- Resident Accounts will require
special attention. Any transaction in the dormant/inoperative accounts will only be authorized
after
approval by the Head of Business or his/her delegates, following the prescribed procedure laid
down in the relevant SOP/SPM. For customers whose accounts are dormant or in-operative, the
bank may allow credit entries without changing at their own, the dormancy status of such
accounts.
Debit transactions/ withdrawals shall not be allowed until the account holder requests for
activation
As Branch Managers are in the best position to know their customers, they must review daily
and produces
report attestedincopy
of transactions of his/her
customers CNIC ifinnot
account already
excess available
of Rs.0.5M. and the
Foreign Branch /&Centralized
Currency High Risk
Operations Department is satisfied with SDD / CDD / EDD of the customer.
account will require special attention. Any abnormal or suspicious transaction will be reported to
AML Unit-Compliance Division. For occasional transactions in the accounts above Rs. 1 million,
the file maintained for this purpose must contain documentary evidence or the daily statement
must
contain a proper notation by branch manager/operations manager giving the
justification/purpose
of such large transaction. Documentary evidence of the monthly checks should be kept in a
separate file. Officers from Regional Unit- Compliance Division /Internal Audit will check the
compliance of above.
The transactions, which are out of character or are inconsistent with the history, pattern, or
normal
operation of the account including through heavy deposits, withdrawals and transfers, shall be
viewed with suspicion, would be properly investigated and referred to Compliance AML Officer
for possible reporting to FMU under AML Act 2010.
At the time of reviewing the KYC form, the supplementary documents with the AOF should also
be reviewed and if found expired, valid documents should be obtained and verified accordingly.
The same should be attached in customers file and records to be updated for audit purposes.
17.2 Direct Monitoring of Daily Transactions by Compliance Division
Compliance Division will perform of-site monitoring of transactions, including high risk areas
transactions, Home Remittance transactions and trade related transactions on random basis.
The
basic objective is to ascertain the overall activities in the branches and implementation of
policies.
However, the branches, considering being the real execution point of transactions, would be
responsible to ensure that bank or any of its officers are never involved in facilitating opening of
accounts of persons/individuals with unverifiable source of income or facilitating transactions
with
Branches are sense
no economic responsible fornot
or those promptly attending
matching with theto customers
any queriesprofile.
raised by Compliance Division,
preferably within two business day or earlier if required by Compliance Division.
The Compliance Division shall have full access to all internal information regarding the
transaction/account and obtain any external confirmations as necessary to conclude whether
the
transaction should be reported to the relevant authorities.
All the bank staf, particularly those engaged in customer services, retail operations, investment
activity and funds management shall apply due care and judgment in identifying suspicious
activities and report any such activity to the Head of their Division/Branch Manager and AML
Unit - Compliance Division on complianceamlunit@summitbank.com.pk.
The Unit Head, AML within Compliance Division will scrutinize and investigate the transaction as
appropriate to verify the origin of funds to assess possible money laundering activity. The Head
of
Compliance & Control will review the report and will discuss it with the relevant officers and
management as appropriate. Such deliberations and interaction shall be properly recorded.
Once
the necessary investigations are complete, he will submit his report to President & CEO with his
recommendations based on which a decision will be taken on actions needed in the light of
relevant
If
SBPHead of Compliance
regulations & Control
and other decides
regulatory to report any transaction to FMU, he shall complete the
obligations.
standard report form and submit it with the consent of the President & CEO. If it is decided not
to
make a formal report to the regulatory authorities, the same will also be recorded. The Unit
Head,
AML shall prepare the MIS and maintain the same as the Banks internal record, detailing the
rationale of the decision.
Under no circumstances may any staf of the Bank warn or inform the customers/or other
irrelevant parties when information relating to such customer is being reported to the regulatory
authorities. Any breach of this duty shall be subject to disciplinary action as per HR policies of
the
bank and this would also breach the code of ethics. Any staf suspected of involvement will
immediately be put under surveillance and appropriate steps taken by the Management in
accordance with local regulations
17.3 Quarterly Compliance Certificate by Branches
All the branches will furnish a quarterly compliance certificate to the Compliance Division
confirming that there have been no deviations from this policy or if some deviation/exception
has
been made, state the exception, competent authority which approved the exception and
Resolution
Target Date.
17.4 Reporting of Transactions
All STRs, including attempted transactions, should be reported regardless of the amount of the
transactions; and, the CTRs should be reported above the reporting threshold of Rs. 2.5 million
as
per requirements of AML Act.
Further, the basis of deciding whether an STR is being filed or not shall be documented and kept
on record together with all internal findings and analysis done in relation to a suspicion
irrespective
of the fact that transaction is subsequently reported or not.
For reporting purposes, as desired by the Regulator, without disclosing the contents of STRs,
shall
intimate to State Bank of Pakistan on bi-annual basis the number of STRs reported to FMU. The
status report (indicating no. of STRs only) shall reach Director, BPRD within seven days of close
of each half year.
17.5 Updating Customer Profile
Wherever considered necessary, contact should be established with the customer to clarify any
pertinent point and KYCF updated if required.
Suitable action should be initiated where satisfactory explanations cannot be found. An

evidence of
the above exercise should be kept in a separate file as a permanent record duly initialed by both
branch and operations manager of the branch. Such records should clearly indicate date of
review,
account number of customers reviewed and an overall assessment against each one
categorized
into satisfactory or unsatisfactory. Specific actions taken in cases marked unsatisfactory should
Especially, attention should be given to profiles and transactions of customer posing higher than
also be mentioned.
average risk. The KYC forms, both hard copies and the in the system should be updated with
details justification and reviewed at the set frequency. A detailed guideline on Customer Risk
Profiling has been given as Annexure-D.
Customers profiles should be revised keeping in view the spirit of KYC/SDD/ CDD/ EDD and
basis of revision shall be documented and customers may be consulted, if necessary. In case of
any
un-satisfactory response from the customer or suspicion over the transaction activity in the
customers account, it should be informed to AML Unit - Compliance Division.
18. Record Keeping
KYCFs of all customers should be kept along with Account Opening Forms. All the relevant
record for transaction monitoring must also be kept in a separate file for review by compliance
division /SBP.
All relevant information concerning customer accounts particularly documents obtained to verify
the identity of the customer shall be recorded and retained. It shall be a condition of the
account
opening mandate that the customer will inform the bank and provide all necessary documents
for
any changes to the information supplied. The Bank shall also maintain a detailed statement of
customer accounts in electronic format for easy access and review of the transactions in the
accounts.
As per Regulation # 5 of AML/CFT Regulations, the record retention period is as follows:
For account holders in relation to evidence of identity and business relationships, transaction
records, ten years from the end of the relationship with the customer.
Records relating to suspicious transactions reported by the Bank are required to be retained
till
such time as permission from State Bank is obtained to destroy such record. Similarly,
customers or accounts involve litigation or it is required by court of law or other competent
authority, shall only by destroy after the permission from the respective authority.
All customer account opening documents shall be subject to regular review and update. This will
be the responsibility of the Branch Manager/Operations Manager.
The Bank should maintain for at least ten years the following records for inspection by the
regulatory authorities:
Anti-money laundering monitoring reports reviewed as well as submitted by the branches to
the Management or any agency/regulator. This also includes the routine transaction
monitoring
done by the branches. Further, any record shall only be destroyed with the permission of the
Management and as per the Record Retention Policy of the Bank.
With respect to Record Retention, banks approved record retention policy also should be
followed.
19. Correspondent Banking
The Bank shall not act as correspondent bank until sufficient information about the respondent
bank has been obtained to understand fully the nature of respondents business as mentioned
in
Prudential Regulation # 2. Further, no relationship with any sanctioned state will be made.
Factors
to consider
Gather include:
adequate information about the respondent bank to understand fully the nature
of
the respondent banks business, including the following, where applicable;
Know your customer policy (KYC).
Information about the respondent banks management and ownership.
Major business activities.
Their geographical presence/jurisdiction (country) of correspondence.
Money laundering prevention and detection measures.
The purpose of the account or service.
The identity of any third party that will use the correspondent banking services (i.e. in
case
of payable through accounts).
Condition of the bank regulation and supervision in the respondents country, determine

from any available sources the reputation of the respondent bank and, as far as
practicable,
the quality of supervision over the respondent bank, including where possible whether it
has been the subject of money laundering or financing of terrorism investigation or
regulatory action; and
Assess the respondent bank in the context of sanctions/embargoes and Advisories about
risks
AML/KYC/CDD of correspondent banks is ongoing process which should be reviewed once in
two years by Financial Institutions Department (FID). Adhoc review should be conducted if below
mentioned parameters prompted. Further in case the correspondent relationship exists in any
high
risk area the review shall be made on annual basis. The complete record of such reviews shall
be
maintained with FID and Head of FID will be responsible to ensure compliance.
Adhoc Reviews of AML/KYC/CDD
In the event of a sharp deterioration at any time in any one or more of the parameters
mentioned
below, immediate adhoc review has to be done by the FID.
Downward revision of the bank/FI rating
Adverse news reports about the bank/FI
Significant change in Shareholding/Directors/Management and /or if negatively
perceived
Downward revision on the Country rating where the counterparty is domiciled
Sharp deterioration in the financial standing of the bank/FI
Bank shall pay special attention when establishing or continuing correspondent relationship with
banks/ financial institutions which are located in jurisdictions that have been identified or called
for
by FATF for inadequate and poor AML/CFT standards in the fight against money laundering and
financing of terrorism.
The bank shall not enter into or continue correspondent banking relations with a shell bank and
shall take appropriate measures when establishing correspondent banking relations to satisfy
themselves that the correspondent banks do not permit their accounts to be used as shell
banks.
Correspondent Banking Relationship shall only be established or continued with the approval
from
the Head of Business and Senior Management (Senior Management means the officer(s) not
below the rank of Executive Vice President). This would also be applicable at the time of
reviewing the relationship and performing periodical KYC/CDD for the correspondent bank.
The responsibility of the satisfactory due diligence before establishing correspondent banking
relationship rests with the Financial Institutions Department. In this regard and in light of the
regulations, FID shall prepare a comprehensive SOP for the process, which in addition to the
above
pointers shall also assess the respondent bank in the context of sanctions / embargoes and
Advisories about risks. The document should also be reviewed by Compliance Division and
approved by Senior Management.
20. Wire Transfers/ Fund Transfer
In cases of outward remittances, sufficient due diligence will be undertaken by the Bank on: the
client, origin of the funds, and purpose of remittance. Following details shall be recorded up to
the
satisfaction, before processing the payment:
Obtain and verify details of the originator
Obtain details of the beneficial owners
Date, type, currency and amount of the wire transfer
Value date
Plausible purpose of remittance.
Details of the beneficiary institution
Relationship between originator and beneficiary
The following information shall be included in the transfer details:

