A project on internship with Janaswamy Associates

A Project Submitted to
University of Mumbai for partial completion of the degree of
Bachelor in Commerce (Accounting and Finance)
Under the Faculty of Commerce

By

Amirunnissa Jahangir Bhat

Under the Guidance of

Prof. Mamta Chhajer

RSET’s
Ghanshyamdas Saraf College
of Arts and Commerce
Affiliated to University of Mumbai
Reaccredited by NAAC with ‘A’ Grade
S.V. Road, Malad (W)
Mumbai – 400064

MARCH 2020
 A project on internship with Janaswamy Associates

A Project Submitted to
University of Mumbai for partial completion of the degree of
Bachelor in Commerce (Accounting and Finance)
Under the Faculty of Commerce

By

Amirunnissa Jahangir Bhat

Under the Guidance of

Prof. Mamta Chhajer

RSET’s
Ghanshyamdas Saraf College
of Arts and Commerce
Affiliated to University of Mumbai
Reaccredited by NAAC with ‘A’ Grade
S.V. Road, Malad (W)
Mumbai – 400064

MARCH 2020
 RSET’s
Ghanshyamdas Saraf College
of Arts and Commerce
Affiliated to University of Mumbai
Reaccredited by NAAC with ‘A’ Grade
S.V. Road, Malad (W)
Mumbai – 400064

CERTIFICATE

This is to certify that Ms. Amirunnissa Jahangir Bhat has worked and duly completed her
Project Work for the degree of Bachelor in Commerce (Accounting & Finance) under the
Faculty of Commerce in the subject of Accounting & Finance and her project is entitled, “A
project on internship with Janaswamy Associates” under my supervision.

I further certify that the entire work has been done by the learner under my guidance and that
no part of it has been submitted previously for any Degree or Diploma of any University.

It is her own work and facts reported by her personal findings and investigations.

___________________________ _____________________
Project Guide Principal
Prof. Mamta Chhajer

___________________________
External Examiner College Seal
Date :
 DECLARATION

I the undersigned Miss Amirunnissa Jahangir Bhat hereby, declare that the work embodied in
this project work titled “A project on internship with Janaswamy Associates”, forms my own
contribution to the research work carried out under the guidance of Prof. Mamta Chhajer is a
result of my own research work and has not been previously submitted to any other University
for any other Degree/ Diploma to this or any other University.

Wherever reference has been made to previous works of others, it has been clearly indicated as
such and included in the bibliography.

I, hereby further declare that all information of this document has been obtained and presented
in accordance with academic rules and ethical conduct.

_________________________
Student
Ms. Amirunnissa Jahangir Bhat

Certified by

_____________________
Project Guide
Prof. Mamta Chhajer
 ACKNOWLEDGMENT

To list who all have helped me is difficult because they are so numerous and the depth is so
enormous.

I would like to acknowledge the following as being idealistic channels and fresh dimensions in
the completion of this project.

I take this opportunity to thank the University of Mumbai for giving me chance to do this
project.

I would like to thank my Principal, Dr. Jayant Apte for providing the necessary facilities
required for completion of this project.

I take this opportunity to thank our Course Co-ordinator, Prof. Mamta Chhajer for her moral
support and guidance.

I would also like to express my sincere gratitude towards my project guide Prof. Mamta
Chhajer whose guidance and care made the project successful.

I would like to thank my College Library, for having provided various reference books and
magazines related to my project.

Lastly, I would like to thank each and every person who directly or indirectly helped me in the
completion of the project especially my Parents and Peers who supported me throughout my
project.
 EXECUTIVE SUMMARY

The experience of working as an intern in Janaswamy associates was fascinating. As a

final year student of B.COM. in Accounting and Finance I chose to do this internship
for the purpose of this project.

Janaswamy Associates is engaged in providing services of accounting, tax and legal

advisory company with specialization in Assurance, Risk Consulting, Legal, Direct
Tax, Indirect Tax (GST) and Corporate Advisory.

In this internship I worked on behalf of Janaswamy Associates in Standard Chartered

Bank who had outsourced the firm for their Cross Border Wire Transfer Reporting
activity.

In the first chapter I have given an introduction to Janaswamy Associates along with
all the services provided by them. It also includes a SWOT analysis of Janaswamy
associates.

The second chapter includes the Mission, Vision and Values of Janaswamy Associates.

My role in the organisation forms part of the third chapter. It includes everything about
the CBWTR activity. The product which I handled in this activity too forms part of this
chapter.

Followed by the third chapter is the fourth chapter that talks about the challenges I faced
during this activity.

The fifth chapter concludes my whole project briefly.

 TABLE FOR CONTENTS
SERIAL TITLE PAGE
NUMBER NUMBER
1. Introduction
1.1 Organisation design and structure
1.2 Services provided 1-8
1.3 SWOT Analysis
2. Statement and Objectives
2.1 Vision
2.2 Mission 9
2.3 Values
3. Role in the organisation
3.1 Introduction to Standard Chartered Bank
3.2 Types of bank transfers
3.3 Swift message
3.4 History
3.5 Features of wire transfers
3.6 Process 10-54
3.7 Reasons for CBWTR reporting
3.8 Financial Intelligence Unit
3.9 What to report under Anti-Money
Laundering
3.10 Important terms of CBWTR
3.11 Exemptions
3.12 Role of Ordering, Intermediary and
Beneficiary banks
3.13 Outward Telegraphic Transfers(OTT)
3.14 Field wise understanding of OTT
4. Challenges faced 55
5. Conclusion 56
6. Bibliography
 CHAPTER 1

INTRODUCTION

Janaswamy Associates established in April 1997 is a leading Firm which has over the
last few decades focused on providing value-added services to its clientele comprising
of Banks and Multinational companies under different acts. It also engaged in providing
services of accounting, tax and legal advisory company with specialization in
Assurance, Risk Consulting, Legal, Direct Tax, Indirect Tax (GST) and Corporate
Advisory.

The Organization employs qualified professional, highly motivated personnel with

wide range of practical experience in Banking, Finance and Information Technology.

The firm has also retained retired senior Bankers and Chartered Accountants having
rich banking experience at almost all major states in India.

1.1 ORGANIZATION DESIGN AND STRUCTURE:

Janaswamy Associates boasts on 200+ people team with an appropriate mix of

Qualified CAs, Experienced Inter CAs & Graduates & Articled Trainees. The Team Is
trained for handling specialized jobs basis the profiles allocated to them on regular
intervals. Apart from Technical Knowledge, Janaswamy tries to empower the Team
with Presentation Skills, Team Work & Positive Attitude.

1.2 SERVICES PROVIDED

1. RISK ADVISORY:

Risk Advisory Services are meant to help a business or organization understand the
risks it faces and minimize such risks. Consider the following simplified example. John
is an expert carpenter who wants to open a business that will manufacture and sell
wooden furniture. To do so, John needs to set up a small factory and employ a dozen
workers. Per government regulations, the factory must have certain safety features such
as large industrial fans and a designated number of fire escapes. If the factory does not

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meet these requirements, the government can shut down the business. In addition, John
must provide his workers with health insurance.

John must also maintain books of accounts for his business, per the
government’s accounting rules and regulations. Similarly, there exist a large number of
regulations that John must abide by to run his business that he, being only a carpenter,
does not know. John then decides to hire Mark, who provides risk advisory services to
carpenters. Mark is an expert in the rules and regulations that govern the woodworking
industry. This is, in essence, what Risk Advisory Services are.

In the 21st century, a business or organization faces all kinds of risks. These include,
but are not limited to, Operational Risk, Regulatory Risk, Strategic Risk, and Cyber
Risk.

Operational Risk refers to risks associated with employee conduct, business processes,
and overall operational structure.

Regulatory Risk refers to risks associated with meeting and adhering to government
regulations.

Strategic Risk refers to risks undertaken by the organization related to the

implementation of its business strategies.

Cyber Risk is a modern phenomenon born in the 20th century and refers to risks
associated with cyber-related threats.

2. INTERNAL AUDIT:

Internal audits evaluate a company’s internal controls, including its corporate

governance and accounting processes. They ensure compliance with laws and
regulations and help to maintain accurate and timely financial reporting and data
collection. Internal audits also provide management with the tools necessary to attain
operational efficiency by identifying problems and correcting lapses before they are
discovered in an external audit.

KEY TAKEAWAYS

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An internal audit offers risk management and evaluates the effectiveness of a
company’s internal controls, corporate governance, and accounting processes.

Internal audits provide management and board of directors with a value-added service
where flaws in a process may be caught and corrected prior to external audits.

3. DUE DILIGENCE AUDIT:

Due diligence is an investigation or audit of a potential investment or product to

confirm all facts, that might include the review of financial records. Due diligence refers
to the research done before entering into an agreement or a financial transaction with
another party. Investors perform due diligence before buying a security from a
company. Due diligence can also refer to the investigation a seller performs on a buyer
that might include whether the buyer has adequate resources to complete the purchase.
Due Diligence Audit is that audit which is carried out in order to find/estimate the actual
financial position of the organization before a large decision is about to take place like
mergers and acquisitions, loan agreement, or when the company’s financial position is
going to be presented to the public.

