Professional Documents
Culture Documents
The Management Committee in its 365th meeting held on 8th September 2015
approved the Compliance & Control Program for its implementation.
This document is for internal use of National Bank of Pakistan employees only. Any
act of divulgence to third parties shall be viewed seriously and warrant disciplinary
action.
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Compliance & Control Program (Revised-2015)
Contents
Items Page
Number
1. Introduction 4
Compliance Function 5
Objective 6
2. Compliance Set-up (Organogram) 6
Core Functions 8
3. Scope of Regional Compliance Work 9
Core Functions 9
Compliance & Control Program for Regional Office 11
Reporting of Prompt Exceptions to Head Office 14
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Compliance & Control Program (Revised-2015)
Home
Introduction:
Compliance is rapidly evolving as a tool for good corporate governance. The regulator has made it
mandatory for the banks to have an independent and effective compliance setup for ensuring strict
observance of all statutory provisions contained in various regulatory guidelines issued from time to
time and also bank's internal policies and fair practices code, which typically include specific areas
such as know your customer, the prevention of money laundering and terrorist financing.
A separate Compliance Set-up was introduced in the Bank vide President Office Circular No.
16/2001 dated 21st June 2001 as a part of Operations Group. Subsequently, Compliance Set-up was
separated from Operations Group and an independent Compliance Group was created vide
President Office Circular No. 05/2004 dated 22nd March, 2004. During this period, different roles,
job & scope of Compliance were defined, which sometimes created ambiguity in understanding the
actual role of the Compliance Group. The actual role of Compliance Group, as per international best
practices & SBP guidelines, is to “ensure that bank is compliant with all the policies of regulators
and internal SOPs”
The Board Audit Committee (BAC) in its 166th meeting held on 8th August 2014 directed that the
Internal Control Unit reporting at that time to Operations Group requires to be revisited for
enhancing its scope and should be merged with Compliance Group for synergy. In compliance of
the directives of BAC, the Internal Control Wing has been established in Compliance Group and
hence the Compliance Review Program (CRP) is being amended / updated to enhance the control
activities.
The function of Compliance Group is to identify the discrepancies, elevate and escalate them to the
concerned authorities and push them for their early and timely rectifications. The rectification of
discrepancy is a function of respective Group who committed the discrepancy, whether at Branch
Level, Regional Office Level or at Head Office Level. The compliance role / function has been
discussed at length in the 350th (A) Management Committee Meeting held on 21st April 2015 and the
worthy President defined the role of Compliance Group that:
“The President said that the function of Compliance Group is not to rectify the errors of
field functionaries but to get the errors rectified by field staff. Their job is to identify the
discrepancies, elevate & escalate them to the concerned authorities and push them for their
early & timely rectifications. He said that if a circular or procedures having ambiguities
were issued in the past, the same may be reviewed and corrected so that ownership of those
activities and role is taken by respective groups in order to perform their responsibilities as
per their TORs/job responsibilities. He stated that no matter, whose job was prior to now,
but now clear demarcation should be made so that this matter is resolved without any
further delay.”
The Bank’s Board of Directors in its 245th meeting held on 13.05.2015 also directed the compliance role
as quoted below:
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Compliance & Control Program (Revised-2015)
The Compliance & Control Program has been based on the aforesaid directives of the President and
Board of Directors.
Compliance Function:
Compliance function is defined as an independent function that identifies, assesses, advises,
monitors and reports on the bank’s compliance risk, that is, the risk of legal or regulatory sanctions,
financial loss, or loss to reputation a bank may suffer as a result of its failure to comply with all the
applicable laws, regulations, codes of conduct and standards of best practices.
The function of Compliance Group is to identify the discrepancies, elevate and escalate them to the
concerned authorities and push them for their early and timely rectifications. The rectification of
discrepancy is a function of respective Group who committed the discrepancy, whether at Branch
Level, Regional Office Level or at Head Office Level.
Compliance function existed in the bank from the day it came into being. All unit heads were
responsible for compliance function in their areas of jurisdiction. Internal Audit function as an
independent entity within the bank was responsible for identifying, assessing, advising, monitoring and
reporting of irregularities and exceptions through various types of audit activities.
