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L I M T E D
AML & CFT Division, Head office

AML Memo No.03/2020/1362 February 02,2020

To : All Managers/ln-charges of all Branches/SME Service Centers, Dhaka Bank Limited
Heads/ln-charges of Divisions/ Units, Dhaka Bank Limited, Head Office
Attention : Branch Anti Money Laundering Compliance Officers (BAMLCOs), All Branches

Subject : Common Irregularities found during the Inspection of Internal Control & Compliance
Division under Independent Testing Procedure (ITP) Checklist

Please refer to BFIU circular 19 dated September 17, 2019 regarding Compliance on AML & CFT Issues. In
this regard, it has been revealed that, during the comprehensive audit conducted by IC&CD few branches
obtained undesired score which is not expected.

In view of the above, Management of the Bank is seriously concerned regarding improving the Independent
Testing Procedure scores (ITP) conducted by IC&CD during their comprehensive audit. Upon case to case
analysis and review, it has been revealed that, most of the branches are scoring lower numbers under some
specific areas, which could have been improved if reasonable attention was ensured prior inspection. We
discussed below few areas where, there is significant room of improvement:

Particulars Recommendations Remarks

Branches must ensure the following documentation and procedure -

Timely review of KYC as and when becomes due as per BFIU Circular *
Number -19 dated Sept 17, 2017 O
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Updating of KYC Review Register properly and preserve the register o
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with BAMLCO for future evidence O
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o Branches must ensure each & every customers are subject to 03
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information verification and income justification under CDD program >

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0) Customers are to be categorized based on risk associated with them, in b=
E this regard please follow Dhaka Bank Risk Based Approach
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3 Documentation & Filing is very important since inspection team works CO
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Most of the cases braches failed to satisfy the inspection team regarding £=
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Beneficial Owner - As per BFIU Circular No - 19, branches have to .2
conduct the KYC of beneficial owner during opening the account of o
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Influential Person / PEPs and related documents must be filed properly .2
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for audit issue.
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Particulars Recommendations Remarks

In order to achieve desired score in independent testing procedure Q

evaluation branches must ensure following procedures - E

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Transactions must be monitored on regular basis and on the basis of O
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risk relevance E
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Documentation of Transaction Monitoring to be preserved in due C/3
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procedure to face audit &

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o> Transactions for online customers and non- face to face customers are CD
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o Credit Card transactions and Online Transactions must also be traced CD
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and monitored on regular basis CD cz
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importance and consequence of Transaction Monitoring
c For High Risk / IP / PEPs accounts transactions to be monitored more CD
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frequently and closely
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Branches may also pursue transaction profile approach for transaction CZ
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monitoring of frequently exceeded accounts cz
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International transactions and Trade Based Transactions are not the E
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exceptions, those are also subject to monitor and surveillance .2
During transaction monitoring BAMLCO should aware of international 03
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banned organization / individuals as well as local restricted CZ
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organizations to prevent entering in banking system

During inspection the branches oet poor score under this part. So, branches or w
are reguested to follow below mentioned guidelines - CO

• Updated CTR file must be preserved under BAMLCOs custody

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• Transaction monitoring on the basis of CTR data must be performed and o Q.
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CO • Branches must screen CTR data for potential Suspicious Transactions Q.
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or and escalation ^ ro
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o • Daily checking of CTR and updating the missing information related to o3 o
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CTR data on UBS System must be a routine task 2? CD
• Daily checking of News Paper for relevant news screening & escalating T3
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if matched with any predicate offender CL

• CASA exceptional Report and other daily journal reports are subject to f1 o
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routine check to prevent any undesired compliance facet
Branches must file the Audit System Check related documents of last year >% CD
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o with a view to produce in front of the inspection team so that they can verify Z3
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m CD the progress and implementation of recommendation given in the last audit. O
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Secondly, branches are requested to update all audit related files £ 2 15
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conducted in last year with supportive documents of implementation CZ
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recommendation. 00

In this regard, all branches are earnestly requested to address the above mentioned instructions and
perform the due diligence to get better score during IC&CDs' as well as Bangladesh Bank’s Audit.
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This is important to mention that, the ITP scores obtained by our branches play a significant role during
accessing the entire Banks AML & CFT compliance status. So let us all work together to achieve our
collective goal along with ensuring good governance and compliance status through adhering instructions of
BFIU.

This is for your kind information and meticulous compliance.

Best regards,

Md. Pakhrul Islam A M M Moyen Uddin

EVP &Deputy CAMLCO Head of IT & CAMLCO

Copy to:

(a) The Managing Director (Current Charge), Dhaka Bank Limited, Head Office
(b) The Deputy Managing Directors, Dhaka Bank Limited, Head Office
(c) Regional Heads, Dhaka Bank Limited
(d) The SEVP & Head of IC&CD, Dhaka Bank Limited, Head Office