The name of the wire transfer originator, account number (or unique reference number which
permits traceability of the transaction) of the originator; and the originators address and
CNIC/passport number;
The name of the beneficiary.
Complete address of the beneficiary and Originator.
The account number of the beneficiary.
Date of birth of the Originator
For the above context, it is clarified that the requirements may not apply to domestic fund
transfer
transactions through e-banking channels (e.g. ATM, internet banking & mobile banking etc) and
RTGS where appropriate controls are already put in place by the E-Business Units of the Bank as
per existing rules, regulations and policies / procedures set for domestic fund transfers. For
meticulous compliance, E-Business Department shall prepare a complete SOP for documenting
the
process in detail which shall also be vetted by Compliance Division.
For all inward transfers, the instructions received shall be reviewed to confirm that:
The remittance is in line with the pattern of the account/ the information captured in KYCF.
Name and address/ or bank reference of remitter is available in the message.
Wire transfers with incomplete originator information may be seen with suspicion which may
require reporting to FMU or termination of the transaction. Bank should remain careful from
financial institutions which do not comply with aforesaid requirements by limiting or
terminating business relationship.
Where the bank is acting as an intermediary institution in passing onward message or payment
instruction, it shall maintain all the required originator information with the wire transfer.
21. Trade Finance Transaction & Related AML Risk:
21.1 Screening of Transaction:
All trade related, imports/exports transactions i.e. L/Cs, Bill Purchase, Export Bill discounting etc.
are required to be filtered through the OFAC/ UN Sanction. In this respect, our Banks customers
and their counter party's name should be filtered through these lists.
All commercial remittance transactions are also required to be filtered through the OFAC / UN
Sanction. Similarly, our Banks customers and their counter party's name should be filtered
through these lists.
The CPU-Trade shall formalize the process and develop the SOP covering the above activity.
Moreover, all such screening shall be documented to remain available for future references and
audit purpose. In this reference, the CPU-Trade shall coordinate, where necessary, with I.T. in
coordination of Compliance Division to automate the process. However, where automation is not
available, till such time, the manual records must be maintained and remain available as
desired
above.
21.2 Sanctioned Countries:
Bank should not provide any trade related facilities to/from sanctioned countries. Trade Finance
activities comprise a mix of money transmission conduits, default undertakings, performance
undertakings and the provision of credit facilities. Concerned departments/segments involved in
the finance of trade are required to adopt risk based policies and controls before entering into
business relationship with counter parties ensuring that parties with whom Bank is being
involved
in doing business do not fall under Sanctioned Countries. Also refer section 9 Risk
Categorization -
prohibited customers and section 25 Unacceptable Customers for further details.
Further, necessary due diligence must be conducted while entertaining trade transactions to
ascertain that our customers suppliers/buyers do not fall in sanctioned states. Similarly, the
vessels
which carry the goods do not belong to the sanctioned countries/areas. Moreover, due
consideration must be given and close coordination must be made with the relevant authorities
to
ensure that the vessels, in case of transshipments/stopovers, do not have touched any
sanctioned
states or ports.
21.3Review and Monitoring Trade Related Activities & Remittance (Commercial &
Home):
CPU-TradeFinanceshallreporttoComplianceDivisionAMLUnitat
Complianceamlunit@summitbank.com.pk cases where any relationship matches with proscribed
entities/individuals and/or CDD/EDD cannot be satisfactorily completed.
CPU-Trade/Home Remittance are required to make all possible eforts for completing due
diligence process satisfactory before execution of any transaction, and in case there are any
doubts,
the same shall be immediately reported to the Compliance Division- AML Unit of the bank. For
meticulous compliance, CPU-Trade/ Home Remittance shall prepare a complete SOP for their
respective areas. The SOP shall also include that in case of beneficiary institution, the bank shall
adopt risk-based internal policies, procedures and controls for identifying and handling in-
coming
wire transfers that are not accompanied by complete originator information. The incomplete
originator information may be considered as a factor in assessing whether the transaction is
suspicious and whether it merits reporting to FMU or termination thereof is necessary.
While doing the due diligence process, CPU Trade Finance/Home Remittance Department are
also
required to check whether the suppliers/buyers of Banks customers with whom the transaction
is
intended to be made falls in high risk jurisdiction(refer section 9 Risk Categorization High risk
customers for details). In case of any match, the bank must conduct Enhanced Due Diligence
(refer section 11 of Enhanced Due Diligence (EDD for details). In this respect, necessary
coordination with the Branch may also be made by CPU-Trade/Home Remittance to ascertain the
genuineness and satisfaction. However, if as a result of EDD, the CPU-Trade/Home Remittance
Department is not satisfied then all such cases with the finding of CPU-Trade must be
immediately
emailed
The AML to complianceamlunit@summitbank.com.pk
Unit with the
within Compliance Division must also review thesubject STR-Customer
remittance transactionsName
on an
ongoing basis as per their SOP of Transaction Monitoring. Reference may also be made to
section 17.2 Direct Monitoring of Daily Transactions by Compliance Division.
All records of due diligence exercise shall be retained for audit purposes and future references
as
per the SBP guidelines and Banks approved Record Retention Policy and SOP.
CPU Trade & Remittances shall remain cautious when entering into business relationship or
before
entering into transactions with institutions which do not comply with the standard requirements
set
out for wire transfers by limiting or even terminating business relationship with them. In this
regard, any such finding or observations must be reported to Financial Institutions Division (FID)
for their information and further action.
22. Advances Granting Loans/Extending Facilities & Due Diligence:
Segments/departments involved in granting loans/advances and extending facilities are