Presently, the Compliance Set-up has been established in all the layers of the Bank i.e.:
1. Head Office
2. Regional Offices
3. Cluster Area Branches
4. Other branches of Clusters
Purpose:
The Compliance & Control Program shall provide the understanding about the work flow of various
functions of the Compliance Group. The key principle underlying the design efficacy of policies and
procedures of a control objective is the principle of segregation of duties. It would hence be
essential for each Group to demonstrate adequate segregation of duties in terms of design and
operation to strengthen the internal controls. In addition, the internal audit shall in its periodical
review of processes ensure that no material areas which may compromise the effective applicability of
this principle is overlooked, whether this pertain to IT or functional controls.
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Compliance & Control Program (Revised-2015)
Objective:
The role of compliance function is to develop and promote the compliance culture in the bank. Their
job objective is to identify the discrepancies, elevate & escalate them to the concerned
authorities and push them for the early rectifications of the reported lapses/ discrepancies/
irregularities. At Head Office Level, the reported exceptions shall be taken up with the concerned
Groups for rectifications. At Regional Office Level, the exceptions shall be reported to the
concerned Regional Head for the earliest rectification.
A checklist has been designed containing the areas & items to be reviewed by the compliance
functionaries after a specified period as given therein. The given frequency of review of every item
is for the Area Compliance & Control Managers (ACCM), to be posted in Area Cluster Branches.
The Area Compliance & Control Inspectors (ACCI) shall visit the other branches of the cluster on
bimonthly basis (Once in two months). However, as soon as the required number of staff members
are posted in the Compliance Group having adequate experience, knowledge & skills, the frequency
of visits of ACCI shall be changed from bimonthly to monthly basis or fortnightly.
Promulgation:
The Compliance & Control Program (CCP) shall be promulgated after approval from the Bank’s
Management Committee. On approval & promulgation of the CCP, all the previously defined role,
functions & job descriptions of the Compliance Group and the Compliance Functionaries shall stand
withdrawn.
Updation:
The review and updation of the Compliance & Control Checklist this program shall be an ongoing
process to ensure continuous alignment between the regulatory framework and the bank-wide
strategy and the internal & external dynamics in which the bank operates.
The Compliance Group shall formally initiate any modifications to the Compliance & Control
Program keeping in view the developments, changes and trends in the compliance environment
whether required by law, regulator or the bank’s Senior Management/BoD. This program, in its
entirety, shall be reviewed on a periodic basis at least once in three years and updated. However,
updation of the checklist shall be a regular feature and an ongoing process. Upon issuance of any
new directive of the regulator or instruction from the bank’s management, the same shall be
incorporated in the checklist.
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Compliance & Control Program (Revised-2015)
Group Chief
Divisional Head
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Core Functions
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In view of enhanced scope of activities in the bank, the responsibilities to review the
implementation of rules and regulations have increased tremendously at all levels. The scope of
Compliance function covers a broad spectrum of review of banks functions including review of
implementation of instructions/ directives given by SBP, applicable laws of the country, instructions
contained in Standard Procedure Manual as per checklist designed for the purpose and reporting of
deviations to appropriate level of management for their rectifications.
1. Availability of sufficient and adequately trained resources at Regional Office to meet the
functional responsibility of all branches under his jurisdiction. In case of requirement of a new
resource, he will submit requisition with the Regional Head who shall post a well trained
resource keeping in view the nature of assignment.
2. Proper training to the staff under his jurisdiction in coordination with the Compliance Group
through NBP Staff Colleges. Moreover, posting of skilled staff as Area Compliance & Control
Managers and Area Compliance & Control Inspectors and arrangement for their proper training
in key areas such as Know Your Customer, Anti Money Laundering and Foreign Exchange etc.
Core Functions:
1. Establishment and maintenance of compliance network in the region by ensuring that:
a. Compliance function has a formal status within the region with appropriate
standing, authority and independence.
b. Compliance staff has access to relevant and necessary documents, information
and personnel to carry out their responsibilities.
c. Compliance staff expresses and discloses its findings to Branch Management,
Regional Management, Regional Compliance & Control Head and Group Chief
Compliance at Head Office without any fear.
d. Compliance staff is not placed in a position where there is a possible conflict of
interest between their compliance responsibilities and any other responsibilities
that may impair their independence and judgment.
e. Compliance function is to assist the Branch/Regional Management in managing
the Compliance risk effectively.