4. SYSTEM IMPLEMENTATION AND REVIEW:

System Implementation is the process of taking your ideas and integrating them into
your companies operation. This part of the process is the most time consuming and
costly part of the system design. It starts with the building part of system design to make
sure that your design is accomplishing what it wanted to accomplish. It is the implement
of the system to user and how they function together in response to one another. This
process many sometimes require the hiring or training of employees. Designation of
roles should already be decided with the process of inputs and outputs being defined.
Training is one of the most vital parts to the implementation phase it will provide a
smooth transition from the old system to the new system or into the modification.
(System Implementation, 2015)

The final stage of system design is the maintenance and review stage which will keep
your system functioning at optimal levels at all time. The system has to be maintained

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throughout its life to maintain its operational capabilities. This includes scheduled and
preventative maintenance this will help to minimize down time. Creating a plan that
includes service parts, system analysis, and proper function will keep your system
performing as it should.

5.REGULATORY COMPLIANCE SERVICES:

Regulatory compliance describes the goal that organisations aspire to achieve in their
efforts to ensure that they are aware of and take steps to comply with relevant laws
and regulations. The services which are included in compliance management are
called as compliance services.

Janaswamy Associate’s Regulatory & Compliance team provides the following key
services:

5.a Corporate Advisory:

Janaswamy Associates have the right blend of people with requisite skills to render
corporate regulatory and financial services. Review & Enhancement of Risk
management and oversight functions in the organization may include strengthening of
internal control systems & E‐governance systems. We provide Advisory to Private
Equity funds on fund organization, identification of opportunities, due diligence,
negotiations and other documentation support.

5.b Business valuations:

Valuation involves advising on valuation of business, company, share and asset, both
for commercial and statutory purposes. Valuations assignments may be conducted
alongside other services such as tax and regulatory, forensic and financial reporting.
Janaswamy’s valuation services are broadly offered during
restructuring/purchase/sale/litigation and regulatory compliance by RBI under FEMA
regulations. Their services, with regard to above, include: Valuation of shareholders’
fund and per share valuation, Business valuation, equity valuation and fixed asset
valuations.

5.c Tax Deduction at Sources:

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Compliance's with Indian withholding tax requirements‐ including monthly compiling
of TDS from clients records, timely deposit of taxes, filing of quarterly e‐ TDS returns
and Issuance of Annual certificates to Vendors.

5.d FEMA Consultancy Services:

The organization is capable of providing a vast spectrum of consultancy services such

as FEMA Consultancy Services specifically applicable for foreign investment in India.
Due to their vast experience in this domain, they have carved a distinct niche in the
market as the reliable FEMA Consultancy. These services include setting up
subsidiaries of foreign companies in India along with FEMA / RBI compliance for
inbound and outbound investments.

5.e Mergers and Acquisitions:

The need for business and financial restructuring and increased competition among
domestic and global conglomerates has acted as a catalyst to spur Mergers &
Acquisitions activity in India. They advise organisations on Corporate and business
restructuring involving business consolidations and/or divestment for value accretion,
unlocking value and future fund raising. Group restructuring including form of
corporate organization (corporate, limited liability partnership, partnership),
shareholding rationalization and family arrangement, Capital and financial structuring
for balance‐sheet management, fund raising, exit strategy, cash repatriations and
business tax planning, Domestic and cross border business and / or corporate
acquisition strategy involving valuations, due diligence (financial, tax and legal),
negotiations financing and related documentation support.

6. FINANCIAL PROCESS OUTSOURCING:

Outsourcing is a business practice in which a company hires another company or an

individual to perform tasks, handle operations or provide services that are either
usually executed or had previously been done by the company's own employees.
Outsourcing the finance and accounting processes has recently become a strategic issue
for many organisations. Businesses are under increasing pressure to improve
performance and reduce costs. Although the emphasis has often been on reducing cost,
there is a trend towards outsourcing to enable strategic change. The real value to be

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gained is that the retained finance function can focus on working more closely with the
business to provide business partnering and help improve decision making.

7. ACCOUNTING SUPPORT SERVICES:

To perform technical accounting and/or payroll auditing functions in support of the

accounting operations for assigned program(s) and/or fiscal services; to prepare and
maintain various financial and statistical records and reports; acts as a resource person
regarding assigned accounting areas.

Supervision Exercised and Received: Employees in this classification receive limited

supervision from a manager of fiscal services or a higher level position within
framework of standard policies and procedures. Employees in this class my serve as a
lead position to Accounting Technician I’s and students.

8. AUDIT AND ASSURANCE SERVICES:

An audit is a systematic review and assessment of information or documents.

There are a few different types of audit but, in the specific context of professional
services, an audit is usually financial.

Assurance is a professional service with the aim of improving the quality and
transparency of information, to reduce the chance of problems occurring from incorrect
information. An audit is a type of assurance service.

Assurance services can be regulatory or compliance-based. They work to ensure that

a company or organisation is following guidelines, rules and policy, and provide both
internal and external confidence for financial statements.

1.3 SWOT ANALYSIS:

SWOT Analysis: - a study undertaken by an organization to identify its internal

strengths and weaknesses, as well as its external opportunities and threats.

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A. Strength:- Over the period of last 20 years Janaswamy Associates pioneered
itself in delivering Auditing and Assurance services to Banking and Financial Services
industry (BFSI). Following are the two major strengths noticed during my internship
with them: -
• Delivery/completion of assigned task/projects in a time bound manner
with accuracy and quality.
• Providing solutions to complex problems faced by clients.
• Its trained staff having good expertise in the relevant area of assurance
services specialized for customer needs.

B. Weakness:- Unlike any other organization Janaswamy Associates also has its
own weaknesses which makes it even more competitive as the firm engages in
continuous process of improving and strengthening itself. Following are the two
major weaknesses noticed during my internship with them: -
• Since Janaswamy Associates continuously engaged in various assurance
services firm trains its employees on constant basis for changes happening
in regulatory requirements. However firm deals with unique weakness
whereby its employees are absorbed by its clients resulting in high
employee turnover.
• Since the Firm employs various senior bankers, sometimes it becomes
difficult for the firm to adapt to changes happening in technological
environment.

C. Opportunities:- Being a chartered accountancy firm, Janaswamy Associates

has pioneered into very niche area of practice i.e. BFSI and following are the
two major opportunities noticed during my internship with them: -
• Janaswany Associates caters to a wide range of BFSI needs and thereby it
is in a position to exploit the changes occurring in the regulatory
environment.
• Janaswamy Associates continuously engaged in new product
development which is customized and delivered as per customer needs.

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 D. Threats:- Being a mid-sized chartered accountancy firm it has its own inherent
external threats. Following are the two major threats noticed during my
internship with them: -
• Janaswany Associates caters to a wide range of BFSI needs only which
makes it more prone to the risk of tough competition as lately there are
many new entrants who have started to cater the Auditing and assurance
needs of BFSI.
• Since there are constant upgradation of technological tracking by regulator
which may make it tough for the firm to retails many support services it is
providing to the BFSI sector.

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 CHAPTER 2

STATEMENT AND OBJECTIVES

2.1 VISION

It is our continuous endeavor to

1. Focus on the essential areas especially in managing risks and the management of
business as a whole.

2. Make effective use of technology.

3. Communicate on a regular and timely basis with the management.

4. Study of Internal controls, Transactions Process Controls, Systems Review.

5. Determine the needs of the clients and endeavor to exceed their expectations.

2.2 MISSION

1. To emerge as a leading Value Added Service Provider to all our clients.

2. To determine client’s needs and exceed their expectations.

3. To provide clients with timely & cost‐effective solutions.

4. To assist our clients to grow and thus ensure our growth by providing innovative
solutions.

5. To Provide services of the highest quality and integrity.

2.3 VALUES

As a CA Firm our values are defined by Integrity, Courage, Confidentiality, Continuous

Learning, Empathy, Innovation, Holistic Approach and Synergy with Razor sharp
Client Focus.

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 CHAPTER 3

ROLE IN THE ORGANISATION

Reporting of Cross Border Wire Transfers of STANDARD CHARTERED BANK

3.1 INTRODUCTION TO STANDARD CHARTERED BANK

Standard Chartered PLC is a British multinational banking and financial

services company headquartered in London, England. It operates a network of more
than 1,200 branches and outlets (including subsidiaries, associates and joint ventures)
across more than 70 countries and employs around 87,000 people. It is a universal
bank with operations in consumer, corporate and institutional banking, and treasury
services. Despite its UK base, it does not conduct retail banking in the UK, and around
90% of its profits come from Asia, Africa and the Middle East.

Standard Chartered has a primary listing on the London Stock Exchange and is a
constituent of the FTSE 100 Index. It had a market capitalisation of approximately
£24.4 billion as of 4 April 2017, the 28th-largest of any company with a primary listing
on the London Stock Exchange. It has secondary listings on the Hong Kong Stock
Exchange and the National Stock Exchange of India. Its largest shareholder is
the Government of Singapore-owned Temasek Holdings.

José Viñals is the Group Chairman of Standard Chartered. Bill Winters is the current
Group Chief Executive.

3.1.1 Name

The name Standard Chartered comes from the names of the two banks from which it
was formed by merger in 1969: The Chartered Bank of India, Australia and China,
and Standard Bank of British South Africa.

