Professional Documents
Culture Documents
Pakistan The content in the Customer Due Diligence section is valid for
the following calendar year:
#N/A
State Life Building, 16) What are the high level requirements for verification of
1-C; I.I.Chundrigar Road, customer identification information (individuals and legal
Karachi entities)?
As per the State Bank of Pakistan's AML/CFT Regulations (para 3 of
Regulation 1: Customer Due Diligence), for identity and due diligence
purposes, at a minimum, the following information shall also be obtained,
verified and recorded on the relevant KYC/CDD form or account opening
form:
State Life Building, For further details, please refer to the AML/CFT Regulations which can be
1-C; I.I.Chundrigar Road, accessed at: http://www.sbp.org.pk/l_frame/Revised-
Karachi AML-CFT-Regulations.pdf.
For further details, please refer to the AML/CFT Regulations which can be
accessed at: http://www.sbp.org.pk/l_frame/Revised-
AML-CFT-Regulations.pdf.
Syed Faraz Anwer 20) In what circumstances are enhanced customer due
diligence measures required?
+92 21 32426711 Section 'D' (paragraphs 4-6) of the State Bank of Pakistan's 'AML/CFT
syed.faraz.anwer@pk.pwc.co Guidelines on Risk Based Approach for Banks & DFIs' provides specific
m high risk elements and recommendations for enhanced due diligence for
certain customer types (e.g. NPOs, NGOs, charities, associations, house
State Life Building, wife accounts, landlords, proprietorships, self-employed professionals, on-
1-C; I.I.Chundrigar Road, line transactions, cash, wire transfers, etc). Paragraph 5 provides high risk
Karachi elements/factors categorised into customers, products and delivery
channels and geography or locations.
For further details, please refer to the guidelines which can be accessed at:
http://www.sbp.org.pk/l_frame/AML-CFT-Guidelines-
RiskBasedApproach.pdf.
For further details, please refer to the AML/CFT Regulations which can be
accessed at: http://www.sbp.org.pk/l_frame/Revised-
AML-CFT-Regulations.pdf.
For further details, please refer to the AML/CFT Regulations which can be
accessed at: http://www.sbp.org.pk/l_frame/Revised-
AML-CFT-Regulations.pdf.
Contact 23) Are relationships with shell banks specifically prohibited?
Syed Faraz Anwer Yes. As per paragraph 4 of Regulation 2 of the State Bank of Pakistan's
(SBP) AML/CFT Regulations, no bank/development finance institution
+92 21 32426711 (DFI) shall enter into or continue correspondent banking relations with a
syed.faraz.anwer@pk.pwc.co shell bank and shall take appropriate measures when establishing
m correspondent banking relations, to satisfy them that their respondent
banks do not permit their accounts to be used by shell banks.
State Life Building,
1-C; I.I.Chundrigar Road, For further details, please refer to the AML/CFT Regulations which can be
Karachi accessed at: http://www.sbp.org.pk/l_frame/Revised-
AML-CFT-Regulations.pdf.
India The content in the Customer Due Diligence section is valid for
the following calendar year:
#N/A
Individuals:
Corporates:
a) Certificate of incorporation;
b) Memorandum and Articles of Association;
c) a resolution from the Board of Directors and Power of Attorney granted
to its managers, officers or employees to transact on its behalf; and
d) an officially valid document in respect of managers, officers or
employees holding legal authority to transact on its behalf.
Partnership firm:
a) registration certificate;
Trust:
a) registration certificate;
b) trust deed; and
Contact c) an officially valid document in respect of the person holding a power of
attorney to transact on its behalf.
Dhruv Chawla
Unincorporated association or a body of individuals:
+91 (0) 8130166550
dhruv.chawla@in.pwc.com a) resolution of the managing body of such association or body of
individuals;
PricewaterhouseCoopers Pvt. b) power of attorney granted to transact on its behalf;
Ltd. c) an officially valid document in respect of the person holding legal
The Millenia, Tower D, 7th authority to transact on its behalf; and
Floor, 1&2 Murphy Road, d) such information as may be required by the bank/FI to collectively
Ulsoor, Bangalore - 560008 establish the legal existence of such an association or body of individuals.
India
17) Where copies of identification documentation are provided,
what are the requirements around independent verification or
authentication?