required to
complete their due diligence process as documented in their respective SOPs/Policies and
complete
their procedures as per SBP Prudential Regulations issued from time to time.
Extending advances/ loans to prohibited/unacceptable customers and customer from
Sanctioned
countries should be avoided. Moreover, while executing loans/advances to customers falling
under
high risk category, EDD shall be applied. Concerned segments should also consider the
beneficial
owners of the firm/FI while giving/extending loans to the companies. Enhanced measures should
be conducted where borrowers are related counter parties or connected borrowers. It should
of loan
also be utilization should be made part of the overall monitoring process. Moreover, while
extending
ensured thatloan facilities
loans or establishing
disbursed relationships,
are being used the Banks
for legitimate policy
purposes. Infor
thisRelated
regard,Party
the must
also be complied with.
monitoring
Segment must also keep all the required documentations as per the requirement of SBP
regulations
& Banks internal policies/ SOPs in their records and retained till the required time period.
22.1 Suspicious Activity in Credit Transactions:
Concerned segments shall monitor and review the credit transactions in their customers
account as
per their SOPs and any suspicious activities/ usual transactions must be reported to Compliance
Division AML Unit for further inquiry. Few examples of suspicious activities are appended
below for reference:
Customer suddenly pays of a large problem loan with no plausible explanation as to the
source of funds.
Customer purchases certificates of deposit and uses them as collateral for a loan.
Customer deposits huge amount of cash, either in one transaction or in structured form by
breaking the amount, to settle the loan.
23. Hold Mail Accounts
Hold mail accounts will NOT be accepted unless approved by Branch Manager/Operations
Manager, who will note the justification on the KYCF. If approved and accepted, the full address
shall be obtained and verified through a letter sent by registered post/courier. Customers will
also
have to agree to visit the Bank at least twice a year to review and collect all their statements/
advices.
All Hold Mail accounts will be reviewed at least once in six months by the Branch/Operations
Manager to ensure that the above requirement is met. In case of non-compliance, a letter will
be
sent to the customer giving him 30 days time to meet the requirement. If satisfactory resolution
is
not achieved, the branch management would need to include such an account in its fortnightly
review and take necessary action towards blocking the account.
24. High Risk Customers
The following categories of relationship pose higher than average risk and require additional
caution and scrutiny:
Politically exposed persons which include senior government officials, senior executive of a
government owned / controlled company, politicians and their family members or related
companies or business associations.
Accounts of moneychangers/exchange companies.
Clubs, societies, Trusts, NGOs and charitable organizations. (PF Trust Accounts Excluded)
Accounts opened under power of attorney.
Non-resident accounts.
Accounts of foreign nationals.
Accounts of customers conducting business in countries that are known for drug production
and transshipment.
Arms dealers
Cash Intensive businesses
All the accounts in the above categories may only be opened after taking Compliance opinion
on
AML risks involved with the entity and the persons associated. Further, the responsibility
regarding completion and scrutiny of documents rests with the Branches and CPU-Account
Opening.
It is mandatory that all accounts categorized in above categories shall be opened after the
approval
of Senior Management as defined in the account opening SOP.
Even after opening of such accounts, branches are required to exercise more frequent
monitoring of
transactions of such accounts and updating of information in KYCF shall be done to ensure
enhanced due diligence.
25. Unacceptable Customers
A number of customer types have been identified to be of very high susceptibility to money
laundering and terrorist financing. These customer types are prohibited from opening an
account
with our bank.
Entities/countries/individuals falling under the sanction, appearing in the internationally
accepted embargo list such as US Treasury (OFAC)/UN Sanction. Also refer section 9 Risk
Categorization -prohibited customers for further details.
Entities/individuals banned by the regulatory authorities.
Anonymous/ Fictitious/ Numbered accounts
Known beneficiaries of corruption or illegal activities.
Accounts where Due Diligence could not be completed or do not have verifiable source of
income.
Shell companies.
Pawnbrokers- A pawnbroker is an individual or business (pawnshop or pawn shop)
that
ofers secured loans to people, with items of personal property used as
collateral. accounts in personal names of the government officials.
Government
Customer's link to ofshore centers or tax heavens.
Ofshore Companies Companies formed and only operating outside Pakistan.
Special name accounts- account using a number or a name (set of characters) that is not
the
actual name of the customer (primary holder of the account).
Further details can also be found at Annexure- K.
Furthermore, the Bank shall not provide any banking services to proscribed entities and persons
or
to those who are known for their association with such entities and persons, whether under the
proscribed name or with a diferent name. The bank shall monitor its relationships on a
continuous
basis and will ensure that no such relationship exists. If any such relationship is found, the same
shall be immediately reported to Financial Monitoring Unit (FMU) via AML Unit-Compliance
Division in the loop and other actions shall be taken as per law and existing polices /
26. Employee Due Diligence
procedures.
A comprehensive employee due diligence policy and procedure shall be implemented/ carried
out
at the time of hiring all employees permanent, contractual, or through outsourcing. This shall
include but not limited to verification of antecedents and screening procedures to verify that
person
being inducted/ hired has a clean history. In this regard a detailed and comprehensive SOP shall
be
27. Review
prepared byofthe
Products and Services
HR Division and approved by the Management for meticulous compliance.
Every new product or service that Summit Bank intends or plans to introduce shall be reviewed
by
Compliance Division so as to identify and assess Money Laundering/ Terrorist Financing (ML/TF)
risks that may arise in relation to new products, services, business practices and delivery
mechanisms including the review of existing products and services on on-going basis.
In this regard, before the launch of any new product/service, the product brief and operating
SOP
shall be submitted to Compliance Division bearing signatures of Head of Operations, Head of
Risk,
Head of I.T. and Head of Internal Control Unit confirming that all the pre-launch requirements
have been completed and checked. . Furthermore, once detail Program/Manual/SOP is prepared,
the same should also be vetted by all stakeholders including Compliance Division.
The Head of Compliance & Control shall review the same and put his/her comment in writing
and
sign of the document accordingly. For existing products/services, the stakeholder/business
owner
of the product/service shall review the same as per the Compliance Program and submit the
same
28. Tax Evasion:
to Head of Compliance & Control for his/her review and comments.
Tax evasion is the illegal evasion of taxes by individuals, corporations, and trusts. Tax evasion
often entails taxpayers deliberately misrepresenting the true state of their afairs to the tax
authorities to reduce their tax liability and includes dishonest tax reporting, such as declaring
less
income, profits or gains than the amounts actually earned, or overstating deduction.
During the monitoring of accounts, branch should monitor those accounts which are layered
funds
for evaded tax. Often customers close their old account and open new account for tax evasion
purpose. Such accounts should be reported to AML Unit - Compliance Division. The AML - CD
will immediately scrutinize and if deemed fit, report to Financial Monitoring Unit (FMU) after
consultation with Business Head (if necessary). The Compliance Division may also approach
senior management for their expertise and guidance.
29. Tipping Of
Every employee of the bank is strictly prohibited from disclosing the fact to the customer or any
other quarter, that a suspicious transaction or related information is being or has been reported
to
any authority (even to Head Office), except if required by law
30. AML Training and Awareness
All the staf in the branches in particular and rest of the Bank in general, shall be adequately
trained to ensure that they are:
Aware of their responsibilities viz a viz various anti- money laundering regulations issued by
SBP and other agencies. This shall include their responsibility for obtaining sufficient
evidence
of identity, recognizing and reporting knowledge for suspicion of Money Laundering.
Know the identity and responsibilities of the Compliance Officers.
The potential efect on the bank, its employees and customers, of any breach of the law or
regulations.
Analysis of abnormal/out of patterns transaction & alerts generated thereof for possible
reporting of suspicions transactions.
It shall be the duty of Head of Compliance & Control to ensure that Compliance staf is provided
with regular (at least on annual basis) training in accordance with the above stated objectives.
To ensure that staf is kept abreast of developments in the money laundering techniques and
prevention measures, communications shall be issued by the Compliance Division. Relevant
AML/CFT training combined with optimum use of technology is becoming inevitable due to ever
changing nature of methods and trends in illicit activities. In this connection, the bank will test
the
capability and knowledge of the relevant staf through online training and testing on periodic
basis,
ideally at least once a year
All records of training shall be properly maintained. HR will maintain a record of staf trained on
Compliance/AML issues.
Furthermore, AML Unit of Compliance Division will also consolidate records of all STRs
raised/reported by them and would use them as training tools to educate branch staf/front end
staf
for future cautions. However, it will be ensured and AML Unit Head would be responsible not to
share any STR or customer information with any staf during the training.
31. Audit
Internal Audit function, in line with Code of Corporate Governance shall regularly assess the
efectiveness of the Compliance & KYC/AML policy, Compliance program, Banks internal
policies and its compliance with regulatory requirements.
32. Insider Trading
"Insider" means- a person who is a director, chief executive, managing agent, chief accountant,
secretary or auditor of a listed company or the beneficial owner holding directly or indirectly not
less than 10% of the shares of a listed company; or a person who, is connected with the
company
or is deemed to have been connected with the company, and who is reasonably expected to
have
access, by virtue of such connection, to unpublished price sensitive information in respect of
securities of the company who has received or has had access to such unpublished price
sensitive
information. Any employee either on his own behalf or on behalf of any other person is
prohibited
from sharing, dealing, trading, communicating or counseling in securities of a company listed on
a
stock exchange on the basis of any unpublished price sensitive information.
Annexure - A
KNOW YOUR CUSTOMER (KYC) FORM / QUESTIONNAIRE
Individual/Joint Account
Account Title Account No. Branch
Customer Identity
Full Name
Address and telephone numbers abroad (if any)
Account Holders Address confirmed Yes No
Reason for Opening of Account
Normal or expected Mode of Transaction
Source of Income
Salary Business (Self Commission Remittance from abroad Others (Please

employed) Specify)
Approximate monthly
income
Years of service with present employer/years business established (if self-

employed)
Nature of business (If self-employed)
Shop Wholesaler Estate Agent Commission Agent Others (Please Specify)
Business Name
Brief Description of Business Activities (Product, geographic areas of operations, suppliers and
clientele)
Existing Relationship
Does the customer presently maintain an account with SMBL Yes No
If Yes
Account No. Branch Name
Introduction Verification (If any)

Introducers Name Account No.
Introducers Confirmation Yes No Relationship with the Customer

Obtained
Introducers Address Introducers Risk Rating
Any mail returned during last six monthsYes NO
Compliance Check
Checked to confirm that the individual account holder/Beneficial Owner is/(are) not appearing in following
lists
SBP-UN Sanction List OFAC List Other

(specify)
Hold Mail Yes No Reasons (if any)
How the Account was Opened

Walk InMarketed ByReferred By
Please also mention the name and other relevant details of the referrer if
any
Initial Deposit (In addition to cash deposited to open the account)
Amount ___________________________________
Source___________________________________
Expected Monthly Volume of Transaction (Rs) (Total Debits and Credits)

Less than 1 M1-5 M5- 25 M25-100 M100500 M Over 500 M
Expected Monthly Transaction Activity) (Total Debits and Credits)

1-1010-2525-5050-100100-500 Over 500
Documents Obtained as per policy and attached with Account Opening Form Yes No
Customers Statement: I/We undertake that the information mentioned in the KYC form is true
and
genuine. Further, I am responsible that in case of any change in my business / source of funds,
I/We shall inform the bank immediately.
Customers Signature:________________, ________________, _________________
Enhanced Due Diligence Required Yes No
Verification
BDO Name and signature Date
Account Opening Officer Name and signature Date
Branch Manager/ Operation Manager Name and Signature Date
Next Review Date: __________________

Annexure - B
KNOW YOUR CUSTOMER (KYC) FORM/ QUESTIONNAIRE
Business Account
Account No. Branch
Customer Identity
Account Title
Details (Address) of domestic and foreign branches (if any)
Account Holders Address confirmed Yes No
Normal or expected Mode of Transaction
Reason for Opening Account Collection Expense Facility Provident

s s based fund/gratuity
Others (Please
Specify)
Years business established
Nature of business
Trading Manufacturing Financial Other Services

Service
Others (Please specify)
Brief Description of Business Activities (Product, geographic areas of operations, suppliers and
clientele)
Existing Relationship
Does the customer presently maintain an account with SMBL Yes No
If Yes
Account No.Branch Name
Introduction Verification (If any)

Introducers Name Account No.
Introducers Confirmation Yes No Relationship with the Customer
Obtained
Introducers Address Introducers Risk Rating High Medium Low