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Compliance & Control Program (Revised-2015)
2. Compliance with relevant laws, regulations and bank’s policies with special emphasis on
KYC and Anti Money Laundering (AML).
3. Coordination with SBP Inspection Team and External Auditors to ensure that visiting SBP
Inspection Team / Auditors are provided with all required documents/information in time.
4. Regional Compliance & Control Head to act as Anti-Money Laundering Supervisory Officer
of the Region.
5. Reporting of Suspicious / Currency Transactions to Head Office for onward submission to
FMU.
6. Review of Regional Office transactions.
7. Ensure that the Area Compliance & Control Managers /Inspectors are functioning as per
Compliance & Control Program.
8. Arrange Inspection of other branches of clusters on bi-monthly basis (once in two months)
and reporting of exceptions to Regional Head for rectification and Compliance Group Head
Office for further escalation. (If Inspectors are posted in Regional Office, then RCCH shall
perform this function. If Inspectors are posted under ACCM then he will perform this
function. Moreover, the frequency of visit of Inspector shall be changed on posting of
adequate staff and CG shall advise any change therein from bimonthly to monthly or
fortnightly)
9. Monitoring & follow up with the concerned authorities for rectification of the exceptions.
10. Reporting of Fraud, Forgery, Attempted Frauds, Dacoity & Attempted Dacoity to Head
Office. Exceptions under this head for Rupees Five Million and above are required to be
reported to SBP within two ( 2 ) working days of detection.
11. Processing of Prompt and Monthly exception reports received from branches and
submission to Regional Head and Head Office as per Criteria of Reporting.
12. Participate in discussion on Audit Reports.
13. Follow up for rectification of irregularities and closure of diarized audit findings.
14. Periodical Visits of the Branches (at least five (5) branches per month)
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Compliance & Control Program (Revised-2015)
1. Sanctioning of Daily
Fresh Finances/ 1. Approval within delegated Business
Discretionary Powers as per Documents of
Renewals
Empowerment.
2. Completion of Review Sheet for all finances
sanctioned / confirmed at Regional Office.
3. If there is violation of Business
Discretionary Powers, Prompt Exception
will be reported.
4. All other exceptions which are not prompt in
nature will become part of Monthly
2. Review of Expense Daily Exception Report.
Vouchers (Running 1. Expenses at Regional Office are approved
within financial powers as per Document of
Expenditure)
Empowerment.
2. All relevant documents have been attached
with the Voucher.
3. With holding tax has been deducted as per
prevailing law. Sales tax Invoice has been
obtained (where applicable)
In case of exception/ violation, the RCCH will
report Prompt exception. All exceptions which
are not prompt in nature will become part of
3. Voucher for Daily Monthly Exception Report.
Purchase of Assets 1. All Expenses for Purchase of Assets have
(Capital been approved as per document of
Expenditure) empowerment.
2. All relevant documents have been attached
with the Voucher.
3. Assets purchased for below Rs. 10,000 are
not charged to Asset Account (debited to
Charges Account) as per Instruction Circular
No. 89/2004 dated August 10, 2004.
4. General Sales Tax has been deducted
correctly and deposited in Govt. Account as
per Instruction Circular No. 126/2008 dated
24th October, 2008.
5. Withholding Tax has been deducted on
Gross Amount as per Income Tax Ordinance
In case of violation, the RCCH will send to
Compliance Group, Head Office as Prompt
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Review Sheet
Review of finances approved at Regional Office:
Business
S. Discretionary
Loan Sanctioning Exceptions
No. Name of Branch Loan Type Powers of
Amount Authority If any
Sanctioning
Authority
1.
2.
3.
4.
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Compliance & Control Program (Revised-2015)
The Prompt Exceptions include fraud, forgery, attempted fraud, theft, dacoity, mishap and all those
exceptions reportable to the President by Head Office as per revised criteria of reporting circulated vide
Instruction Circular # 89/2015 dated 28.07.2015.
The ACCM and ACCI if find any Prompt Exception during their branches’ review, they will report the
same on the format prescribed hereunder to the Branch Management for their comments and will send
the PE to RCCH on the same day.