3.1.2 Overview of standard chartered bank:

Standard chartered bank is a multinational financial services company which is

headquartered in London, United Kingdom. Apart from United Kingdom, the bank has
operations in more than seventy countries throughout the whole world. In addition, the
bank operates a network of 1700 branches including subsidiaries, associates and joint

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ventures. The bank also employs around 80,000 people throughout the whole world.
According to the data of 2010, standard chartered bank employs about 85,231 people .
Basically this bank is also known as Universal or global bank. The bank has also
operations in consumer, corporate and institutional banking and treasury services.
Instead of this British base, round about 90 percent of its profit come from Africa, Asia
and the Middle East. The following bank is also a primary listed member of London
Stock Exchange and also is a constituent of the FTSE 100 Index. Further more , this
bank has also secondary listings on the Hong Kong Stock Exchange and the Indian
Stock Exchanges. Standard Chartered bank is also the largest shareholder in the
Government of Singapore-owned Temasek Holdings.

3.1.3 Background of the Company

In most of the territories of the universe, the standard chartered bank PLC (public
limited company) has expanded its operation. The bank focuses its activities in Asia,
Africa and the Middle East. In addition, its operation is segmented under six regions:
LTK and Europe, Middle East and South Asia (MESA), South East Asia, and the
America .The Standard Chartered was formed in 1969 through a merger of two banks:
The Standard Bank of British South Africa which was founded in 1863, and the
Chartered Bank of India, Australia and China ,which was founded in 1853. Both
companies were keen to capitalize on the huge expansion of trade and to earn the
handsome profits to be made from financing the movement of goods from Europe to
the East and to Africa.

3.1.4 The Chartered Bank

Founded by James Wilson following the grant of a Royal Charter by Queen Victoria
in 1853

Chartered opened its first branches in Mumbai (Bombay), Kolkata and Shanghai in
1858, followed by Hong Kong and Singapore in 1859

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Traditional trade was in cotton from Mumbai (Bombay), indigo and tea from Kolkata,
rice from Burma, sugar from Java, tobacco from Sumatra, hemp from Manila and silk
from Yokohama.

Played a major role in the development of trade with the East which followed the
opening of the Suez Canal in 1869 and the extension of the telegraph to China in 1871.

In 1957 Chartered Bank bought the Eastern Bank together with the Ionian Bank's
Cyprus Branches. This established a presence in the Gulf.

3.1.5 The Standard Bank

Founded in the Cape Province of South Africa in 1862 by John Paterson. Commenced
business in Port Elizabeth, in January 1863.

Was prominent in financing the development of the diamond fields of Kimberley from
1867 and later extended its network further north to the new town of Johannesburg
when gold was discovered there in 1885. Expanded in Southern, Central and Eastern
Africa and, by 1953, had 600 offices.

In 1965, it merged with the Bank of West Africa, expanding its operations into
Cameroon, Gambia, Ghana, Nigeria and Sierra Leone. In 1969, the decision was made
by Chartered and by Standard to undergo a friendly merger. On January30, 1970 the
new shares of the Standard and Chartered Banking Group Limited were listed in the
London Stock Exchange. From the early 1990s, Standard Chartered has focused on
developing its strong franchises in Asia, Africa and the Middle East. It has concentrated
on consumer, corporate and institutional banking and on the provision of treasury
services - areas in which the Group had particular strength and expertise. Since 2000
the Bank has achieved several milestones with a number of strategic alliances and
acquisitions, which have extended the customer and geographic reach and enlarged the
product range that Standard Chartered offers.

3.1.6 Five Values of Standard Chartered Bank

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Standard Chartered Bank has five values, which are critical to their success. These
values determine how the employees achieve their goals, the way they work together
and how it feels to be a part of Standard Chartered Bank. In brief these values are:

1. Courageous

Being courageous is about confidently doing what is right. Often the task may seem
insurmountable but with courage and tenacity, the odds can be overcome. A truly
courageous act both inspires and builds character.

2. Responsive

How SCB responds to customers and how it will influence customer’s belief in their
commitment

towards them. A proactive response is often unexpected and more effective in such
case. It clearly

demonstrates organization’s willingness to go beyond the unexpected.

3. International

As a member of global village SCB views the world from the widest perspective. They
consider themselves to be global citizens and the world is full of new opportunities and
exciting possibilities. SCB also delivers world-class products and services.

4. Creative

Creativity belongs to those who are excited by challenges and engage themselves in
fresh thinking and an open mindedness. Creative thinkers are not limited by convention
but are those allow their minds to soar beyond predictable solutions. SCB believes that
they are a creative organization as well.

5. Trustworthy

Trust is the foundation of every successful relationship. SCB trusts because the
organization believes in the sincerity of their promise. They also believe that building
trust can take forever, but losing it takes only a moment.

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3.2 TYPES OF BANK TRANSFERS AND HOW THEY WORK CROSS
BORDER

3.2.1 Intra-bank transfers (Same-bank)

Intra-bank transfers are within the same bank and are quite simple. Assume we have Bob
and Alice, who both have accounts at the Emirates NBD (ENBD) bank. When Bob sends
money to Alice; the bank (ENBD) simply debits (reduces) Bob’s account balance and
credits (adds to) Alice’s account balance. A simple record operation. In this case the
only thing that changed are the internal balances for each of the account holders.

3.2.2 Inter-bank transfers (Across banks)

Inter-bank transfers are between different banks. These types of transfers are not as
simple as the intra-bank transfers. This type of transfers can either be direct or indirect.
A direct inter-bank transfer means that both banks interacting maintain an account for
the other bank, i.e Bank A has an account in Bank B and vice versa. The indirect inter-
bank transfer is when both banks interact using another party/parties (be it banks or other
financial entities).

The key insight is that for a transfer to take place, the source and destination banks must
have accounts at a single entity (i.e. a single set of “books”).

Let us explore how each of the two types work starting with direct inter-bank transfers.

3.2.3 Direct inter-bank transfer

As previously mentioned this type of bank transfers is when each of the banks hold an
account in the other bank. Let us go back to Bob and Alice. Assume Bob owns an
account in Emirates NBD and Alice owns an account in Mashreq Bank and both banks
are in the UAE. Also assume that Emirates NBD has an account with Mashreq Bank and
Mashreq Bank has an account at Emirates NBD.

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In this case when Bob (Emirates NBD) transfers money to Alice (Mashreq), Bobs Bank
ENBD debits (subtracts) Bob’s account and credits the Mashreq bank’s account it has.
ENBD then let’s Mashreq bank know, and Mashreq bank will credit Alice’s account on
the Alice’s account on the other side.

3.2.4 Indirect inter-bank transfers

Now not all banks own accounts in other banks. That is why when we transfer money
and in various occasions we are asked for what is called the intermediary
entity/bank or even a correspondent bank. Intermediary banks are for cases where a
bank does not have an account on the receiving bank. Again going back to our example
where Bob wants to send to Alice. In this case Emirates NBD does not have an account
in Mashreq Bank and vice versa. When a transfer happens Emirates NBD would debit
Bob’s account and would inform the intermediary bank where both banks have accounts
in say it is Standard Chartered; Emirates NBD will request Standard Chartered to debit
their account and credit Mashreq bank’s account it (Standard Chartered) has and
accordingly Mashreq bank would credit Alice’s account.

That is the general flow that is mostly used when going cross-border too. Also usually
when the banks are in the same country where it is managed and regulated by its Central
Bank the intermediary in many cases would be the Central Bank rather than another third
bank or another financial entity for within same county transfers.

Now when we transfer money cross border we also need to consider another important
point aside from whether each a bank has an account on the other bank; that is currency.

Let us assume Bob lives in the UAE and has a bank account in Emirates NBD and that
Alice lives in Bahrain and has an account in the National Bank of Bahrain (NBB). When
Bob transfers to Alice we need to consider two cases as previously stated. Whether banks
have a direct relationship or an indirect relationship and also the currency.

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3.2.5 Cross border direct inter-bank transfers

Let us start with the direct inter-bank transfers. Assuming Emirates NBD has an account
in NBB and vice versa. Bob’s bank Emirates NBD will send a SWIFT transfer message
to Alice’s NBB bank in Bahrain and accordingly the debiting and crediting of accounts
would happens just as previously explained. Bob’s Emirates NBD bank will debit Bob’s
account and credit NBB’s account it has; NBB on the other end in Bahrain will credit
Alice’s account. Notice that we mentioned SWIFT? We have wrote about it here; It is
important to know what it does and I advise to read about it here. In short SWIFT allows
banks or financial entities to securely communicate using a unified and standard
protocol. SWIFT does not move the money, it is just the messaging bit between entities.

3.2.6 Cross border indirect inter-bank transfers

Now what if Emirates NBD did not have an account in NBB and vice versa a.k.a. an
indirect inter-bank transfer. This where the intermediary bank and SWIFT plays a major
role.

So Bob’s Emirates NBD bank in the UAE will send a transfer SWIFT message to Alice’s
bank (NBB) in Bahrain and given there aren’t accounts for either banks; SWIFT in this
case will reach a bank where both banks have accounts in (let us assume it is Standard
Chartered).

Emirates NBD will debit Bob’s account and ask the intermediary bank to debit its
account in Standard Chartered and credit NBB’s account also in Standard Chartered.
Standard Chartered takes its fee for facilitating the process. NBB will then credit Alice’s
account.

It is worth noting that sometimes more than one intermediary bank is necessary for a
transaction to complete (this is particularly acute in remote parts of the world); in some
cases the central banks are involved as another intermediary bank in the process. Since
wires generally operate on a netting basis (usually daily), it becomes clear why cross
border transfers are slow.

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If a different currency is involved than the exchange rate is usually done at either bank
at the lowest rate possible.

Banks networks are highly established and Verify Payments add a layer on top to
facilitate better access and utilization of banks by providing real-time payments using
banks transfers.