Any mail returned during last six Yes NO
months
Compliance Check
Checked to confirm that the individual account holder/Beneficial Owner is/(are) not appearing in following
lists
SBP-UN Sanction List OFAC List Other (specify)
Hold Mail Yes No Reasons (if yes)
How the Account was Opened

Walk InMarketed ByReferred By
Please also mention the name and other relevant details of the referrer if
any
Initial Deposit (In addition to cash deposited to open the account)
Amount ___________________________________
Source___________________________________
Expected Monthly Volume of Transaction (Rs) (Total Debits and Credits)

Less than 1 M1-5 M5- 25 M25-100 M100500 M Over 500 M
Expected Monthly Transaction Activity (Total Debits and Credits))

1-1010-2525-5050-100 100-500 Over 500
Documents Obtained as per policy and attached with Account Opening Form Yes No
Customers Statement: I/We undertake that the information mentioned in the KYC form is true
and
genuine. Further, I am / We are responsible that in case of any change in my business / source
of
funds, I/We shall inform the bank immediately.
Customers Signature:__________________, __________________, _______________
(Authorized Signatories)
Verification
BDO Name and signature Date
Account Opening Officer Name and signature Date
Branch Manager/ Operation Manager Name and Signature Date
Next Review Date:________________

Annexure C
Customer Risk Profiling Form
Account Title:__________________________________________________________________
Risk Determinants Risk Variables/Determinants AssignedRisk

Rating (0-20)
Exceptions in getting KYC related information from
customer
High net worth customer or high value transactions
Politically exposed person, its close associate or
family member
Relatively complex control/ ownership structureCustomer
Beneficial ownership of funds may not belong to
customer
Reliability of verification measures
Hold Mail
Age of business
Business& Counter parties i.e. customers/suppliers of the
Relationshipsaccount holders are not known or in high risk areas
Use of products & services which entail non face-to-
face conduct
Customer seeks private banking or other riskier
servicesProducts & Services
Excessive use of funds remitting instruments
Customer subscribes for International/ foreign
products & services
Large wire-in/wire-out or inland online transfers
ChannelsLevel of cash based transactions
Element of anonymity in transactions
Customer is based or linked to High Risk
Jurisdictions as per FATF
Customer's link to ofshore centers or tax heavens
LocationsCustomer is based or linked to UN Sanctioned
Countries
Name matches with databases i-e World Check,
OFAC, EU lists etc.
TransactionPattern Transaction Pattern is not very clear and carries an
carries the risk of inherent risk. Further, the pattern is in line with the
being suspiciousexamples defined in the Annexure G of the policy
Any other risk factorAny determinant which the branch thinks to be
known and recorded.
Define the risk and rate each one of them
individually.
Total Risk Rating
Compliance Check
Checked to confirm that the individual account holder/Beneficial Owner is/(are) not appearing in
following lists
SBP-UN Sanction List OFAC List Other (specify)
Low Risk Scale: 0-80

Medium Risk Scale: 81-140
High Risk Scale: 141 and above*
Customer Risk Profiling: High* / Medium / Low (tick one)
*Following accounts, irrespective of the risk points achieved shall be marked as high
risk:
NGO/NPO, Trusts, Clubs, Associations, Charities.
(If yes, please fill in the EDD form)
Next Review Date:
Prepared by: _____________________

Account Opening Officer
Reviewed by: _____________________

Operation Manager
Approved by: _____________________

Branch Manager
Annexure D
GUIDE FOR RISK PROFILING
The High Risk Accounts to be reviewed half yearly.
The Medium Risk Accounts to be reviewed yearly.
The Low Risk Accounts to be reviewed after every two years. However, they may be reviewed
earlier in case required.
All accounts when deviated from their profile as per the bank's record, should be reviewed
irrespective of their next review date.
High Risk Accounts will normally be characterized by nature of account, suspicious conduct and
transactions.
Regardless of risk weights, if any customer is categorized in Medium/High risk based on

respective below profiles, the same should be adhered conservatively.
Following Risk Assessment Key will be used:
Each determinant in the CRP (Customer Risk Profiling) form shall have individual risk score
(0/5/10/20) based on inherent risk associated with it. The total score shall determine the overall
risk
rating of the customer i.e. Low/Medium/High.
FOR INDIVIDUAL ACCOUNTS:
Beneficial Owner
High Risk Where the beneficial owner is not the account operator and either of them
(beneficial owner or account operator) is resident abroad
Medium Risk Where the beneficial owner is not the account operator and both are resident in
Pakistan
Where the account operator is the beneficial owner
Low Risk
Resident / Non Resident Accounts:
High Risk Pakistani or foreign nationals not living in Pakistan

High Risk Foreign nationals resident in Pakistan
Low Risk Pakistani nationals resident in Pakistan
Source of Funds/Source Of Wealth/Countries:
High Risk:
Persons receiving income from several sources (local and international) for
consultancy/services rendered.
Account activity consisting of funds un-related to main declared source of income
and apparently not within wealth status of individual.
Persons receiving funds, which are not earned by him/her or is appeared not to be
the beneficial owner of the funds.
Medium Risk: Account activity consisting of funds un-related to main declared source of income
but within wealth status of individual, monthly remittances from abroad for family
support,
Low Risk:Salaried person, pensioners, monthly savings accounts, investment income return,
rent from customer owned property,
Inward / Outward Remittances:
High Risk:
Frequent actual inward/outward remittances not commensurate with customer's
financial standing or; Inward/outward remittances from/to the countries/territories
designated as non-cooperative by Financial Action Task Force (FATF) (currently
nil)
Medium Risk: Frequent intended or actual inward/outward remittances commensurate with
customer's financial standing
Low Risk:No or minimal intended or actual inward/outward remittance
Hold Mail:
High Risk
High Risk-High Profile Persons
High Risk: Politicians, Senior Government Officials, Government Officials In Key Public
/PSE Posts, Persons associated with Trusts, Charitable Organizations, Clubs,
Societies, Social Welfare Organizations Etc.(OR PUBLICLY KNOWN Affiliation
with religious/social welfare groups), Housewives, Self employed individuals,
Free lancers, Professionals, Landlords.
High Net Worth Individuals

Extremely wealthy persons but whose source of wealth/explanation of how it was
earned is not credible
Such persons are often served by personal/private bankers
Enquiries about the source of their wealth are discouraged
Market Reputation:
High:Bad Reputation in Society
Medium:Unknown in Society
Low:Good Reputation in Society
No Risk:Extremely good reputation supported by documented due diligence
Nature Of Business ( if self employed)

High Risk Businesses
Any cash intensive business
Import/Export of drugs, weapons, cigarettes
Exchange companies
Brokers/dealers
Travel agencies
Fund managers
Ofshore subsidiaries of corporations
Art and antique dealers
Real estate dealers/agents
Car/Boat/Plane dealerships
Jewel/Gem/Precious metal dealers
Used Truck/Auto/machine part manufactures
Arms and ammunition dealers
FOR BUSINESSES ACCOUNTS
Beneficial Owner
High Risk Where the beneficial owner is not the account operator and either of them
(beneficial owner or account operator) is resident abroad
Medium Where the beneficial owner is not the account operator and both are resident in
Pakistan
Where the account operator is the beneficial owner
Low
Source of Funds/Source of Wealth/Countries/Jurisdictions Doing Business With
High: Funds emanating from Narcotic producing countries (e.g. Iran, Afghanistan, South
America) and formerly non-cooperative FATF jurisdictions: Russia,
Liechtenstein, Israel, Lebanon, Philippines, Bahamas, Cayman Islands, Panama,
Cook Islands, Dominica, Marshall Islands, Nauru, Niue, St Kitts and Nevis,
Antigua, Barbuda, St. Vincent and the Grenadines)
High Values from European countries and North America (USA).
Medium:
Low values from other countries
Low:
Nature of Business
High Risk Businesses
Any cash intensive business
Import/Export of drugs, weapons, cigarettes
Exchange companies
Brokers/dealers
Trusts, NGOs, NPOs, Charitable Organizations, Clubs, Welfare Associations
Travel agencies
Fund managers
Ofshore subsidiaries of corporations
Art and antique dealers
Real estate dealers/agents
Car/Boat/Plane dealerships
Jewel/Gem/Precious metal dealers
Used Truck/Auto/machine part manufactures
Arms and ammunition dealers
Resident / Non Resident Company

High Risk:Companies and Corporations incorporated abroad and having their representative
office in Pakistan
Medium Risk: Companies and Corporations incorporated abroad and doing full fledge business
in
Pakistan.
Low Risk:Companies and Corporations incorporated in Pakistan
Resident / Non Resident Partners / Directors

High Risk:Non Resident Partners/Directors
Medium Risk: Resident foreign nationals will come under medium risk category
Low Risk:Resident Pakistani nationals
Business Region Clientele / Suppliers, Branch Locations
High Risk:Businesses having their clients/suppliers/branch offices located in

Outside Pakistan:
Drug Producing Countries
E.g. Columbia, the Golden Triangle in Asia (countries known for high production
of heroin like Afghanistan, Thailand, Mynanmar,Laos) Peru, Afghanistan etc.