The Regional Compliance & Control Head (RCCH) will report all Prompt Exceptions observed by the
ACCM or ACCI during their branches’ review to the Regional Head under intimation to
Compliance Group Head Office. The Regional Head will submit his comments within 24 hours and the
Prompt Exception will be reported to Compliance Group Head Office along-with the comments of the
Regional Head.
The RCCH will not delay submission of Exception Report to CG Head Office under any
circumstances, especially with the reason that “Comments from the Regional Head are still
awaited” or “on advising by the Regional Management to hold the exception”. In case Regional Head
does not give comments within the stipulated time, the RCCH will submit the Exception Report to
Head Office clearly mentioning therein that “Exception Report was submitted to Regional Head on (date)
but comments not received”.
The RCCH will ensure that in case of any prompt exception in the branch/ regional office it is
intimated to Compliance Group Head Office on the same day he gets information from ACCM, ACCI
or any other source.
The RCCH will ensure that exceptions relating to fraud, forgery, attempted fraud, dacoity for
Rupees five million and above are reported to Compliance Group, Head Office on top priority basis since
these are required to be reported to SBP within two ( 2 ) working days of its detection in terms of SBP
BPRD Circular No. 3 of 2014 dated February 20, 2014.
Additionally, the compliance functionaries may also report any other irregularity/observation of
significant nature which may cause any financial/reputational loss to the bank as Prompt Exception.
Moreover, in case of non-deduction of tax or non-depositing of tax in Govt. Treasury in time, the
Compliance Functionaries are required to report exceptions on Prompt basis.
The Prompt Exception Reporting Formats have been designed for reporting of PE of different
natures, detail of which is given below:
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(Please note that under the column of Annexure, “P” stands for Prompt)
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At month end, the RCCH will arrange for consolidation of all outstanding exceptions and prepare a
branch-wise consolidated report as per Format annexed as M-1 to M-8 (M stands for Monthly, from
Page # 50 to 58). The format will contain branch-wise outstanding exceptions identified by the
ACCM and ACCI but not rectified. The details thereof will also be provided to Regional Head for their
immediate rectification.
The compliance officials shall check the activities as per the checklist given hereunder in this
document. The frequency in the checklist has been set for Area Compliance & Control Managers
(ACCM) of Cluster Area Branches. As the review criterion has been enhanced, therefore the Area
Compliance & Control Inspector (ACCI) shall be allotted to check/review three ( 3 ) branches per
month. However, till posting of the required skilled staff in the Regional Compliance Wings, the
number of allotted branches may vary. In such eventuality, the frequency of checking/review by
ACCI shall also be bimonthly (once in two months). However, the Compliance Group Head Office
may change the frequency from bimonthly to monthly or fortnightly keeping in view the staff
strength of Regional Compliance Wings as well as nature of exceptions in the area/specific
branches.
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At end of each month, the RCCH will consolidate all the outstanding exceptions reported by
ACCM, ACCI OR observed by the RCCH and shall prepare a branch-wise consolidated Monthly
Exception Report (MER) of outstanding exceptions of all the branches and regional office. The
RCCH shall send the said MER to the Compliance Group Head Office for escalation to the
appropriate level under intimation to the Regional Head for their immediate rectification.
However, exceptions relating to fraud, forgery, attempted fraud, dacoity, etc. which are prompt in
nature will be reported immediately to the Head Office as per present mechanism. It is re-
emphasized here that exceptions relating to fraud, forgery, dacoity for Rupees five million and
above are required to be reported to SBP within 2 working days hence RCCH are required to
remain highly attentive on these exceptions so as to ensure compliance of SBP directives.
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4. Coordination with SBP Inspection Team and External Auditors to ensure that they are
provided with all required documents/information in time.
5. To check reporting of Suspicious / Currency Transactions Reports by the branch.
6. Arrange Inspection of other branches of clusters through RCCI on bi-monthly basis (once in
two months) (If Inspectors are posted under ACCM. Moreover, the frequency of visit of
Inspector shall be changed on posting of adequate staff to monthly or fortnightly)
7. Monitoring & follow up with the concerned authorities for rectification of the exceptions,
irregularities and closure of diarized audit findings..
8. Reporting of Fraud, Forgery, Attempted Frauds, Dacoity & Attempted Dacoity to Head
Office. Exceptions under this head for Rupees Five Million and above are required to be
reported to SBP within two ( 2 ) working days of detection.