3.2.7 Cross-border wire transfer

Cross-border transfer means any wire transfer where the originator and the beneficiary
bank or financial institution are located in different countries. It may include any chain
of wire transfers that has at least one cross-border element.

Banks use wire transfers as an expeditious method for transferring funds between bank
accounts. Wire transfers include transactions occurring within the national boundaries
of a country or from one country to another. As wire transfers do not involve actual
movement of currency, they are considered as a rapid and secure method for
transferring value from one location to another.

Wire transfer, bank transfer or credit transfer, is a method of electronic funds

transfer from one person or entity to another. A wire transfer can be made from one
bank account to another bank account or through a transfer of cash at a cash office.

Different wire transfer systems and operators provide a variety of options relative to
the immediacy and finality of settlement and the cost, value, and volume of
transactions. Central bank wire transfer systems, such as the Federal Reserve's Fed
Wire system in the United States, are more likely to be real-time gross
settlement(RTGS) systems. RTGS systems provide the quickest availability of funds
because they provide immediate "real-time" and final "irrevocable" settlement by
posting the gross (complete) entry against electronic accounts of the wire transfer
system operator. Other systems such as Clearing House Interbank Payments
System (CHIPS) provide net settlement on a periodic basis. More immediate settlement
systems tend to process higher monetary value time-critical transactions, have higher

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transaction costs, and have a smaller volume of payments. A faster settlement process
allows less time for currency fluctuations while money is in transit.

3.3 SWIFT MESSAGE

3.3.1 SWIFT MT103 is an improvised version of the original MT100 customer credit
transfer message.

MT103 is used to make a single payment. It has a large number of options that are to
describe exactly how the payment should be made.

Let us study a few examples of MT103 facilitating foreign currency trade payments
between the exporter and importer located in 2 countries. Through our example we will
examine the architecture of trade payments between with 2 banks having a single
account relationship, 2 banks having multiple account relationship and 2 banks having
no relationship thereby using an intermediary bank to facilitate the actual
payment.Please remember that MT103 like other SWIFT messages is a mere
communication of financial transaction. SWIFT offers a secured, encrypted and
standardized medium of financial transaction communication.

MT 103 FIELDS

Field Field Name

:20 Transaction Reference Number
:23B Bank Operation Code
:32A Value Date/ Currency/ Interbank Settled
:33B Currency/ Original Ordered Amount
:50A, F or K Ordering Customer (Payer)
:52A or D Ordering Institution (Payer’s Bank)
:53A, B or D Sender’s Correspondent (Bank)
:54A, B or D Receiver’s Correspondent (Bank)
:56A, C or D Intermediary (Bank)
:57A, B, C or D Account with Institution (Beneficiary’s Bank)
:59 or 59A Beneficiary
:70 Remittance Information (Payment Reference)

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 :71A Details Of Charges (BEN/OUR/SHA)
:72 Sender to Receiver Information
:77B Regulatory Reporting

Payment Reference: Your bank payment reference must be indicated in all MT103
and it should be correct. This reference number enables the payee/beneficiary to apply
the payment.

BEN/OUR/SHA: This field indicates as to who is being the transfer charges. The
‘OUR’ instructions mean that the sender will bear the charges. ‘SHA’ means means
sender only pay sender bank’s outgoing transfer charge. Receiver receives the payment
minus the correspondent bank charges. ‘BEN’ (beneficiary) means sender does not pay
any charge. Beneficiary receives the payment minus all transfer charges.

MT103 – Single Customer Credit Transfer with Direct Account Relationship

Circles G.m.b.H. orders UBS, Zürich, to pay Euro 1,558.47 to ABN Amro Bank,
Amsterdam, for the account of W.E. Jose.

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In the above example no reimbursement party will be indicated as the home currency
as well as the transaction currency is Euro (no conversion involved) and both the bank
have an account relationship. The direct account relationship, in the currency of the
transfer, between the Sender and the Receiver will be used.

UBS Zurich will debit the account of Circle G.m.b.H and credit the account of ABN
Amro Bank held with them for Euro 1558.47 whereas ABN Amro bank will debit the
account of UBS by Euro 1558.47 and credit W.E.Jose. These 2 banks have only one
account in Euro currency held with each other hence no serviced/settlement account
needs to be specified. Final beneficiary is W.E.Jose whose account is held with ABN
Amro Bank.

MT103 – Single Customer Credit Transfer specifying account for reimbursement

Transaction: Circles G.m.b.H. orders UBS, Zürich, to pay Euro 1,558.47 to ABN
Amro Bank, Amsterdam, for the account of W.E. Jose.

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However by this time, these 2 banks have more than one Euro account relationship,
hence UBS, Zürich will have to specify the particular account number that needs to be
used for reimbursement and settlement. The flow of the transaction will be the same as
the above example, the only addition is the mention of reimbursement account in the
SWIFT message.

In field 53b of MT103 the account number (say 456 75 1598) of the Sender’s account
(UBS Zurich), serviced by the Receiver(ABN Amro Bank), which is to be used for
reimbursement in the transfer will be specified.

This way ABN Amro bank will know as to which particular Euro account of UBS held
with them needs to be debited to settle the transaction.

MT103 – Single Customer Credit Transfer with ordering and account-with

institution.

Circles G.m.b.H. orders UBS, Zürich, to pay USD 2000.00 to OCBC Bank, Singapore
for the account of W.E. Jose.

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Please note 2 changes in this example; currency is USD and UBS, Zurich does not a
hold a USD account directly with any bank (assumption held for the sake of this
example).

Since UBS, Zurich does not have a direct account relationship with OCBC Bank and
does not hold a USD account it requests Goldman Sachs bank AG, Zurich to handle the
transaction. UBS, Zurich routes all its USD transaction through its correspondent bank
Goldman Sachs AG, Zurich as it has a Dollar account with Citibank New York.

Now both the banks ie Goldman Sach Bank AG and OCBC Bank SG have a USD
currency account with Citibank, New York. Hence the transaction can be successfully
routed through Citibank New York for settlement in USD.

Note that in order to settle this particular transaction there will be 2 MT103 messages
sent

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First MT103: will be sent by Goldman Sachs AG, Zurich to Citibank, New York for
$2000.00 instructing Citibank to debit their USD account for $2000.00 and credit
OCBC Bank Singapore for $2000.00.

Second MT103: will be sent by Citibank New York to OCBC Bank, Singapore
instructing them to debit their USD account for $2000.00 and credit the beneficiary
W.E.Jose.

3.3.2 SWIFT MT 202

What is an MT202?

When a SWIFT payment is booked, an MT103 payment confirmation is created. This

is a message from the sending bank to the recipient's bank, instructing the recipient's
bank to credit the recipient a certain amount.

However, often for international SWIFT payments, funds have to move between several
different banks before they reach the recipient. The way that the banks in between the
sender and recipient communicate the transfer of these funds is with an MT202 cover
message.

This MT202 message informs each of the banks in the chain of the payment amount,
currency and recipient bank.

The MT202 also creates an audit trail, so it's easy to see who helped process the transfer
of funds from the sender to the recipient. SWIFT has also recently implemented their
updated, SWIFT gpi system. This will provide banks and financial institutions with

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huge improvements to the tracking and visibility of payments made via the SWIFT
payment network.

If you make an international payment via SWIFT, you probably won't see the MT202,
but you may be able to see the MT103 payment confirmation.

Purpose of the message MT202

Requests the movement of funds between financial institutions, except if the transfer is
related to an underlying customer credit transfer that was sent with the cover method,
in which case the MT 202 COV must be used.

Scope of the message MT202

This message is sent by or on behalf of the ordering institution directly, or through
correspondent(s), to the financial institution of the beneficiary institution. All parties
identified in the message must be financial institutions.
It is used to order the movement of funds to the beneficiary institution.
This message may also be sent to a financial institution servicing multiple accounts for
the Sender to transfer funds between these accounts. In addition it can be sent to a
financial institution to debit an account of the Sender serviced by the Receiver and to
credit an account, owned by the Sender at an institution specified in field 57a.
This message must not be used to order the movement of funds related to an underlying
customer credit transfer that was sent with the cover method. For these payments the
MT 202 COV or MT 205 COV must be used.

Fields Field Name

:20 Transaction Reference Number
:21 Related Reference
:13C Time Indication
:32A Value Date, Currency Code, Amount
:52 A or D Ordering Institution
:53A, B or D Sender’s Correspondent
:54A, B, D Receiver’s Correspondent

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 :56A or D Intermediary
:57A, B or D Account with Institution
:58A, D Beneficiary Institution
:72 Sender to Receiver Information

3.4 History

The first widely used service for wire transfers was launched by Western Union in 1872
on its existing telegraph network. Once a sender had paid money to one telegraph
office, the operator could transmit a message and "wire" the money to another office,
using passwords and code books to authorize the release of the funds to a recipient at
that location. By 1877 the service was used to transfer almost $2.5 million each year.
Because the earliest wire transfers were using telegraph networks, it was
termed telegraphic transfer and this name is still used in some countries.

3.5 The salient features of a wire transfer transaction are as under :

i) Wire transfer is a transaction carried out on behalf of an originator person (both

natural and legal) through a bank by electronic means with a view to making an amount
of money available to a beneficiary person at a bank. The originator and the beneficiary
may be the same person.

ii) Cross-border transfer means any wire transfer where the originator and the
beneficiary bank or financial institution are located in different countries. It may include
any chain of wire transfers that has at least one cross-border element.

iii) Domestic wire transfer means any wire transfer where the originator and receiver
are located in the same country. It may also include a chain of wire transfers that takes
place entirely within the borders of a single country even though the system used to
effect the wire transfer may be located in another country.