Drug Transshipment Countries
E.g. Aruba, Hong Kong, Spain, Thailand, Turkey etc.
Bank Secrecy Havens
E.g. Switzerland, Caymans, Greece, Luxembourg, Panama, etc.
Emerging nations seeking hard currency investment
E.g. Eastern Europe, Russia,
Within Pakistan
Federally Administered Tribal Areas (FATA), Federally Administered Northern
Areas (FANA), Provincially Administered Tribal Area (PATA)
Medium Risk: Businesses having their clients/suppliers/branch offices located in countries other
the ones mentioned above
Low Risk:Domestic company with no foreign connections
Hold Mail:
High Risk
High Public Profile of partners /directors
High Risk: Politicians, Senior Government Officials, Government Officials In Key Public
/PSE Posts, Trusts, Charitable Organizations, Clubs, Societies, Social Welfare
Organizations Etc. (OR PUBLICLY KNOWN Affiliation with religious/social
welfare groups
High Net worth Individuals

Extremely wealthy persons but whose source of wealth/ explanation of how it was earned
is not credible
Such persons are often served by personal/private bankers
Inquiries about the source of their wealth are discouraged
Market Reputation: Company/ Partners & Directors:
High: Bad Reputation in Market

Medium: Unknown in Market
Low: Good Reputation in Market
No Risk: Extremely good reputation supported by documented Due Diligence
Age of Business:
High Less than one Year
Medium 1 To 5 Years
Low Over 5 Years
No Risk Government Corporations
Annexure E
Rules for Filling Risk Profiling Form
Low Risk:If the total risk score is less than 80

Medium Risk: If the total risk score is between 81 and 140
High Risk:If the total risk score is between 141 and above
Rule 1: Each element can be scored between 0 to 20 as follows:
Risk Level Points Earned
No risk 0
Low 5
Moderate 10
High 20
Note: Rating/Scoring of each determinant/variable is to be derived from Guide for Risk

Profiling- Annexure D.
Examples:
i. If the business age of the customer is 4 years, the rating assigned against Age of
Business in CRP form would be 10.
ii. If the account holder is identified as PEP at the time of account opening or during course
of business relationship, the rating against PEP in CRP would be 20.
iii. If the account is opened by a customer who is involved in a cash intensive business such
as
Boutique Owner, Restaurant Owner, Poultry Business etc, the rating against Level of
cash based transactions would be 20.
iv. If the customer has provided all the KYC related information and documentation, the
rating in CRP form against Exception in getting KYC related information from
customer would be 0.
v. If the customer is a salaried individual and have no other source of income, the rating in
CRP Form against High Net Worth Customer would be 0.
Rule 2: The total score of the matrix will identify the resultant risk rating of the customer as
defined above.
Examples:
1. After assigning rating to each and every determinant/variable in the CRP Form of the
customer the total risk rating lies in the range 0-80, the account would be termed as Low
Risk and to be reviewed every two years.
customer the total risk rating lies in the range of 81-140, the account would be termed as
Medium Risk and to be reviewed yearly.
customer
the total risk rating lies in the range of 141 and above, the account would be termed as High
Risk and to be reviewed half yearly.
However, during the course of relationship and before the review date, in case there is a change
in
customers profile or there is a change in his/her behavior, the branch shall immediately
perform
KYC/CDD and shall fill in the revised CRP form and co-ordinate with the relevant
person/officer/department for uploading the same in to the system. Proper documented record
and
system generated vouchers shall be filed with the Account Opening Form and related
Rule 3: The determinants which are categorized as High Risk in the risk profiling guidelines,
documents
shall
for records and audit purposes.
have the highest rating i.e. 20, similarly those determinants which are categorized as medium,
low or no risk shall earn points as 10, 5 and 0 respectively.
Rule 4: The risk rating may be changed during the course of relationship. The respective branch
on
such occasions shall fill in the updated CRP form and send the same to CPU for updating it in to
the system. However, the responsibility of the same to ensure that it has been updated rests
with
the respective branch only.
EDD Form Annexure F
Business relationship involving Higher Risk (Account Number)
Title of Account:
1 Account Type:
Individual Business Individual Sole Proprietor
Joint Stock Trust/NGO/Welfare Association
Others
Client Details (If not individual/Business Individual/Sole Proprietor):

Trustees/Directors/Members :
2 Please state the name of Country of Residence if 3. Please state the name of Country of
other than Pakistan:Origin if other than Pakistan:
4 Nature of business and details of Beneficial Owner: (Beneficial owners are the directors
and stake holders of the company. The details here shall include the source of income if
other than the account mentioned above, their brief profile and market reputation).
5 KYC Extracts: (Summary of KYC that includes source of income, nature of business and other
business details)
6 Source of Assets Deposited:
7 Details of mandate if given:
8 Based on your investigation state/ explain the reason for the account getting the risk point
for the above marked monitor(s):
9 Incase of any signatory who is neither a beneficial owner nor a key principal shall also be
verified if they were the principal contact with the bank acting on behalf
of directors or owners with whom the bank had little or no direct contact:
10 Means of Information collected: (Please mark as many as relevant)

Call to customer
Review of Account Statement
Review of Transaction
Internal knowledge of Customer Business
Other Source Nadra Verisys & Internet
11 Customer Verification:
NTN Annual Report E-CIB Internet
12 Market Feedback (Kindly also provide additional information about the asset i.e
Nature/Volume etc):
13 Conclusion
Based on our enhanced due diligence of the subject account we conclude that:
The conduct of account is satisfactory with no material suspicious activity with
reference to AML regulation.
The account has abnormal activity and the account needs further investigation. (Nb:
In
case the account is concluded to be marked in this category, it should be immediately
referred to Compliance Division).
CERTIFIED THAT THE ABOVE IS TRUE TO THE BEST OF OUR KNOWLEDGE
Prepared by BDO / Relationship Manager: Countersigned by CRO/Acc Opening Officer:
Approved by Branch Manager: Countersigned by Operation Manager:
Enclosure: Supporting documentation (Please list all if available)

Annexure G
Examples or Characteristics of Suspicious Transactions (Red Alerts)
That May Be a Cause for Increased Scrutiny for AML/CFT Purposes
The following are examples or characteristics of possible suspicious transactions for money
laundering or financing of terrorism. This list of situations may be taken as a means of
highlighting
the basic ways in which money may be laundered. The examples provided are not exhaustive
and
may serve only as guidance for the branches to recognize suspicious activities.
While each individual situation may not be sufficient to suggest that money laundering is taking
place, a combination of such situations may be indicative of such a transaction. A customer's
declarations
1. Transactionsregarding the
which do background
not of such
make economic transactions
sense shall bewith
or inconsistent checked for plausibility
customers businessand
explanation
or profile ofered by the customer may be accepted after reasonable scrutiny.
i) A customers relationship having a large number of accounts with the same bank, frequent
transfers between diferent accounts or exaggeratedly high liquidity;
ii) Transactions in which assets are withdrawn immediately after being deposited, unless the
customer's business activities furnish a plausible reason for immediate withdrawal;
iii) Transactions that cannot be reconciled with the usual activities of the customer, for example,
the use of Letters of Credit and other methods of trade finance to move money between
countries
where such trade is not consistent with the customer's usual business;
iv) Provision of bank guarantees or indemnities as collateral for loans between third parties that
are
not in conformity with market conditions;
v) Unexpected repayment of an overdue credit without any plausible explanation;
vi) Back-to-back loans without any identifiable and legally admissible purpose;
vii) Paying in large third party cheques endorsed in favour of the customer;
viii) Substantial increases in deposits of cash or negotiable instruments 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 company and trust accounts;
ix) High velocity of funds through an account, i.e., low beginning and ending daily balances,
which
do not reflect the large volume of funds flowing through an account;
x) Mixing of cash deposits and monetary instruments in an account in which such transactions
do
not appear to have any relation to the normal use of the account;
xi) Multiple transactions carried out on the same day at the same branch of a financial
institution
but with an apparent attempt to use diferent tellers;
xii) The structuring of deposits through multiple branches of the same bank or by groups of
individuals who enter a single branch at the same time;
xiii) The deposit or withdrawal of cash in amounts which fall consistently just below
identification
or reporting thresholds;
xiv) The deposit or withdrawal of multiple monetary instruments at amounts which fall
consistently just below identification or reporting thresholds, if any, particularly if the
instruments
are sequentially numbered;
xv) Customers making large and frequent deposits but cheques drawn on the accounts are
mostly
to counter-parties not normally associated with customers business;
xvi) Extensive or increased use of safe deposit facilities that do not appear to be justified by the
customer's personal or business activities;
xvii) Goods or services purchased by the business do not match the customer's stated line of
business;
xviii) A retail business has dramatically diferent patterns of currency deposits from similar
businesses in the same general location;
xix) Loans are made for, or are paid on behalf of, a third party with no reasonable explanation;
xx) Suspicious movements of funds occur from one financial institution to another, and then
funds
are moved back to the first financial institution.
xxi) The deposit of excess balance in the accounts linked to credit cards/store value
cards
xxii) Unusual pattern of purchase through credit cards/store value cards etc.
2. Transactions involving large amounts of cash
i) Exchanging an unusually large amount of small-denominated notes for those of higher
denomination;
ii) Purchasing or selling of foreign currencies in substantial amounts by cash settlement despite
the
customer having an account with the bank;
iii) Frequent withdrawal of large amounts by means of cheques, including travelers cheques;
iv) Large cash withdrawals from a previously dormant/inactive account, or from an account
which
has just received an unexpected large credit locally or from abroad;
v) Large cash withdrawals made from a personal or business account not normally associated
with
customers profile;
vi) Company transactions, both deposits and withdrawals, that are denominated by unusually
large
amounts of cash, rather than by way of debits and credits normally associated with the normal
commercial etc;
vii) Depositing cash by means of numerous credit slips by a customer such that the amount of
each
deposit is not substantial, but the total of which is substantial;
viii) The deposit of unusually large amounts of cash by a customer to cover requests for
bankers'
drafts, money transfers or other negotiable and readily marketable money instruments;
3.
ix)Transactions
Customers who involving locations
together, of concern & wire
and simultaneously, usetransfers
separate tellers to conduct large cash
i) Transactions
transactions or involving foreign currency
foreign exchange exchanges or deposits that are followed within a short
transactions
time by wire
x) Large cashtransfers
deposits to locations
made to theofaccount
specificofconcern (for example,
an individual or legal countries identified
entity when by
the apparent
national authorities/international bodies, UN or FATF etc.);
business activity of the individual or entity would normally be conducted in cheques or other
ii) A personal
payment or business account through which a large number of incoming or outgoing wire
instruments.
transfers take place without logical business or other economic purpose, particularly when this
activity is to, through or from locations of specific concern (as mentioned above);
iii) The use of multiple accounts to collect and then funnel funds to a small number of foreign
beneficiaries, both individuals and businesses, particularly when these are in locations of
specific
concern (as mentioned above);
iv) Obtaining credit instruments or engaging in commercial financial transactions involving
movement of funds to or from locations of specific concern when there appears to be no logical
business reasons for dealing with those locations (as mentioned above);
v) The opening of accounts of financial institutions from locations of specific concern (as
mentioned above);
vi) The business relationships conducted in unusual circumstances e.g. significant unexplained
geographic distance between the bank and the customer;
vii) The receipt of small or large amounts (in cash, using online or otherwise) from various
locations from within the country especially if such deposits are subsequently transferred within
a
short period out of the account and/or to a destination not normally associated with the
customer;
viii) Substantial increase in cash deposits by a customer without apparent cause, especially if
such
deposits are subsequently transferred within a short period out of the account and/or to a
destination not normally associated with the customer;
ix) Building up large balances, not consistent with the known turnover of the customer's
business,
and subsequent transfer to account(s) held overseas;
x) Transfer of money abroad by an interim customer in the absence of any legitimate reason;
xi) Repeated transfers of large amounts of money abroad accompanied by the instruction to pay
the
beneficiary in cash;
xii) Large and regular payments that cannot be clearly identified as bona fide transactions, from
and to countries or geographic areas areas identified by credible sources;
as having significant levels of corruption, or other criminal activity