9. Participate in discussion on Audit Reports.
10. Reporting of Prompt and Monthly Exceptions to Regional Compliance & Control Head &
Head Office where required.
11. Act as Anti-Money Laundering Officer of the Branch.
The Regional Compliance & Control Head will arrange for effective follow up with the Regional Head
till complete rectification of irregularities and will provide rectification status report to Group Chief
Compliance at Head Office for all those irregularities reported earlier.
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S.
Items of Review Review Function Frequency
No
Account Opening
Account Opening - Individual
1 Review Sheet Daily
Accounts
2 Account Opening - Government
Review Sheet Daily
Accounts
3 Account Opening - Firms/Limited
Companies/Societies/Trusts/Clubs Review Sheet Daily
etc.
Reconciliations of NBP General/Collection/Suspense/Sundry Accounts
F-21A is printed on daily basis and properly
checked/ filed.
RBVs received in the branch are responded in
time. Examine the outstanding entries in List-B
4 NBP General Account of NBP General Account and reasons for non- Daily
responding.
Proper follow up has been made with originating
branch for un-responded RBVs.
Originated RBVs are dispatched to responding
branches in time.
F-110 A is prepared accurately and all Govt.
Daily
5 Submission of 110-A to relevant Account entries have been reported.
Office The branch has maintained the record of F-110
Daily
properly.
Entries are reversed within 30 days and taken
Suspense/Advance Mobilization
6 to proper head of account and no entry Daily
Account:
remained outstanding for more than 30 days.
Entries are reversed within 30 days and branch
Sundry Deposit / Other Sundry is following up for outstanding entries. No entry
7 Monthly
Liabilities Account
remained outstanding for more than 30 days.
Funds of all collection accounts (Electricity,
Gas, Telephone) & tax deductions/collections
(Income/ Sales/Property Tax/FED/Traffic
Challan, EOBI Collection etc.) are remitted as
8 Collection Accounts per instructions Monthly
Registers & scrolls are properly maintained.
Utilities bills & Taxes collection timing is
observed.
Charges (if any) are recovered.
Maintenance of all types of accounts:
Profit rates are applied correctly & profit paid in
time.
Withholding tax is deducted from profit and
9 Application of Profit rates and deposited in Govt. a/c as per procedure. Quarterly
deduction of withholding tax
Profit has been paid to the closed accounts. WH
Tax Exempted to Accounts after obtaining proper
documents.
Verify Requisition Slips that Cheque Books
10 Issuance of Cheque Books issued to A/c holder or his authorized agent Daily
only.
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19 CNIC not available Old accounts having NICs were debit blocked as
Monthly
per Para-26 R-1 of AML/CFT Regulations.
20 Expiry of CNIC Branch informed the active customers on expiry
of their CNICs as per BPRD Circular Letter # Monthly
20/2011.
Remittances
Acknowledgement from customer is taken at the
time of issuance of all instruments (On random
basis).
Issuance of Bank Drafts, TTs, Pay TT messages are relayed in time.
21 Daily
Orders, MTs, Call Deposits etc.
New voucher is being used for issuance of
instruments/TTs etc.
Copy of CNIC is obtained from Walk in
Customer.
Branch follows up for DDs paid Ex-Advices with
concerned branches.
Branch passed entry on original TT message
duly signed/stamped by authorized person of
Payment of Bank Drafts/ TTs/POs/
22 SWIFT Centre. Daily
CDR
Confirmation is obtained from issuing branch
for big amounts.
In case of Cash Payment over counter, CNIC of
beneficiary is obtained.
Beneficiaries filled Form specially designed for
Western Union /eRemittance Transactions
correctly as per CNIC.
Branch has sent activity report along with one
Western Union/ eRemittance (all consolidated RBV to link branch on same day. Daily
23
operators’ payments)
In case of Remote Transaction proper procedure is
followed.
Customer filled form & system generated
voucher have been placed properly for review.
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Miscellaneous:
Periodical balancing of books have been done for
all relevant accounts and figures tally with
General Ledger.
1. Sundry Deposit A/c
34 Balancing of Books (Non-System 2. DD/GDD Payable A/c Monthly
Based Books)
3. Cumulative Deposit A/c
4. Call Deposit Account
5. Locker Key Deposit A/c
6. Stamp Account
Transparent complaint box is affixed at
prominent place.