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iv) The originator is the account holder, or where there is no account, the person (natural
or legal) that places the order with the bank to perform the wire transfer

3.6 Process

A bank wire transfer is effected as follows:

1. The entity wishing to do a transfer approaches a bank and gives the bank the
order to transfer a certain amount of money. IBAN and BIC codes are given as
well so the bank knows where the money needs to be sent.
2. The sending bank transmits a message, via a secure system (such
as SWIFT or Fedwire), to the receiving bank, requesting that it effect payment
according to the instructions given.
3. The message also includes settlement instructions. The actual transfer is not
instantaneous: funds may take several hours or even days to move from the
sender's account to the receiver's account.
4. Either the banks involved must hold a reciprocal account with each other, or the
payment must be sent to a bank with such an account, a correspondent bank,
for further benefit to the ultimate recipient.
Banks collect payment for the service from the sender as well as from the recipient. The
sending bank typically collects a fee separate from the funds being transferred, while
the receiving bank and intermediary banks through which the transfer travels deduct
fees from the money being transferred so that the recipient receives less than what the
sender sent.

3.7 REASONS OF CBWTR REPORTING

A white paper published by the Government of India in the year 2012 suggests that
about INR 92.95 bank have been laundered or stacked by Indians in Swiss banks.
Experts however contend that the real number is much higher. Though an individual
account holder is held responsible in money laundering cases, the accountability also
lies equally with financial institutions for adequate reporting of facts to the authorities.
Financial institutions could therefore attract penalties in case of delays, non-reporting
and/or misreporting of information.

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In India, Money laundering is regulated under the Prevention of Money Laundering
Act, 2002 (PMLA) that obligates banking companies, financial institutions and
intermediaries to verify and record client identity, fund beneficiaries and related
transaction details and furnish this information to the Financial Intelligence Unit –
India (FIU-IND).

3.7.1 Money laundering

Money laundering is any act or attempt to conceal or disguise the identity of illegally
obtained funds so that they appear to have originated from legitimate sources. These
funds are moved between countries through shell accounts/ companies, intermediaries
and /or money transmitters to finally enter the economy through legalized businesses,
eventually integrating with the economy.
Internationally, money laundering is regulated by INTERPOL ( International Criminal
Police Organization) , while in India it is the joint responsibility of a number of
institutions including the Financial Intelligence Unit – India (FIU-IND).
3.7.2 Terrorists and criminals
Wire transfer is an instantaneous and most preferred route for transfer of funds across
the globe and hence, there is a need for preventing terrorists and other criminals from
having unfettered access to wire transfers for moving their funds and for detecting any
misuse when it occurs. This can be achieved if basic information on the originator of
wire transfers is immediately available to appropriate law enforcement and/or
prosecutorial authorities in order to assist them in detecting, investigating, prosecuting
terrorists or other criminals and tracing their assets.

3.7.3 Periodicity of cross border wire transfer Cross report

The Notification no 12 of 2013 dtd 27.08. 2013 requires that “All cross border wire
transfers of the value of more than five lakhs rupees or its equivalent in foreign currency
where either the origin or destination of fund is in India needs to be reported by the 15th
of the succeeding month.

Governments in several countries have formed Financial Intelligence Units (FIU) to

receive, process and disseminate information on money related crimes. They function
as a national centre for the receipt and analysis of suspicious transactions, information
about money laundering, other related offences and financing of terrorism. FIUs in most
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countries has administrative and law enforcement nature. Financial Intelligence Unit
work in cooperation with the international bodies like the FATF and the Egmont
Group.

3.8 Financial Intelligence Unit of India (FIU -IND)

The FIU- IND was set by the Government of India in 2004 as the central national
agency responsible for receiving, processing, analyzing and disseminating information
relating to suspect financial transactions.
FIU-IND is an independent body reporting directly to the Economic Intelligence
Council (EIC) headed by the Finance Minister. The function of FIU-IND is to receive
cash/suspicious transaction reports, analyse them and, as appropriate, disseminate
valuable financial information to intelligence/enforcement agencies and regulatory
authorities.

3.8.1 Constitution of FIU

The FIU – IND is a multidisciplinary body with a sanctioned strength of 74 members
from various government departments. The members are inducted from organizations
including Central Board of Direct Taxes (CBDT), Central Board of Excise and Customs
(CBEC), Reserve Bank of India (RBI), Securities Exchange Board of India (SEBI),
Department of Legal Affairs and Intelligence agencies.

The Financial Intelligence Unit, India (FIU-IND) was set by the Government of India
in 2004
as the central national agency responsible for receiving, processing, analysing and
disseminating information relating to suspect financial transactions.
FIU-IND is an independent body reporting directly to the Economic Intelligence
Council
(EIC) headed by the Finance Minister.
It is a multidisciplinary body with a sanctioned strength of 74 members from various
government departments.
The members are inducted from organizations including Central Board of Direct
Taxes
(CBDT), Central Board of Excise and Customs (CBEC), Reserve Bank of India (RBI),

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Securities Exchange Board of India (SEBI), Department of Legal Affairs and
Intelligence
agencies.
It is responsible for coordinating and strengthening efforts of national and
international
intelligence, investigation and enforcement agencies in pursuing the global efforts
against
money laundering and related crimes.
It aims to provide quality financial intelligence for safeguarding the financial system
from the
abuses of money laundering, terrorism financing and other economic offences.

3.8.2 The functions of FIU-IND are:

The function of FIU-IND is to receive cash/suspicious transaction reports, analyse
them and,
as appropriate, disseminate valuable financial information to intelligence/enforcement
agencies and regulatory authorities.
Collection of Information: Act as the central reception point for receiving Cash
Transaction
reports (CTRs), Cross Border Wire Transfer Reports (CBWTRs), Reports on Purchase
or
Sale of Immovable Property (IPRs) and Suspicious Transaction Reports (STRs) from
various
reporting entities.
Analysis of Information: Analyse received information to uncover patterns of
transactions
suggesting suspicion of money laundering and related crimes.
Sharing of Information: Sharing information with national intelligence/law
enforcement
agencies, national regulatory authorities and foreign Financial Intelligence Units.
Act as Central Repository: Establish and maintain national data base on cash
transactions and
suspicious transactions on the basis of reports received from reporting entities.

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 Coordination: Coordinate and strengthen collection and sharing of financial
intelligence
through an effective national, regional and global network to combat money laundering
and
related crimes.
The main function of FIU-IND is to receive cash/suspicious transaction reports, analyse
them
and, as appropriate, disseminate valuable financial information to
intelligence/enforcement
agencies and regulatory authorities . The functions of FIU-IND are:
Collection of Information: Act as the central reception point for receiving Cash
Transaction reports (CTRs),Non-Profit Organisation Transaction Report(NTRs), Cross
Border Wire Transfer Reports (CBWTRs), Reports on Purchase or Sale of Immovable
Property (IPRs) and Suspicious Transaction Reports (STRs) from various reporting
entities.
Analysis of Information: Analyze received information in order to uncover patterns
of
transactions suggesting suspicion of money laundering and related crimes.
Sharing of Information:Share information with national intelligence/law
enforcement
agencies, national regulatory authorities and foreign Financial Intelligence Units.
Act as Central Repository:Establish and maintain national data base on the basis of
reports received from reporting entities.
Coordination:Coordinate and strengthen collection and sharing of financial
intelligence
through an effective national, regional and global network to combat money laundering
and related crimes.
Research and Analysis:Monitor and identify strategic key areas on money laundering
trends, typologies and developments.

3.8.3 Why you need to report to FIU-IND ?

The FIU-IND or FIU is the regulatory arm of the government that keeps track of all
the suspicious transactions and/or cash transactions taking place across the country
and devises strategies to counter money laundering.
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The FIU maintains a national database of all transactions received from the reporting
entities, and analyse it for discrepancies.
The agency also disseminates information to domestic and international
intelligence/fraud investigation agencies, promotes awareness on the issue and
suggests policy changes to counter it.
Any act is suspected to be a money laundering offence, the proceeds are liable to be
frozen, seized and confiscated under the PMLA.

3.8.4 Who needs to report to FIU-IND?

The Financial Intelligence Unit in India (FIU-IND) is responsible for analyzing and
raising red flags for all money laundering activities in the country. But the FIU is
dependent on receiving the information from other organizations who wade through
several thousand financial transactions daily and report such cases.
All financial entities in the economic system are supposed to report the Cash
Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) to the FIU
under the Prevention of Money Laundering Act, 2002 (PMLA). The rules of PMLA
apply to:
• Bank
• Financial institutions such as chit funds, housing finance companies, payment
system operators, non-banking financial companies, private cash loans
lenders and the Department of Posts
• Financial intermediaries such as stock brokers, registrars, portfolio managers,
investment advisors, underwriters etc.
• Enforcement Agency
• National Data Portal

3.9 What do you need to report under Anti-Money Laundering?

Under the prevention of money laundering act all reporting entities need to submit
reports to the FIU from time to time. The following reports need to be submitted
monthly:

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1. Cash Transaction Report (CTR):
a. Cash transactions of value more than rupees ten lakhs or its equivalent in foreign
currency.
b. Number of transactions for a single account, which are valued at more than rupees
ten lakhs within a month.