as providing funding or support for terrorism activities
as associated with the production, processing or marketing of narcotics or other illegal
drugs etc.
xiii) Wire transfers ordered in small amounts in an apparent efort to avoid triggering
identification
or reporting requirements;
xiv) Wire transfers to or for an individual where information on the originator, or the person on
whose behalf the transaction is conducted, is not provided with the wire transfer, when the
inclusion
4. of such
Transactions information
involving would beparties
unidentified expected;
xv) Use of multiple
i) Provision personal
of collateral andofbusiness
by way pledge oraccounts or the
guarantee accounts
without of non-profit
any discernible organizations
plausible reason
or
by
charities
third to collect
parties unknown andtothen
the funnel funds
bank and whoimmediately or after a close
have no identifiable short relationship
time to a small
withnumber
the of
foreign beneficiaries.
customer;
xvi) Customer
ii) Transfer who generally
of money to anotherusebank
credit cards/store
without valueofcards
indication out of their defined geographical
the beneficiary;
location
iii) or locations
Payment prone
orders with to money
inaccurate launderingconcerning
information and terrorist
thefinancing.
person placing the orders;
iv) Use of pseudonyms or numbered accounts for efecting commercial transactions by
enterprises
active in trade and industry;
v) Customers holding in trust of shares in an unlisted company whose activities cannot be
ascertained by the bank;
vi) Customers who wish to maintain a number of trustee or clients' accounts that do not appear
consistent with their type of business, including transactions that involve nominee names.
5. Other suspicious accounts or customers
i) Large sums deposited through cheques or otherwise in newly opened accounts which may be
suspicious;
ii) The customers who are reluctant to provide minimal information or provide false or
misleading
information or, when applying to open an account, provide information that is difficult or
expensive for the bank to verify;
iii) An account opened in the name of a moneychanger that receives structured deposits;
iv) Customers whose deposits contain counterfeit notes or forged instruments;
v) An account operated in the name of an ofshore company with structured movement of
funds;
vi) Accounts that receive relevant periodical deposits and are dormant at other periods. These
accounts are then used in creating a legitimate appearing financial background through which
additional fraudulent activities may be carried out;
vii) A dormant account containing a minimal sum suddenly receives a deposit or series of
deposits
followed by daily cash withdrawals that continue until the sum so received has been removed;
viii) An account for which several persons have signature authority, yet these persons appear to
have no relation among each other (either family ties or business relationship);
ix) An account opened by a legal entity or an organization that has the same address as other
legal
entities or organizations but for which the same person or persons have signature authority,
when
there is no apparent economic or legal reason for such an arrangement (for example, individuals
serving as company directors for multiple companies headquartered at the same location, etc.)
x) An account opened in the name of a recently formed legal entity and in which a higher than
expected level of deposits are made in comparison with the income of the promoter of the
entity;
xi) An account opened in the name of a legal entity that is believed to be involved in the
activities
of an association or foundation whose aims are related to the claims or demands of a terrorism
organization;
xii) An account opened in the name of a legal entity, a foundation or an association, which may
be
linked to a terrorism organization and that shows movements of funds above the expected level
of
income;
xiii) Shared address for individuals involved in cash transactions, particularly when the address
is
also a business location and/or does not seem to correspond to the stated occupation (for
example
student, unemployed, selfemployed, etc.);
xiv) Stated occupation of the customer is not commensurate with the level or type of activity
(for
example, a student or an unemployed individual who receives or sends large numbers of wire
transfers, or who makes daily maximum cash withdrawals at multiple locations over a wide
geographic area);
xv) Regarding non-profit or charitable organizations, financial transactions for which there
appears
to be no logical economic purpose or in which there appears to be no link between the stated
activity of the organization and the other parties in the transaction;
xvi) A safe deposit box is opened on behalf of a commercial entity when the business activity of
the customer is unknown or such activity does not appear to justify the use of a safe deposit
box;
xvii) Safe deposit boxes are used by individuals who do not reside or work in the institution's
service area despite the availability of such services at an institution closer to them;
xviii) Unexplained inconsistencies arising from the process of identifying or verifying the
customer
(for example, regarding previous or current country of residence, country of issue of the
passport,
countries visited according to the passport, and documents furnished to confirm name, address
and
date of birth); G shares with the branches the examples and scenarios through which money
The Annexure
xix) Official embassy
laundering could takebusiness is conducted
place. These through
shall be taken in personal accounts.
to account by the branches at the time of
xx) Large deposits on pretext of transfer/disposition of property.
account opening and during the course of relationship and any deviation or slightest suspicion
xxi)
shallFrequent and unusual advance payments against imports.
be immediately investigated and the same shall be reported to the Compliance Division for
further
action and reporting if necessary.
Apart from the scenario as mentioned in Appendix G, there may be other avenue for money
launderers which might be used for their illicit means. The branches officers, specially Tellers,
Operation and Branch Managers shall remain vigilant at all times and shall review the customer
activities on daily basis. Any deviation from the customer profile or any abnormal behavior
noted,
shall be immediately reported to the Compliance Division.
Annexure H
KEY DEFINITIONS MEANING AND INTERPRETATIONS
The Annexure covers the definition which must be known to the person dealing with KYC/CDD,
AML/CFT and general operations in Bank Accounts. It is recommended that one should have
complete understanding of the concepts and the desired results before dealing with
customers/employees/stakeholders.
1. Beneficial owner in relation to a customer of a bank/ DFI, means the natural person(s) who
ultimately own(s) or controls a customer or the person on whose behalf a transaction is being
conducted and includes the person(s) who exercise(s) ultimate efective control over a person or
a
body of persons whether incorporated or not;
2. Beneficiary means the person to whom or for whose benefit the funds are sent or deposited
in
bank;
3. Beneficiary institution means the financial institution that receives the funds on behalf of
the
wire transfer or fund transfer beneficiary;
4. Control in relation to a legal person, means the power to exercise a controlling influence
over
the management or the policies of the undertaking, and, in relation to shares, means the power
to
exercise a controlling influence over the voting power attached to such shares;
5. Correspondent bank means the bank in Pakistan which provides correspondent banking
services to bank or financial institution situated abroad and vice versa;
6. Correspondent banking means provision of banking services by one bank (correspondent)