Certified copies of an official valid document(s) may be used. The copies
need to be verified by seeing the original document(s) and stamped as
'original(s) seen and verified'.
India beneficiaries with 15% or more interest in the trust and any other natural
person(s) exercising ultimate effective control over the trust through a
chain of control or ownership.
e) Where the client or the owner of the controlling interest is a company
listed on a stock exchange or is a subsidiary of such a company, it is not
necessary to identify and verify the identity of any shareholder(s) or
beneficial owner(s) of such companies.
a) non-resident customers;
b) high net worth individuals;
c) trusts, charities, NGOs and organisations receiving donations;
d) companies having a close family shareholding or beneficial ownership;
e) firms with 'sleeping partners';
f) politically exposed persons of foreign origin;
g) non face-to-face customers;
h) those with a high risk reputation (based on publicly available
information); and
i) correspondent banking relationships.
India information available on the person in the public domain. Banks should
verify the identity of the person and seek information about their source of
funds before accepting the PEP as a customer. The decision to open an
account for a PEP should be taken at a senior level and this procedures
should be clearly stipulated in the bank's customer acceptance policy.
b) the bank should also be satisfied that the respondent bank has verified
the identity of all customers having direct access to its accounts and is
undertaking ongoing due diligence on them. The bank should also ensure
that the respondent bank is able to provide the relevant customer
identification data immediately upon request.
PricewaterhouseCoopers Pvt.
Ltd.
The Millenia, Tower D, 7th
Floor, 1&2 Murphy Road,
Ulsoor, Bangalore - 560008
India
Malaysia The content in the Customer Due Diligence section is valid for
the following calendar year:
#N/A
a) all insurance policies are sold with premium amount below RM5,000
(approx. USD1,114); or
b) any single premium insurance policy is below RM10,000 (approx.
USD2,230).
Malaysia
Any transaction involving RM10,000 (approx. USD2,230) and above (e.g.
exchange cash for cash chips, exchange cash/vouchers for chip warrants,
request for cheques or wire transfers for payments of winnings/capital,
use of membership cards/temporary cards in respect of e-cash out facility,
etc.). Customer due diligence is also required on the third party when
customer requests RM10,000 (approx. USD2,230) and above to be paid to
a third party.
Contact
For licensed gaming outlets:
Alex Tan
Appropriate thresholds are decided internally based on their own risk
+60 3 2173 1338
assessment. Thresholds are not publicly disclosed.
alex.tan@my.pwc.com
For dealers in precious metals and stones:
Level 10, 1 Sentral, Jalan
Rakyat, Any cash transaction equivalent to RM50,000 (approx. USD11,146) and
Kuala Lumpur Sentral, PO above, either as a single transaction or multiple transactions on a given
Box 10192, day.
50706 Kuala Lumpur,
Malaysia 16) What are the high level requirements for verification of
customer identification information (individuals and legal
entities)?
Individuals:
a) full name;
b) date of birth;
c) nationality; and
d) permanent and mailing address and NRIC/passport number.
Legal Entities:
Alex Tan a) has performed customer due diligence (CDD) obligations on its
customers that have direct access to the accounts of the reporting
+60 3 2173 1338
institution; and
alex.tan@my.pwc.com b) is able to provide relevant CDD information to the reporting institution
upon request".
Level 10, 1 Sentral, Jalan
Rakyat, S. 20.4 "Reporting institutions shall not enter into, or continue,
Kuala Lumpur Sentral, PO correspondent banking relationships with shell banks. Reporting
Box 10192, institutions are required to satisfy themselves that respondent banks do
50706 Kuala Lumpur, not permit their accounts to be used by shell banks".
Malaysia
For the non-financial institution sector, there is no specific guideline for
correspondent banking.
Contact
Alex Tan
+60 3 2173 1338
alex.tan@my.pwc.com
Level 10, 1 Sentral, Jalan
Rakyat,
Kuala Lumpur Sentral, PO
Box 10192,
50706 Kuala Lumpur,
Malaysia
Malaysia
Contact
Alex Tan
+60 3 2173 1338
alex.tan@my.pwc.com
Level 10, 1 Sentral, Jalan
Rakyat,
Kuala Lumpur Sentral, PO
Box 10192,
50706 Kuala Lumpur,
Malaysia
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