2. Cross Border Wire Transfer (CBWT) / Electronic Fund Transfer

3. Non-Profit Organization Transaction Report:

Cash transactions of more than rupees ten lakhs involving a non-profit organization
as recipient.

4. Cross Border Transaction Report :

All cross border wire transfers of value more than rupees five lakhs and above or its
equivalent in foreign currency.

The reporting entities also need to submit the following cash transaction reports
within 7 days of identification of a suspicious transaction:

1. Counterfeit Currency Report (CCR): Reporting of counterfeit currency.

2. Suspicious Transaction Report (STR): All suspicious transactions irrespective of
whether they are in cash or otherwise.

3.10 Important terms of CBWTR.

. The information can be used by Financial Intelligence Unit - India (FIU-IND) for
analysing suspicious or unusual activity and disseminating it as necessary. The
originator information can also be put to use by the beneficiary bank to facilitate
identification and reporting of suspicious transactions to FIU-IND. Owing to the
potential terrorist financing threat posed by small wire transfers, the objective is to be
in a position to trace all wire transfers with minimum threshold limits. Accordingly, we
advise that banks must ensure that all wire transfers are accompanied by the following
information:

3.10.1 Cross-border wire transfers

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(a) All cross-border wire transfers must be accompanied by accurate and meaningful
originator information.

(b) Information accompanying cross-border wire transfers must contain the name and
address of the originator and where an account exists, the number of that account. In
the absence of an account, a unique reference number, as prevalent in the country
concerned, must be included.

(c) Where several individual transfers from a single originator are bundled in a batch
file for transmission to beneficiaries in another country, they may be exempted from
including full originator information, provided they include the originator’s account
number or unique reference number as at (b) above.

3.10.2 Domestic wire transfers

(a) Information accompanying all domestic wire transfers of Rs. 50000/- (Rupees Fifty
Thousand) and above must include complete originator information i.e. name, address
and account number etc., unless full originator information can be made available to
the beneficiary bank by other means.

(b) If a bank has reason to believe that a customer is intentionally structuring wire
transfers to below Rs. 50000/- (Rupees Fifty Thousand) to several beneficiaries in order
to avoid reporting or monitoring, the bank must insist on complete customer
identification before effecting the transfer. In case of non-cooperation from the
customer, efforts should be made to establish his identity and Suspicious Transaction
Report (STR) should be made to FIU-IND.

(c) When a credit or debit card is used to effect money transfer, necessary information
as (a) above should be included in the message.

3.11 Exemptions

Interbank transfers and settlements where both the originator and beneficiary are banks
or financial institutions would be exempted from the above requirements.

3.12 Role of Ordering, Intermediary and Beneficiary banks

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3.12.1 Ordering bank

An ordering bank is the one that originates a wire transfer as per the order placed by its
customer. The ordering bank must ensure that qualifying wire transfers contain
complete originator information. The bank must also verify and preserve the
information at least for a period of ten years.

3.12.2 Intermediary bank

For both cross-border and domestic wire transfers, a bank processing an intermediary
element of a chain of wire transfers must ensure that all originator information
accompanying a wire transfer is retained with the transfer. Where technical limitations
prevent full originator information accompanying a cross-border wire transfer from
remaining with a related domestic wire transfer, a record must be kept at least for ten
years (as required under Prevention of Money Laundering Act, 2002) by the receiving
intermediary bank of all the information received from the ordering bank.

3.12.3 Beneficiary bank

A beneficiary bank should have effective risk-based procedures in place to identify wire
transfers lacking complete originator information. The lack of complete originator
information may be considered as a factor in assessing whether a wire transfer or related
transactions are suspicious and whether they should be reported to the Financial
Intelligence Unit-India. The beneficiary bank should also take up the matter with the
ordering bank if a transaction is not accompanied by detailed information of the fund
remitter. If the ordering bank fails to furnish information on the remitter, the beneficiary
bank should consider restricting or even terminating its business relationship with the
ordering bank.

These guidelines are issued under Section 35A of the Banking Regulation Act, 1949
and any contravention thereof may attract penalties under the relevant provisions of the
Act.

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3.13 Outward Telegraphic Transfer

3.13.1 What is Telegraphic Transfer?

Telegraphic transfer, also known as Wire transfer is an electronic method of transferring

funds. In this method, money is transferred from one bank to another via cable services
or telegraphs. Earlier, overseas payments via telegraphic transfer was a popular method.
Though, telegraph is not used for transfers today, name still remains the same for the
transfer of funds electronically or for any wire transfer transactions. Telegraphic
transfers are safe and convenient way to transfer funds to people staying overseas.
Telegraphic transfer or wire transfer is the most common means of transferring funds
overseas.

3.13.2 Wire transfer can be classified into two types which are as follows :

a) Cross border wire transfer which involves one domestic and one foreign entity. It
can be both outward and inward remittance. Outward remittance means remitting
money from your account in India to beneficiaries account overseas. Whereas, inward
remittance means getting money remitted to your account in India from overseas
remitter.

b) Domestic wire transfer is transaction that involves remitter and beneficiary located
in the same country.

3.13.3 How does Telegraphic Transfer Work?

To put it in a simpler way, telegraphic transfer works in a below process flow:

The remitter instructs his/herbank to wire the funds to beneficiary residing overseas.
Wire transfer instruction can be given to the bank by filling up the remittance form.
Some of the Indian banks also offer this wire transfer facility online over the net
banking services.

As per the instruction, money will then be sent by remitting bank to its corresponding
bank in the overseas country.

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If beneficiary holds an account in correspondent bank, then the money will be directly
credited to beneficiary account. If beneficiary holds an account with some other bank
in the country other than correspondent bank, then funds will be transferred to
beneficiary’s bank account.

Sometimes, the funds transfer process may have to pass through one or more
correspondent banks.

3.13.4 What is the Information Required for Telegraphic Transfer?

Here are the important points to be provided for telegraphic transfer :

• Name of the remitter

• Bank account details of remitter
• Payment currency
• Amount to be remitted
• Name of the beneficiary
• Account number of beneficiary or IBAN (International Bank Account Number)
for payments to UAE and Europe
• Name and address of beneficiary bank
• Beneficiary bank’s SWIFT(Society for Worldwide Interbank Financial
Telecommunication) code and BIC Code (Bank Identifier Code)
• Details of intermediary bank
• Reason or purpose of transfer

3.13.5 What is the Time Limit and Cost involved in Telegraphic Transfer?

Generally, telegraphic transfers take around two to four working days to reach its
destination depending on the origin and destination country of the transfer. It also
depends on various regulatory requirements of both the countries.

Telegraphic transfers are quite expensive as they are the fast mode of funds transfer.
Remittance charges will be levied by the remitting bank. Also, corresponding banks or
intermediary banks involved in the particular transaction may levy the charges to the
transaction as per their fee schedule. Remittance transaction may also be subjected to
charges from beneficiary bank at the time of giving credit. Remitter can choose to bear

36 | P a g e
the charges of remitting bank and its correspondent bank. In such cases, amount will be
debited from remitters account. Remitter can also choose to put the charges on
beneficiary. Then the amount will be credited to beneficiary after the deduction of total
charges.

3.13.6 What are the Benefits of Telegraphic Transfer?

Here are some important benefits of telegraphic transfer :

• Quick way to transfer funds as the money will reach beneficiary within 2 to 4
working
• Eliminates the cash transactions.
• This facility can be used across several Specifically, it’s beneficial for those
who are residing abroad and needs to send money to their family in home
country.
• As it is the faster way of transferring money, chances of getting affected by
exchange rate fluctuations are low.
• Convenient way of transferring funds overseas. Most of the banks now offer
wire transfer facility over internet banking.
• Amount can be transferred up to any limit as prescribed by FEMA (Foreign
Exchange Management Act).
• Secure and safe mode of transfer.

3.13.7 How to Remit Funds to India?

Specifically for NRIs, remittance can be actioned in many currencies. Funds in major
currencies like USD, EUR, GBP and many other can be transferred to your own account
or to any other person’s account in India with mentioning the clear purpose of transfer.

While submitting the instruction to ordering bank overseas, you need to ensure
beneficiary details along with beneficiary bank details and SWIFT code are correctly
mentioned. SWIFT code and intermediary bank details can be easily obtained from
concerned bank’s official website.

3.13.8 What is the Role of Banks in Wire Transfer?

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Remitting Bank

Ordering bank initiates the process of wire transfer as per the customer instructions.
Ordering bank needs to check whether the customer has provided all the information
(remitter’s information) correctly to qualify for a wire transfer. Bank must verify the
information before processing the wire transfer request.

Intermediary Bank

Intermediary bank involved in the wire transfer process must keep the record of all the
transaction and also ensure the details are correctly mentioned in the request.

Beneficiary Bank

Beneficiary bank must ensure the transaction carries the entire information of remitter
and the details of funds remitted. Banks need to be complied with certain norms, such
as anti-money laundering and Know Your Customer (KYC).

When there is any delay or something goes wrong, you can always approach your bank
with the transaction reference number. Transaction reference number is provided by the
remitting bank to remitter, as soon as the wire transfer transaction is initiated. Status of
the transaction can be tracked by financial institutions using this reference number.

Cross border remittances are subjected to various regulations and also terms and
conditions. Banks also ensure the due diligence from their end. With the faster process
and convenience involved, telegraphic transfer helps you to get the successful money
transfer to India, easily and quickly.