to
another bank (respondent) including but not limited to opening and maintaining accounts in
diferent currencies, fund transfers, cheque clearing, payable through accounts, foreign
exchanges
services or similar other banking services;
7. Cross-border wire transfer means a wire transfer where the ordering institution and the
beneficiary institution are located in diferent countries or jurisdictions;
8. Currency Transaction Report or CTR means as defined under AML Act;
9. Customer
10. Customer means a person
due diligence or having
CDD inrelationship withincludes;
broader terms the bank which includes but not limited
to identifying the customer and verifying the customers identity on the basis of documents,
a)
holding
data or of deposit/deposit certificate/ or any instrument representing deposit/placing of money
with a bank/DFI,
information availing
obtained fromother financial
customer services,
and/or locker facility,
from reliable safe deposit
and independent facility, or custodial
sources;
services
b) from the
identifying, bank/DFI;
where there is a beneficial owner who is not the customer, the beneficial owner
and
taking adequate measures, to verify his identity so that the bank/DFI is satisfied that it knows
who
the beneficial owner is, including, in the case of a legal person, trust or similar legal
arrangement,
measures to understand the ownership and control structure of the person, trust or
arrangement;
c) understanding and, as appropriate, obtaining information on the purpose and intended nature
of
the business relationship; and
d) monitoring of accounts/transactions on ongoing basis to ensure that the transactions being
conducted are consistent with the banks/DFIs knowledge of the customer, their business and
risk
profile, including, where necessary, the source of funds and, updating records and data/
information to take prompt action when there is material departure from usual and expected
activity through regular matching with information already available with bank/DFI.
11. Domestic wire transfer means any wire transfer where the originator and beneficiary
institutions are located in Pakistan regardless the system used to efect such wire transfer is
located
in another jurisdiction;
12. Dormant or in-operative account means the account in which no transaction has been
taken place from last one year;
13. FATF Recommendations means the Recommendations of Financial Action Task Force as
amended from time to time;
14. FMU means financial monitoring unit established under the AML Act;
15. Fund transfer/wire transfer means any transaction carried out by financial institution on
behalf of originator person by way of electronic means or otherwise to make an amount of
money
available to beneficiary person at another beneficiary institution, irrespective of whether the
originator and the beneficiary are the same person;
16. Government entity means federal or provincial government, a ministry within such a
government, a local government or an agency specially established by any such government, or
a
department, organization or corporation owned or controlled by such government under federal,
provincial or local law;
17. Intermediary institution is an intermediary in the wire transfer payment chain; that
receives
and transmits a wire transfer on behalf of the ordering institution and the beneficiary institution,
or
another intermediary institution;
18. Monetary threshold expressed in Pak rupee includes a reference to the equivalent amount
expressed in any other currency;
19. Money laundering and financing of terrorism or ML/TF has the same meaning as
ascribed to them in AML Act;
20. Occasional customer or walk-in-customer means the person conducting occasional

transactions and is not a customer; having relationship with the bank/DFI;
21. Occasional transaction or walk-in-transaction means a transaction carried by or on

behalf of a person who is not a customer; having relationship with the bank/DFI;
22. Online transaction means deposit or withdrawal of cash using diferent branches of a bank
through electronic means;
23. Ordering institution means the financial institution that initiates a wire transfer on the
instructions of the wire transfer originator in transferring the funds;
24. Originator means the person who allows or places the order to initiate a fund transfer/wire
transfer or an online transaction;
25. Payable-through account means an account maintained at the correspondent bank by the
respondent bank which is accessible directly by a third party to efect transactions on its own
(respondent banks ) behalf;
26. Person has the same meaning as ascribed to it under the AML Act, 2010;
27. Politically exposed persons or PEPs are individuals who are entrusted with prominent
public functions either domestically or by a foreign country, or in an international organization,
for
example Heads of State or of government, senior politicians, senior government, judicial or

military officials, senior executives of state owned corporations/departments/autonomous
bodies.
This does not intend to cover middle ranking or more junior individuals in the foregoing
categories;
28. Respondent bank means the bank or financial institution outside Pakistan to whom
correspondent banking services in Pakistan are provided and vice versa;
29. Risk refers to risk associated with money laundering and financing of
terrorism;
30. Senior management means the officer(s) not below the rank of Executive Vice President
as
designated by the board of a bank/DFI for the purpose of AML/CFT regulations;
31. Shell bank means a bank that has no physical presence (mind and management), in the
country in which it is incorporated and licensed and/or which is not affiliated with a regulated
financial services group that is subject to efective consolidated supervision; and
32. Supplementary Document means additional supporting document that were provided
at the account opening/last KYC review. E.g contractual employment validity of 12 month.
33. Suspicious transaction report or STR means as defined under AML Act.
Annexure-I
MINIMUM DOCUMENTS TO BE OBTAINED FROM VARIOUS TYPES OF

CUSTOMERS / ACCOUNT HOLDER(S) UNDER AML/CFT REGULATIONS
Sr. Natureof Documents / papers to be obtained

No. Account
1 Individuals
A photocopy of any one of the following valid identity documents;
(i) Computerized National Identity Card (CNIC) issued by NADRA.
(ii) National Identity Card for Overseas Pakistani (NICOP) issued by
NADRA.
(iii) Pakistan Origin Card (POC) issued by NADRA.
(iv) Alien Registration Card (ARC) issued by National Aliens Registration
Authority (NARA), Ministry of Interior (local currency account only).
(v) Passport; having valid visa on it or any other proof of legal stay along
with passport (foreign national individuals only).
Sole(i) Photocopy of identity document as per Sr. No. 1 above of the proprietor.
2 Proprietors(ii) Registration certificate for registered concerns.
(iii) Sales tax registration or NTN, wherever applicable.
(iv) Certificate or proof of membership of trade bodies etc, wherever
applicable.
(v) Declaration of sole proprietorship on business letter head.
(vi) Account opening requisition on business letter head.
Partnership(i) Photocopies of identity documents as per Sr. No. 1above of all the
partners and
3 authorized signatories.
(ii) Attested copy of Partnership Deed duly signed by all partners of the
firm.
(iii) Attested copy of Registration Certificate with Registrar of Firms. In
case the
partnership is unregistered, this fact shall be clearly mentioned on the
Account
Opening Form.
(iv) Authority letter from all partners, in original, authorizing the person(s)
to
operate firms account.
LimitedLimited Companies / Corporations
Companies / (i) Certified copies of:
Corporations(a) Resolution of Board of Directors for opening of account specifying
the person(s) authorized to open and operate the account.
4
(b) Memorandum and Articles of Association.
(c) Certificate of Incorporation.
(d) Certificate of Commencement of Business, wherever applicable.
(e) List of Directors on Form-A/Form-B issued under Companies
Ordinance 1984, as applicable; and
(f) Form-29, wherever applicable;
(ii) Photocopies of identity documents as per Sr. No. 1 above of all the
directors and persons authorized to open and operate the account.
(iii) For individual (natural person) shareholders holding 20% or above stake
(10% or above in case of EDD) in an entity, identification and verification
of such natural persons; and
(iv) For legal persons holding shares equal to 20% or above in an entity,
identification and verification of individual (natural person) shareholders
holding shares equal to 20% or above of that legal person.
5 Branch Office (i) A copy of permission letter from relevant authority i-e Board of
or Investment.
Liaison Office (ii) Photocopies of valid passports of all the signatories of account.
of (iii) List of directors on company letter head or prescribed format under
Foreign relevant laws/regulations.
Companies (iv) A Letter from Principal Office of the entity authorizing the person(s) to
open and operate the account.
(i) Certified copies of
6 Trusts, Clubs, (a) Certificate of Registration/Instrument of Trust
Societies and (b) By-laws/Rules & Regulations
Associations (ii) Resolution of the Governing Body/Board of Trustees/Executive
Committee, if it is ultimate governing body, for opening of account
authorizing the person(s) to operate the account.
(iii) Photocopy of identity document as per Sr. No. 1 above of the
authorized person(s) and of the members of Governing Body/Board of
Trustees /Executive
Committee, if it is ultimate governing body.
Certified copies of
(a) Registration documents/certificate
7 NGOs/NPOs/ (b) By-laws/Rules & Regulations
Charities (ii) Resolution of the Governing Body/Board of Trustees/Executive
Committee, if it is ultimate governing body, for opening of account
authorizing
the person(s) to operate the account.
(iii) Photocopy of identity document as per Sr. No. 1 above of the
authorized person(s) and of the members of Governing Body/Board of
Trustees /Executive
Committee, if it is ultimate governing body.
(iv) Any other documents as deemed necessary including its annual
accounts/ financial statements or disclosures in any form which may help to
ascertain the detail of its activities, sources and usage of funds in order to
assess the risk profile of the prospective customer.
(i) Certified copy of Power of Attorney or Agency Agreement.
(ii) Photocopy of identity document as per Sr. No. 1 above of the agent and
principal.
(iii) The relevant documents/papers from Sr. No. 2 to 7, if agent or the
8 Agents principal is not a natural person.
Accounts (i) Photocopy of identity document as per Sr. No. 1 above of the
Executor/Administrator.
(ii) A certified copy of Letter of Administration or Probate.
9 Executors and
Administrators
10 Minor (i) Form-B, Birth Certificate or Student ID card (as appropriate) shall be
Accounts obtained from minor.
(ii) Photocopy of identity document as per Sr. No. 1 above of the guardian
of the minor.
Note:
1. The photocopies of identity documents shall invariably be attested by Gazetted officer/

Nazim/Administrator or an officer of bank after original seen.
2. In case of a salaried person, in addition to CNIC, an attested copy of his service card, or any
other acceptable evidence of service, including, but not limited to a certificate from the
employer will be obtained.
3. In case of an individual with shaky/immature signatures, in addition to CNIC, a passport size
photograph of the new account holder besides taking his right and left thumb impression on
the specimen signature card will be obtained.
4. In case of expired CNIC, account may be opened on the basis of attested copies of NADRA
receipt/token and expired CNIC subject to condition that Bank/branch shall obtain copy of
renewed CNIC of such customer within 03 months of the opening of account. For CNICs
which expire during the course of the customers banking relationship, Bank/branch shall
design/ update their systems which can generate alerts about the expiry of CNICs at least 01
month before actual date of expiry and shall continue to take reasonable measures to
immediately obtain copies of renewed CNICs, whenever expired.
5. In case the CNIC does not contain a photograph, bank/branch shall obtain following:
(i) A duly attested copy of either driving license, service card, Nikkah Nama, birth certificate,
Educational degree/certificate, pension book, insurance certificate.
(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.
6. Bank/branches shall obtain copies of CNICs of all the members of Governing and Executive
Bodies of DHA or ask for delegation of power to Administrator under section (7) & (8) of the
Pakistan Defence Housing Authority Order, 1980 and accept copy of CNIC of Administrator
as well as authorized signatories for the purpose of opening accounts of DHA or similar other
authorities subject to compliance of other requirements.
7. The condition of obtaining Board Resolution is not necessary for foreign companies/entities
belonging to countries where said requirements are not enforced under their laws/regulations.
However, such foreign companies will have to furnish Power of Attorney from the competent
authority for opening bank accounts to the satisfaction of their banks.
Annexure- J
SPECIFIC HIGH RISK ELEMENTS AND RECOMMENDATIONS FOR EDD
S.NO Customer Recommendations for EDD