Complaint Register is properly maintained.
35 Processing of Customer Complaints Banking Mohtasib Complaint Forms & Monthly
Procedure displayed at the branch.
Customer complaint is handled promptly within
prescribed time.
Locker operation was allowed without recovering
the overdue locker rent.
Key deposit recovered from locker hirers.
36 Lockers Quarterly
Notice regarding locker insurance displayed.
Lockers broke opened in case of continuous
default in payment of locker rent.
Staff remained posted for more than three years in
the same branch.
37 Staff Matters Quarterly
Staff members availed Privilege Leave for 15
days during the year.
Deduction of Income Tax from Income Tax deducted from the retirement
38 Retirement Benefits of NBP Staff benefits calculated by the Branch Management
Member is as per FBR Rules.
1. CCTV System installed & in working
condition with recording for 30 days.
2. Burglar Alarm System installed.
3. Smoke Detectors installed and in working
order.
39 Security Measures 4. Security Guards performing their allotted Quarterly
duties.
5. Fire Extinguishers are available and not
expired.
6. Proper Strong Room Door installed.
7. Proper Locker Room Door installed.
Declared Rate of Profit
Annual Accounts of the Bank
Prize Bond Draw Lists
Notice for Levy of Incidental Charges
40 Branch Notice Board Service standards Monthly
Banking Mohtasib complaint form displayed for
customers.
List of unclaimed deposits placed
Notice indicating acceptances of soiled notes
Internal complaint handling procedure.
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Compliance & Control Program (Revised-2015)
45 Establishment/Amendment of
Import LC Review Sheet Monthly
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The Area Compliance & Control Manager/Inspector may check/inspect any item of review more
frequently than prescribed in the frequency as per his choice.
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Date of Present
Branch Team Name
Assignment
Branch Manager
Operations Manager
Date
No. of No. of No. of Clearance *Reasons
Conducted
Audit & Inspection Irregularities Irregularities outstanding Certificate for non-
On (Date)
Pointed out Rectified Irregularities Accepted rectification
SBP Inspection
Annual Audit
(Significant Findings)
Snap Audit
IS Audit
The branch has been reviewed as per check list, which is attached duly filled from the period from
_________________ to ________________ and the pointed out exceptions have been discussed with
the branch management for on spot rectification. The Branch Manager / Operations Manager has also
signed the checklist, copy of which has also been handed over to him / them for rectification
of outstanding exceptions within seven (7) days.
Name:_______________________
Designation:___________________
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Compliance & Control Program (Revised-2015)
The exceptions pointed out have been discussed by the ACCM / ACCI for on spot rectification
thereof. However, the following exceptions could not be rectified due to the brief reason(s) given
against each. However, we will make utmost efforts to rectify these outstanding exceptions within
seven (7) days and will take measures for non-repetition in future.
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Compliance & Control Program (Revised-2015)
Annexures
(Prompt Exceptions)
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Annexure “P-1”
Reporting of Mishaps (Committed OR attempted Fraud/Forgery/Dacoity/Fire/Theft/Robbery etc.)
1.
Name of Branch & Code
2.
Regional Office
3.
Category of Branch
4.
Nature of Incident
5.
Date of Incident
6.
Date of Detection/ Report
7.
Name & Designation of Officer who
detected
8.
Amount Involved
9.
Recovery if any
10.
Whether incident is covered under the
insurance policy.
11.
Name of Insurance Company
12.
Sum Insured in case of Dacoity
13.
Status of Insurance Claim lodged to HO
14.
In case of Dacoity the name of Security
Agency
15.
Security Arrangements like hidden
cameras, alarm etc.
16.
Date F.I.R. Lodged
17.
Name of staff responsible with
designation & present place of Posting.
18.
Involvement of Outsider if any
19.
Steps taken/ To be taken
20.
Modus Operandi in Brief
21.