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 3.14 Field wise understanding for Outward Transactions for TRFTRN section

Column Outward Remittance

Referenc
e/ Column Remarks for
Serial Heading Outward
P (Remitter R (Beneficiary
Number Remittance
Leg) Leg)
of
TRFTRN
A / 1 Line Number* Self-Explanatory Self-Explanatory Running
sequence
number is being
used starting
from 1
B / 2 Report Serial Self-Explanatory Self-Explanatory The unique
Num* number which
uniquely
identifies a
report within a
batch.
Same number to
be used for both
P & R leg of a
single reported
CBWTR.
C / 3 Transaction Date* Transaction Transaction Posting date of
debit/credit date debit/credit date the transaction
to be reported
and not the
value date.
D / 4 Transaction Time Can be left blank Can be left blank No structured
if not available if not available data available
for this data
point.
E / 5 Transaction Ref System generated System generated Same number
No unique reference unique reference to be reported
number for the number for the for both
reported reported Remitter and
transaction. transaction. Beneficiary leg
of single
transaction.
F / 6 Transaction P for the remitter R for the Each
Type* leg beneficiary leg transaction
needs to
necessarily
have P & R leg
where in at
least one leg
should have an

39 | P a g e
 overseas
attribute. Cross
Border
Transactions
undertaken in
offshore
banking units
located within
India also need
to be reported
where one leg
is overseas.

G / 7 Instrument Type* Self-Explanatory Self-Explanatory The product

being used to
undertake the
crossborder
transaction
needs to be
reported. For
example, if the
product used is
a travel foreign
exchange card,
then the product
mapping would
be J-Prepaid
Card.
H / 8 Transaction Name of the Name of the For the remitter
Institution Name* ordering beneficiary bank leg, the name of
institution. where the the ordering
transaction institution
terminates should be
populated
which would be
derived from
the BIC/ IFSC
code.
For the
beneficiary leg,
details of the
institution
where the
transaction has
terminated
needs to be
populated.
In case of
reporting of

40 | P a g e
 transactions
undertaken
using credit/
prepaid card,
merchant bank
name or
acquiring bank
name to be
reported.
I / 9 Transaction BIC/ IFSC or Beneficiary Bank For the remitter
Institution Ref equivalent code BIC or equivalent leg, the
Num* of the ordering code where BIC/IFSC or
institution. the transaction equivalent code
terminates of the ordering
institution
should be
populated.

For the
beneficiary leg,
details of the
institution
where the
transaction has
terminated
needs to be
populated.
In case of
reporting of
transactions
undertaken
using credit/
prepaid card,
merchant bank
or acquiring
bank unique
code to be
reported
J / 10 Transaction State State code as per Default value of Since this is a
Code* Indian motor XX is suggested mandatory field
vehicle act, where for use and a value
the transaction needs to be
originates. populated for
the purpose of
rule validation,
a default value
of XX for
Beneficiary
state code is
suggested since

41 | P a g e
 Indian state
codes are not
applicable for
overseas
locations.
K / 11 Transaction Country code of Country code of At least one leg
Country Code* ordering the beneficiary should have an
institution bank where the overseas
transaction country code
terminates and the other
should
necessarily
have the
country code as
IN.
Additionally, in
case of
reporting of
transactions
undertaken
using credit/
prepaid card,
merchant bank
country code or
acquiring bank
country code
can be reported
in beneficiary
leg.
L / 12 Payment For Foreign For Foreign Since the
Instrument Currency cheques Currency cheques payment
Number / drafts issuance, / drafts issuance, messages are
the instrument the instrument generally
number should be number should be transmitted
populated populated using the
SWIFT
platform, there
is no
instrument
number
available. Only
in case of
foreign
exchange
cheques/
demand drafts
issued using
foreign
correspondent
banks, a

42 | P a g e
 cheque number
would be
available but
not as part of
the payment
message.
MT110 sent in
support can be
relied upon.
M / 13 Payment For Foreign For Foreign Since the
Instrument Issue Currency cheques Currency payment
Institute Name / drafts issuance, cheques / drafts messages are
the instrument issuance, the generally
issuing institute instrument transmitted
name should be issuing institute using the
populated name should be SWIFT
populated platform,
there is no
instrument
number
available. in
case of
foreign
exchange
cheques/
demand drafts
issued using
foreign
correspondent
banks,
MT110 sent
in support can
be relied upon
for the name
of the issuing
institute.
N / 14 Instrument Issue For Foreign For Foreign Since the
Institution Ref Currency Currency payment
Num cheques / drafts cheques / drafts messages are
issuance, the issuance, the generally
instrument instrument transmitted
issuing institute issuing institute using the
reference reference SWIFT
number should number platform,
be populated should be there is no
populated instrument
number
available.
Only in case
of foreign

43 | P a g e
 exchange
cheques/
demand
drafts issued
using foreign
correspondent
banks,
MT110 sent
in support can
be relied
upon for the
name of the
issuing
institute
reference
number.
O /15 Instrument Country code of Country code of The country
Country Code* the ordering the beneficiary code of the
institution bank where the beneficiary
transaction institution
terminates should be
populated
which would be
derived from
the BIC code.
(At least one
leg should
have an
overseas
country code.)

P / 16 AmountRupees* INR Value as per INR Value as per The INR vostro
system system credits greater
conversion rate conversion rate than INR 5
lakhs for each
individual
transaction
needs to be
reported. The
consolidated or
net outward
remittance to
the overseas
bank needs to
be separately
reported as a
CBWTR.
Conversion rate

44 | P a g e
 to be applied as
per system.
Q / 17 Amount Foreign Foreign Currency Foreign Currency Foreign
Currency* Value as per Value as per currency value
payment message/ payment message/ as derived from
system system the payment
message or
system.
Conversion rate
to be applied as
per system for
INR
denominated
cross border
transactions.
R / 18 Currency Of Currency Code Currency Code Three-digit
Transaction* code of the
transacting
currency to be
populated. The
currency code
should be same
in
both side of
transaction
S / 19 Purpose Of Purpose Code Purpose Code Purpose Code
Transaction* Description, as Description, as Description, as
per R- per per
Return Guidance R-Return R-Return
Guidance Guidance

T / 20 Purpose Code As per R-Return As per R-Return As per R-

Guidance Guidance Return
Guidance
U / 21 Risk Rating* The transactional The transactional Both the legs of
level risk rating level risk rating the transactions
arrived at as per arrived at as per need to have
the internal risk the internal risk the same risk
assessment of the assessment of the rating since this
reporting bank reporting bank is a
needs to be needs to be transactional
populated. populated. level risk
assessment.
V / 22 Customer Name* Remitter Name as Beneficiary name Name as
per payment as per payment available in the

45 | P a g e
 message/ RE message/ RE payment
system system message/ RE
system needs to
be populated
W / 23 Customer Id Customer ID of Can be left blank There is a
the remitter to be if not available length
populated as per restriction of 10
the bank’s system characters in
in case the the CBWTR
remitter is the format. In case
customer of the the customer ID
bank, else Can be is greater than
left blank if not 10 character,
available then the first 10
or last 10
characters of
the customer ID
needs to be
populated
X / 24 Occupation Occupation of the Can be left blank Occupation as
remitter to be if not available available in the
populated as per bank’s system
the bank’s system needs be
in case the populated
remitter is the
customer of the
bank, else Can be
left blank if not
available
Y / 25 Date Of Birth Date of birth of Can be left blank Date of birth/
the remitter to be if not available incorporation as
populated as per available in the
the bank’s system bank’s system
in case the needs to be
remitter is the populated
customer of the
bank, else to be
left blank. In case
of legal persons,
Date of
Incorporation
needs to be
populated.
Z / 26 Gender Gender of the Can be left blank Gender as
remitter to be if not available available in the
populated as per bank’s system
the bank’s system needs to be
in case the populated
remitter is the
customer of the

46 | P a g e
 bank, else to be
left blank. X-Not
Categorised needs
to be populated
for legal persons.
AA / 27 Nationality Nationality of the Can be left blank Nationality as
remitter to be if not available available in the
populated as per bank’s system
the bank’s system needs to be
in case the populated. For
remitter is the legal persons,
customer of the in case country
bank, else Can be of
left blank if not incorporation is
available available, then
the country
code needs to
be populated.
AB / 28 Identification Identification type Can be left blank Identification
Type of the remitter to if not available type as
be populated as available in the
per the bank’s bank’s system
system in case the needs to be
remitter is the populated. The
customer of the data in the
bank, else Can be bank’s system
left blank if not needs to be in
available line with the
FINnet
Reporting
format guide.
AC / 29 Identification Wherever the If the account ----
Number remitter is number of the
customer of the beneficiary (field
RE, identification AQ 43) is left
number of the blank, then this
remitter must be field must be
populated, as per populated with
identification the
type selected. identification/uni
In cases where que reference
the remitter is not number
a customer of the mentioned in the
RE, and if the SWIFT message.
account number (Also refer
of the remitter remarks in
(field AQ 43) is column AQ 43
left blank, then below)
this field must be
populated with