1 NPOs/NGOs/ In relation to these customers, bank/branches may:
Charities, Trusts, Clubs, (i) obtain a declaration from Governing Body/Board of
Societies, and Trustees/Executive Committee/sponsors on ultimate
Associations etc control,
purpose and source of funds etc;
(ii) obtain an undertaking from Governing Body/Board of
Trustees/Executive Committee /sponsors to inform the
bank/DFI about any change of control or
ownership during operation of the account; and
(iii) obtain a fresh Resolution of the Governing
Body/Executive Committee of the entity in
case of change in person(s) authorized to
operate the account.
In relation to housewife accounts, bank/branches
may
2 Housewife accounts (i) obtain a self-declaration for source and
beneficial ownership of funds;
(ii) Update details of funds providers, if any
along with customers profile; and
(iii) Identify and verify funds providers if
monthly credit turnover exceeds the threshold as
prescribed by the Management.
In case there is resistance from the customer in providing

the required documentations at the time of account
opening, establishing the relationship with such
customers should be avoided.
Moreover, all the required documents should be kept in

record for audit purposes. Refer 11.3 Housewife
Account for details.
3 Proprietorships and self In relation to these accounts, following measures

employed individuals/ are to be taken by bank/branches:
professionals (i) The business transactions in personal accounts of
proprietors may only be permitted by linking it with
account/business turnover. For example, such customers
having monthly credit turnover of Rs. 5 million or above
may be required to open a separate account for business
related transactions; and
(ii) In order to verify the physical existence of business or
self-employment status, bank/branches may conduct
physical verification within 05 working days of the
opening of account and document the results thereof on
account opening form. In case of unsatisfactory
verification, bank/branch may consider reporting it to
AML Unit/FMU and/or may change risk profile, as
appropriate.
In case branches are not able to satisfactorily complete

required CDD measures, account shall not be opened or
any service provided and consideration shall be given if
the circumstances are suspicious so as to warrant the
filing of an STR. If CDD of an existing customer is found
unsatisfactory, the relationship should be treated as high
risk and reporting of suspicious transaction be considered
as per law and circumstances of the case.
Where the customer is maintaining registered business

but using his/her personal account for business
transaction, branch should advise the customer for
avoiding business transaction in the account. Incase if it
still continues, branch should raise STR to the
ComplianceDivisionon
complianceamlunit@summitbank.com.pkwiththe
subject as STR-Customer Name / Account Number.
4 Landlords In relation to such customers, bank/branches may apply

any recommend methods for assessment of source of
funds/income e.g. Passbook of
landholding records etc.
Recommendations for EDD
Products & Services
In relation to online transactions, Bank/branches
1 Online transactions
should pay special attention to geographical
factors/locations for movement funds.
Recommendations for EDD
Delivery Channels In relation to cash transactions, Bank/branches may:
1 Cash (i) monitor cash transactions on enhanced basis
by applying relatively stringent thresholds,
as deemed appropriate; and
(ii) pay special attention on cash based
transactions considering examples of Red
Alerts given in Annexure-II to AML/CFT
regulations.
2 Wire transfers In relation to wire transfers, bank/branches may:

(i) monitor such transactions on enhanced basis
by applying relatively stringent thresholds,
as deemed appropriate; and
(ii) Ensure that funds transfers which are out of
character/ inconsistent with the history,
pattern, source of earnings and purpose,
shall be viewed with suspicion and properly
investigated for appropriate action, as per
law.
Annexure
Annexure LK
GENERAL LOW
HIGH RISK
RISK SCENARIOS/
SCENARIOS/ FACTORS
FACTORS
Low risk
Customers A financial
Products and institution regulated/ supervised
Geography by the State Bank of
or Locations
factors for PakistanChannels
Delivery except exchange companies/ money remitters;
Customers A Non-Bank Finance Company (NBFC)The
Non-resident customersNon-face-to-face regulated/ supervised
jurisdictions which by
Securities and Exchange Commission of
Correspondent banksbusiness Pakistan (SECP)
have been identified unless
for an entity is
accountsrelationships notified
or for application of the requirements;
inadequate AML/CFT
Customers with linksAto government
transactions entity; measures by FATF or called for
ofshore tax havensCash A foreign
intensive government
or entity; by FATF for taking
Public administrations
Customers in high-valueother forms of or enterprises;
counter-measures
items etcanonymous An entity listed on any stock exchangeCountries in Pakistan; and
identified by
An entity listed on a stock exchangecredible
High net worth customerstransactions outside sources
Pakistansuchthat asis
subject to regulatory
with no clearly identifiablePayment disclosure requirements
received mutual and its information
evaluations or
source of incomefrom is unknown
publicallyor available. detailed assessment reports,
There is a doubt about Basic Banking Accounts
theun-associated third(BBA); as having inadequate
veracity
Low risk or adequacy Low value
ofparties accounts having monthly AML/CFT
credit turnover
standardsup to Rs.
available
factors for 25,000;
identificationPrivate banking Countries subject to
data Salary accounts of individuals subject
on the customerRelationships
Products to the condition
sanctions, embargos, thatforaccount is
There is reason
And Transaction tonot used
believe for other than salary purposes;
example, the United
that the customer has been
Channel Pension accounts for direct credit of Nations
pensions;
refused banking facilitiesRemittance cards restricted to receive Countries
inward remittances
identified only;
by and
by another bank/ DFI Other financial products or services credible that provide appropriately
sources as having defined
Companies that have and limited services to certain types ofsignificant
customerslevels
so as ofto increase access
nominee shareholders to or corruption, or other criminal
shares in bearer form financial services. activity
Legal persons or Country identified by credible sources such as mutual
Countries evaluation or
or geographic
arrangements that are detailed assessment reports, as adequately complying with
areas identified by credible and having
Low risk asset holding
personal efectively implemented the FATF Recommendations; and
factors sources as providing
vehiclesfor Country identified by credible sources as having
funding a low level
or support for of
Geography corruption, or other criminal activity. terrorism activities
or Locations

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COMPLIANCE & KYC/AML POLICY

COMPLIANCE & KYC/AML POLICY

Prepared by: Compliance Division

Prepared on: July 2009

1st Updated in: April 2010

2nd Updated in: March 2013

3rd Updated in: November 2013

4th Updated in: June 2016

SECTION CONTENTS PAGE

1. Introduction- What is Compliance

B KNOW YOUR CUSTOMER/ANTI MONEY LAUNDERING POLICY 10-33

17. Review and Monitoring of Transactions

Annexure Annex-A KYC Form Individual/Joint Account 34-65

Annex-B- KYC Form Business Account

Annex-C- Customer Risk Profiling Form

Annex-D- Guide for Risk Profiling

Annex-E- Rules for filling Risk Profiling Form

Annex-F- EDD Form

Annex-G- Examples of suspicious transactions

Annex-H Key Definitions- Meaning & Interpretation

Annex-I- Minimum Documents to be obtained from various type of

Annex-J-Specific High Risk Elements and Recommendation for EDD

Annex-K- General High Risk Scenarios/Factors

Annex-L -General Low Risk Scenarios/Factors

SECTION-A COMPLIANCE POLICY

Following are the main objectives of the compliance policy:

4) Role and Scope of Compliance Function

It is to be understood that compliance is not a function merely confined to the Compliance

7) Roles and Responsibilities/ Regulatory Requirement of Compliance Officers

Ensuring Compliance relating to

In order to discharge its aforementioned responsibilities efectively, Compliance Division will

The Head of Compliance & Control shall:

10) Relationship with Internal Audit & Regulatory Bodies

11) Framework to Follow

Compliance is an important mechanism that supports efective governance. Compliance with

SECTION-B KYC/AML POLICY

3. Definition of Money Laundering

customers source of income by Bank officials where desirable

o Know how the situation will be reported and investigated.

Customer due diligence or CDD in broader terms includes;

8.1 Bank would do due diligence when;

10. Timing of Verification

11. Enhanced Due Diligence (EDD)

Non- resident- Accounts of individuals, firms or companies residing in countries outside

Metal Dealers-who deal in metals, scrap metals etc.

Obtaining additional information on the customer (occupation, volume of assets, address,

11.1 Third Party Mandate Holders

11.2 Use of Personal Accounts for Business Purposes

11.3 Housewife Accounts:

12. Simplified Due Diligence (SDD)

13.1 Transactions with Non-account holders

13.2 Transactions made by Non- account holders on behalf of Customer account

16. Foreign Currency Accounts Maintenance & Monitoring

16.1 Individual Accounts Opening, Maintenance and Monitoring

16.2 Entity Accounts - Opening, Maintenance and Monitoring

17.2 Direct Monitoring of Daily Transactions by Compliance Division

17.3 Quarterly Compliance Certificate by Branches

Suitable action should be initiated where satisfactory explanations cannot be found. An

19. Correspondent Banking

20. Wire Transfers/ Fund Transfer

The following information shall be included in the transfer details:

21. Trade Finance Transaction & Related AML Risk:

21.1 Screening of Transaction:

21.2 Sanctioned Countries:

Revised Compliance & KYC AML

Revised Compliance & KYC AML

Customers Signature:, , _