Regional Head Comments (Within 24 hours)
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Annexure “P-2”
Annexure “P-3”
7. Steps taken/ to be
taken
8. Regional Head
Comments
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Annexure “P-4”
2. Regional Office
3. Category of Branch
4. Type of facility
5. Date of Sanction
6. Amount Sanctioned
7. Date of Disbursement
8. Present Outstanding
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Annexure “P-5”
Reporting of Shortage/Shortfall of Pledged Stock:
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Annexure “P-6”
Shortage of Cash:
Annexure “P-7”
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Annexure “P-8”
Annexure “P-9”
Disbursed/Renewed Finances without issuance of DAC
2. Regional Office
3. Category of Branch
4. Name of Borrower
5. Nature of Finance(s)
6. Limit(s) Sanctioned
7. Sanctioning Authority with ref
8. Date of Disbursement
9. Amount Disbursed
10. Name of Officials made
11. Brief Details
12. Steps taken/ To be taken
13. Regional Head Comments
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Annexure “P-10”
Reporting of Other Prompt exceptions (Not classified above)
2. Regional Office
3. Category of Branch
4. Nature of Exception
7. Brief Details
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S.
Yes No If "No" comments
No Items of Review
1 Copy of valid CNIC of all account holders /partners
obtained.
2 Copy of CNIC of all account holders / partners verified
through NADRA Verisys.
3 Proper KYC completed and AOF has requisite
information regarding expected monthly turnover,
source of income, purpose of account, expected monthly
income, usual mode of transactions and maximum
expected transaction amount (DR & CR) etc.
4 Proof of profession (student/self employed/service/
pension etc.) obtained.
5 Identity documents of account holder(s) & next of kin
attested.
6 Signature of joint account holders obtained on AOF
7 Signature verified by the branch officials.
8 CNIC was bearing thumb impression whereas account
was opened with signature
9 Permission for opening of high risk account obtained
from Compliance Group HO through Regional Head.
10 Letter of thanks dispatched to account holder on the
same day
11 Undertaking obtained if signatures of account holder
differ on CNIC & AOF.
12 Zakat deduction option checked on AOF for non-
Muslim/ Muslim accountholder who submitted affidavit
of non-deduction.
13 Separate CZ-50 obtained from all joint account holders.
14 Acceptance of Terms & Conditions for account opening
& maintenance obtained from account holder.
15 Acknowledgement of receipt of copy of account opening
form obtained from account holder.
16 FATCA form has been attached with the AOF duly filled
up & signed.
17 Cheque books were issued to the account holder
without obtaining acknowledgement of letter of thanks
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Compliance & Control Program (Revised-2015)
S.
Items of Review Yes No If "No" comments
No
Accounts were opened after obtaining special
1 resolution/ authority from the concerned administrative
department
Account holder authorized himself for account
2
operations in a joint account
Government accounts/deposits to be operated by an
officer of Federal/ Provincial/ Local Government in his
official capacity were opened after obtaining special
3 resolution/authority of the concerned administrative
department duly endorsed by Ministry of Finance or
Finance Department of concerned Provincial or Local
Government
Authority letter was obtained from the Government
4 Department and operating instructions by the
designated persons.
Copy of valid CNIC of concerned official(s) obtained and
5
verified from NADRA before opening of account.
Identity documents of concerned officials obtained and
6
attested.
Acceptance of Terms & Conditions for account opening &
7
maintenance obtained from account holder.
Acknowledgement of receipt of copy of account opening
8
form obtained from account holder.
Copy of Instruction Circular was not attached/ obtained to
9
open Office Collection Account
Page 39 of 54
Compliance & Control Program (Revised-2015)
S.
Items of Review Yes No If "No" comments
No
1 Accounts of firms/ limited companies/ societies/ associations
were opened after obtaining proper identification/ documents
CNICs/ SS Cards of Directors/ authorized signatories/
2 trustees/ Identification documents of all Directors/ Trust
Deed containing list of trustees duly attested are available
Up-dated Form-29/ Board Resolution to open account/
3 Certificate of commencement of Business/ Certificate of
registration/ Copy of bye-laws/ rules & regulations available/
obtained
4 Account operation instructions given by the company is as per
procedures given in articles of association
5 Copies of memorandum & articles of association bear SECP
seal
6 Under taking by all authorized persons to inform bank in case of
any change in their particulars not furnished
7 Partnership deed is attested.
8 Un-registered partnership mentioned on AOF In
9 partnership account, authority letter in favor person
authorized to operate the Account obtained
10 In sole proprietorship account, letter of sole proprietorship for
account opening was obtained
In association/society account resolution of governing body/
11 executive committee for opening of account and authorizing the
persons to operate the account was obtained
12 Permission for opening of high risk account obtained from
Compliance Group HO through Regional Head.