47 | P a g e
 the
identification/uni
que reference
number
mentioned in the
SWIFT message.
(Also refer
remarks in
column AQ 43
below)
AD / 30 Issuing Authority Issuing authority Can be left blank Please use the
of the ID of the if not available following:
remitter to be Passport -
populated as per Passport Office,
the bank's system Election ID
in case the card - Election
remitter is the Commission,
customer of the PAN Card -
bank, else Can be Income Tax
left blank if not Dept, ID Card -
available (As per issuing
authority),
Driving License
– RTO,
Account
introducer -
(not
applicable),
UIDAI Letter –
UIDAI,
NREGA job
card – NREGA,
Others - (as per
issuing
authority)
AE / 31 Place Of Issue Place of issuance Can be left blank Place of
of the ID of the if not available issuance of the
remitter to be ID as available
populated as per in the bank's
the bank's system system needs to
in case the be populated
remitter is the
customer of the
bank, else Can be
left blank if not
available
AF / 32 PAN PAN of the Can be left blank PAN as an
remitter to be if not available identifier needs
populated as per to be populated.
the bank's system Care needs to

48 | P a g e
 in case the be taken to
remitter is the avoid
customer of the populating any
bank, else Can be alternative
left blank if not value in this
available field.
AG / 33 UIN Aadhaar of the Can be left blank Aadhaar
remitter to be if not available number needs
populated as per to be populated
the bank's system provided the
in case the same is legally
remitter is the permitted.
customer of the
bank, else Can be
left blank if not
available
AH / 34 Address* For customer For customer In cases where
payments which payments which the address is
use the format use the format not available for
MT 103, the MT 103, the the
address of the address as beneficiaries,
remitter to be available in the then the BIC
populated as per message or any Code + Unique
the message or other system used No. (ID
bank's system. needs to be /Account) needs
populated. to be populated
in the address
field.
AI / 35 City For customer Can be left blank Name of the
payments, the city if not available city of the
of the remitter to remitter or
be populated as beneficiary is
per the bank's not a structured
system in case the data field in the
remitter is the message. In
customer of the case if any of
bank, else Can be the legs belong
left blank if not to a customer,
available. then the name
of the city can
be populated
basis the data
available in the
bank's system,
else Can be left
blank if not
available.
AJ / 36 State Code* For customer XX-not State Code of
payments, the categorised to be the remitter or
state code of the populated for the beneficiary is

49 | P a g e
 remitter to be beneficiary leg not a structured
populated as per since state code is data field in the
the bank's system unavailable for message. In
in case the the beneficiary case if any of
remitter is the the legs belong
customer of the to a customer,
bank. In all other then the state
cases, XX-not code can be
categorised to be populated basis
populated. the data
available in the
bank's system.
AK / 37 Pin Code For customer Can be left blank PIN code of the
payments, the if not available city of the
PIN code of the remitter or
city of the beneficiary is
remitter to be not a structured
populated as per data field in the
the bank's system message. In
in case the case if any of
beneficiary is the the legs belong
customer of the to a customer,
bank, else Can be then the PIN
left blank if not code of the city
available. can be
populated basis
the data
available in the
bank's system,
else Can be left
blank if not
available.
AL / 38 Country Code* For customer Since country Country Code
payments, the code is not a of the remitter
country code of structured data or beneficiary is
the remitter to be field in the not a structured
populated as per message, country data field in the
the bank's code of message. In
system. In case beneficiary case if any of
of intermediary institution to be the legs belong
payments, XX- used to populate to a customer,
not categorised this field. then the country
to be populated. code can be
populated basis
the data
available in the
bank's system.
AM / 39 Telephone For customer Can be left blank In case if any
payments, if not available of the legs
telephone number belong to a

50 | P a g e
 of the remitter to customer, then
be populated as the telephone
per the bank's number can be
system in case the populated basis
remitter is the the data
customer of the available in the
bank, else Can be bank's system,
left blank if not else Can be left
available. blank if not
available.
AN / 40 Mobile For customer Can be left blank In case if any
payments, mobile if not available of the legs
number of the belong to a
remitter to be customer, then
populated as per the mobile
the bank's system number can be
in case the populated basis
remitter is the the data
customer of the available in the
bank, else Can be bank's system,
left blank if not else Can be left
available. blank if not
available.
AO / 41 Fax For customer Can be left blank In case if any of
payments, fax if not available. the legs belong
number of the to a customer,
remitter to be then the fax
populated as per number can be
the bank's system populated basis
in case the the data
remitter is the available in the
customer of the bank's system,
bank, else Can be else Can be left
left blank if not blank if not
available. available.
AP / 42 Email For customer Can be left blank In case if any of
payments, email if not available the legs belong
address of the to a customer,
remitter to be then the email
populated as per address can be
the bank's system populated basis
in case the the data
remitter is the available in the
customer of the bank's system,
bank, else Can be else Can be left
left blank if not blank if not
available. available.
AQ / 43 Account Number Wherever the If the RE is able Bank to bank
remitter is to ascertain the payments are
customer of the account number undertaken

51 | P a g e
 RE, account of the beneficiary basis the BIC
number of the from any of the code of the
remitter must be fields in the banks. BIC
populated. SWIFT message, codes to be
then such account populated in
In cases where the number of the lieu of account
remitter is not a beneficiary must number for
customer of the be populated, else bank to bank
RE, if the RE is must be left transfers.
able to ascertain blank. Wherever
the account account number For credit card
number of the of the beneficiary payments, the
remitter from any is left blank, underlying
of the fields in the identification/uni credit card
SWIFT message, que reference number needs
then such account number (field AC to be populated
number of the 29) must be for the remitter
remitter must be populated. account details.
populated, else For beneficiary
must be left (Also refer account,
blank. Wherever remarks in merchant
account number column AC 29 account number
of the remitter is above) or a unique ID
left blank, of the merchant
identification/uni as available
que reference needs to be
number (field AC populated.
29) must be
populated.

(Also refer
remarks in
column
AC 29 above)
AR / 44 Account With Reporting entity Name of the For bank to
Institution Name name in case the beneficiary bank bank transfers
remitter is where the account using MT 202s,
customer. In is held. name of
other cases, name institution
of the institution needs to be
from where the derived from
transaction the BIC/ IFSC
originated/ code or
account was held. equivalent.

52 | P a g e
 AS / 45 Account With Reporting entity BIC of the For bank to
Institution Ref BIC in case the beneficiary bank bank transfers
Num remitter is where the account using MT 202s,
customer of is held. the BIC/ IFSC
reporting entity. code or
In other cases, equivalent
IFSC/BSR/BIC needs to be
of the institution populated.
from where the
transaction
originated/
account was held.
AT / 46 Related For customer For customer The name of
Institution Name payments which payments which the sender/
use the format use the format receiver
MT 103, Sender MT 103, Receiver correspondent
(remitter) (beneficiary) bank to be
Correspondent Correspondent populated
Bank name to be Bank name to be which would be
populated populated derived from
the BIC code.
In case the
reporting entity
is an
intermediary in
the transaction,
then the name
of the reporting
entity as a
related
institution on
the originator
side can also be
populated.
AU / 47 Institution To be updated as To be updated as Self-
Relation Flag E F Explanatory

AV / 48 Related For customer For customer The BIC of the

Institution Ref payments which payments which sender/ receiver
Num use the format use the format correspondent
MT 103, Sender MT 103, Receiver bank to be
(remitter) (beneficiary) populated. In
Correspondent Correspondent case the
Bank Bank reporting entity
BIC to be BIC to be is an
populated populated intermediary in
the transaction,
then the BIC of
the reporting

53 | P a g e
 entity as a
related
institution on
the originator
side can also be
populated.
AW / 49 Remarks Can be used as Can be used as Alternatively,
per reporting per reporting Can be left
entities discretion entities discretion blank if not
available.

54 | P a g e
 CHAPTER 4
CHALLENGES FACED

While understanding the internship, the intern had to face some challenges in order to
bridge the gap between the theoretical acquiring of knowledge and the practical
application of the same.

Along with bridging this gap the corporate culture was new to the intern and adapting
to it in the initial days was challenging. No doubt time management is an essential part
of every individual and very few master it. But in terms of professional life in order to
sustain one has no option but to learn to master it . of course due to college life there
is a sense of responsibility and discipline in the intern which made it easier for me to
balance both. Reporting on time was expected out of every single employee of the
company. The working hours were 1 am to 7pm.

Delivering on the expectations of the seniors and the company was a demanding task
which were not simply satisfied by the working hard but more importantly by being a
team player. The corporate ethics and code of conduct ensured that every single
employee or intern acted in a desirable manner and sometimes makes an intern go
against his/her judgements.

55 | P a g e
 CHAPTER 5
CONCLUSION

The time spent at the internship was no doubt learning for me. This project helped the
intern attain loads of knowledge about the different function periodically performed in
a chartered accountant firm. The atmosphere at the office was always welcoming,
additionally, it was satisfaction knowing that the intern was able to contribute to the
company by assisting .

The main thing the intern has learned through this internship is time management skills
as well self motivation . when I first started I did not think that I was going to be able
to make myself sit an office for eight hours a day, six days a week . Eventually when I
realized what I had to do I organized my day so it was not overlapping or wasting my
hours. I learned that I needed to be organized. From this internship and time
management the intern learn how to self motivate through the office for so many hours.

Asking questions is one key to learning and keeping oneself flexible throughout the
internship can open many doors. Internships are a great way to learn the ropes and so
the intern made sure to take advantages of the opportunity and not take experience
lightly.

56 | P a g e
 BIBLIOGRAPHY
https://www.investopedia.com

www.quora.com

https://corporatefinanceinstitute.com/

www.edjoin.org

https://www.moneymover.com/about/faqs/what-mt202

https://www.iotafinance.com/en/SWIFT-ISO15022-Message-typeMT202.html