1.3 Kha Summary of Circular - 26 New Instructions of Circular - 26 ‘The Anti-Money Laundering Division can be called by any name. 32 Ka, Bank will assess their Money Laundering and Terrorist Financing risk on regular interval as per the ML/TF Risk Assessment Guidelines for banking sector. Business Nature, Customer, Product or Services, Country and Geographical location will be considered to assess the risk. Kha. Enhance Due Diligence has to be ensured in case of High risk profile.. Ga, Simplified Due Diligence can be ensured in case of Low risk profile. Gha. Bank must apply necessary due diligence considering the risk, importance and relevance of existing customers. Besides, during reviewing the KYC of existing | customers, the information of previous due diligence has to be considered too. | 33 (1) The account opening form issued by the department, Banking Regulations and Policies of Bangladesh Bank has to be used for opening accounts. But considering the advantage of latest technology, bank may use the latest technology, instructed in Guidelines on Electronic Know Your Customer (e-KYC). Where the application of e- KYCis not possible, hardcopy of account opening form can be used. 3.4 (1)-Ga 34(3) CDD has to be performed in case of Occasional transactions done through Wire ‘Transfer, | On-going CDD has to be performed identifying the Business nature, risk exposure and source of fund of customer. In case of High risk accounts, the existing information has to be reevaluated and updated on regular basis. 34 (4) The authenticity of the identity and other related information of customer or beneficial owner have to be assessed during onboarding the customer or before withdrawal of fund after opening the account, But in case of walk in customer, these activities have to be performed during transaction. Where ML/TF risk is ‘comparatively lower, these activities can be done within the shortest possible time after opening account rather than terminating or hampering the business relationship. 3.5-Kha The Id card of bearer needs to be attested, 3.5-Ga Govt. Social Security Allowance account has to be considered for financial inclusion. 3.6 (1) Where application of e-KYC is not possible, the attached sample KYC ‘Appendix -Ka" has to be used. 3.6 (2) ‘Appendix - Ka’ can never be considered as a part of account opening form and must not be filled by customer himself/herself. 3.6 (3) Bank will create and monitor the Transaction profile of customer considering the {ransactions of last 6/12 months. If any significant change in transaction is noticed, bank will investigate and update the profile. If anything suspicious activity found, STR/SAR has to be raised, Bank has to be careful not to be cause of any harassinent of customer in this regard, 3.6 (4) Bank must have the mecha a inism of identification when low risk account turns into high risk account. 3.6 (7) 3.14-jha The ML/TF practice of any country has to be considered business relationship with the country, | ‘Agent banking can follow the instructions of Guideline on e-KYC isoue b before establishing any by BFIU where |9.1(1) - Ka Black listed persons and organizations, issued by Bangladesh Governments should be considered during transaction monitoring Deposits into the accounts of School, College, University and other educational institutions for tuition fees purposes and Govt. accounts for utility bill collection purpose need not to be included in CTR report. But in case of cash withdrawal, the transactions have to be included in the report. ‘ations and challenges in Self-Assessment report cannot be n these points to the report and forward If any identified comp! solved at branch level, Branch must menti itto the ICC and AMLD for their s In case of Cross boarder wire transfer, bank has to preserve the information of applicant's account number or Unique transaction reference number (if account number is unavailable) so that the transaction can be found easily later on. Same procedure will be applied for Beneficiary related information. J} The Unique transaction reference number is also applicable for the transactions Ifthe ordering bank does not satisfy the requirements mentioned in the sections 9(1) 9.1(1) Kha those are below the 1000S threshold. 93 (1) and 9(2), no wire transaction will take place. 10. Bank will follow the resolution no. 1267 and resolution no. 1373 of UN security council and other resolutions related to the prevention of proliferation of mass | destruction weapons. Instructions replaced in Circular - 26 ‘CIRCULAR - 19 CIRCULAR - 26 32 (2) Uniform account opening form, issued | by BFIU has to be used for opening new accounts. 3.3 (1) The account opening form issued by the department Banking Regulations and Policies of Bangladesh Bank has to be used for opening accounts. 3.3 (3) - Gha If no natural person can be identified as the beneficial owner of a company, the accurate and complete information of Chief Executive Officer has to be collected. |'3.5 (1) Bank can use their own account opening form aligning with the Uniform account opening form, issued by BFIU. 3.4 (8) - Gha If no natural person can be| identified as the beneficial owner of a company, the accurate and complete information of any Senior Management Officer has to be collected. 3.6 (1) Bank has to use Digital e-KYC form and Where application of e-KYC is not possible, the attached sample KYC ‘Appendix -Ka’ has to be used 3.5 (3) Bank will collect declaration from customer regarding estimated transaction profile and review the profile after 6 months. After reviewing bank may update the profile discussing with customers or raise STR if anything suspicious is found. 3.6 (3) Bank will create and monitor the | Transaction profile of customer considering the | transactions of last 6/12 months. If any significant change in transaction is noticed, bank will investigate and update the profile. If | anything suspicious activity found, STR/SAR has to be raised. Bank has to be careful not to bess . ‘cause of any harassment of customer in this _| regard. a .6 (4) ~ STR/SAR has to be raised against the | 3.7 (3) STR/SAR has to be raised against the customer whose account has been closed or | customer whose account has been closed or whose account has not been opened due to the | whose account has not been opened or potential unavailability of satisfactory information while | customers/entity due to the unavailability of | performing CDD. : satisfactory information while performing CDD. | 3.11 (5) Due diligence of the countries listed in | 3.13 (5) - Due diligence of the countries listed the High Risk and Non-Cooperative Jurisdictions | in Jurisdictions under Increased Monitoring, Published by FATF should be applied more | High risk jurisdictions subject to a call for action stringently for maintaining correspondent | published by FATF should be applied more | banking relationship. stringently for maintaining correspondent banking relationship. If needed, proper and effective implementation of Counter Measures issued by FATF has to be ensured. Be elnstmuctions on Money Laundering | 3.17 - Instructions on Circular letter Now, Prevention Law 2012, section - 6(3) shall be | circulated on 22.04.2018 shall be followed flowed regarding maintaining confidentiality | regarding maintaining confidentiality of of information regarding STR. information regarding STR. 82(4) - ICC has to conduct AML audit minimum | 8.2(4) - ICC has to conduct AML audit minimum on 10% agents. on 5% agents, | on Grading ( >= 14 — High Risk, <14 - Low | Risk Grading (>= 15> High Risk <5 Low risk) ris! “Updated KYC Profile forms have been attached in ‘Appendix — A’ for all types of accounts. In addition to the circular, the following instructions should be followed as per the instructions of Rais Bhai. > For terminating business relationshi senior officials will be required, * Branch has to send a report to AMLD on monthly basis Teviewing the CTR and TP breach report if any suspicious transaction is found, P with customer (in case of AML issues), approval of