Accounts for business purposes were opened in personal name
13 of partners/ sole proprietor/ director instead of in the name of
business
14 Acceptance of Terms & Conditions for account opening &
maintenance obtained from account holder.
15 Acknowledgement of receipt of copy of account opening form
obtained from account holder.
Page 40 of 54
Compliance & Control Program (Revised-2015)
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Compliance & Control Program (Revised-2015)
In case of "No"
S.No Items of Review Yes No
comments
1. Disbursement Authorization Certificate has
been issued before issuance of LG.
2. The customer has submitted request for
issuance of Letter of Guarantee along-with
format of the L/G.
Page 42 of 54
Compliance & Control Program (Revised-2015)
Retirement of Documents
L/C #
In case of "No"
S.No Items of Review Yes No
comments
1. Documents have been scrutinized within a
reasonable time.
2. In case of discrepant documents negotiating bank
has been informed immediately via SWIFT
3. In case discrepant documents have been received,
same have been conveyed to importer for
acceptance immediately.
4. Lodgment of documents in time
Page 43 of 54
Compliance & Control Program (Revised-2015)
Export Negotiation
L/C #
Page 44 of 54
Compliance & Control Program (Revised-2015)
Export Re-Finance
Name of Customer ______________________ Review Date
Account #
In case of "No"
S.No Items of Review Yes No
Comments
1. Export Finance facility is within the approved limit.
2. Disbursement Authorization Certificate has been
issued as per procedure.
3. Customer application for grant of SBP Finance is
available
4. Form D submitted to SBP is duly completed and
signed by the borrower, his signature is verified by
the bank and the Form is also signed by the bank.
5. Undertaking on Form B for Direct Exporter or on
Form C for Indirect Exporter duly signed by the
borrower and verified by the bank is available on
bank record.
6. Copy of Export Order / LC for Direct Exporter and
Inland Letter of Credit/ Standardized Purchase Order
in case of Indirect Exporter is on branch record
7. Following is available on branch record:
In case of Pre-Shipment Finance
For Direct Exporter
Original and duplicate copy of Form E and Bill of
Lading
Or FCRs and EPRC (for direct exporter),
For Indirect Exporter
Invoice, Truck/ Railway Receipt, Goods Received
Note/ Delivery Challan signed by the
In case of Post Shipment (for direct exporter)
EPRC.
8. Approved EE-1 or NOC from other bank is on bank’s
record and the proposed application is within
Exporter’s entitlement.
9. Form D-3 submitted to SBP is duly completed and
signed by the borrower, his signature is verified by
the bank and the Form is duly signed by the bank
10 Finance is within entitlement limit of the Exporter.
Page 45 of 54
Compliance & Control Program (Revised-2015)
Page 46 of 54
Compliance & Control Program (Revised-2015)
M-1
Violations of Know Your Customer Reported For the Month of _____________________
Page 47 of 54
Compliance & Control Program (Revised-2015)
M-2
Grand
Total
Page 48 of 54
Compliance & Control Program (Revised-2015)
M-3
Non- Documents
negotiable have not been Bill of
SBP Permit
shipping Not entered in scrutinized Exchange have
not endorsed
No. of documents Inward Mail within a Lodgment of not been Total No. of
Name of Form-1 not for the amount
Document endorsed 100% register and reasonable documents not properly Violations
Branch filled properly utilized
Retired lien have not receipt date not time, in time endorsed and Reported
(Partially/
been marked marked preferably with delivered to
Fully)
on deposits of 24 hrs from the the Importer
importer date of receipt
Grand
Total
Page 49 of 54
Compliance & Control Program (Revised-2015)
M-4
Grand Total
Page 50 of 54
Compliance & Control Program (Revised-2015)
M-5
Total No. of
Name of Name of Nature of
Violations
Region Branch Finance
Reported
Grand Total
Page 51 of 54
Compliance & Control Program (Revised-2015)
M-6
Grand Total
Page 52 of 54
Compliance & Control Program (Revised-2015)
M-7
Violation of the Financial Powers (Below the Limit from Prompt Exception)
Page 53 of 54
Compliance & Control Program (Revised-2015)
M-8
Page 54 of 54