The Banking Tutor’s

Notes

KYC & AML

Compiled by Sekhar Pariti
Book No 43 from The Banking Tutor

Page 1 of 77
 Introduction
KYC, or Know Your Customer is a critical process in the banking industry. KYC’s
purpose is to ensure that banks are doing business with legitimate customers and
that they are complying with KYC bank regulations.

KYC is the most important part of maintaining a healthy financial system. KYC
guidelines help prevent banks from being used by criminals for money laundering
activities but also enable them to better serve their customers and manage risks
wisely.

KYC means identifying and verifying the identity of the customer through
independent and reliable sources of documents, data, or information.

Banks may refuse to open an account or halt a business relationship if the client
fails to meet minimum KYC requirements.

In this Book, I have furnished important concepts related to KYC and AML (based
on RBI Master Direction updated 10th May 2021.

This Book contains two Parts – A & B.

Part A contains Notes related to KYC and AML.

Part 2 contains Objective Type Questions and Answers related to KYC and AML.

I sincerely Thank my Friend Mr Lalit Verma, Chief Manager, Canara Bank, New
Delhi who has helped me in many ways in bringing out this Book in this way.

25-08-2022 Sekhar Pariti

+91 94406 41014

Page 2 of 77
Part 1
Notes

Page 3 of 77
RE stands for Regulated Entity.

The objective of KYC guidelines are

(a) to prevent Bank from being used, intentionally or unintentionally, by

criminal elements for money laundering activities.

(b) to enable the bank to understand the customers and their financial
dealings be er so that the risks can be managed prudently.

The 4 main pillars on which the KYC norms of the Bank rests are:

1) Customer Acceptance Policy

2) Customer Identification Procedure

3) Monitoring of Transactions

4) Risk Management

OVD stands for Officially Valid Documents

Objectives of the Customer Acceptance Policy :

a) No account is opened in anonymous or fictitious/benami name.

b) Parameters of risk perception are clearly defined

c) Documentation requirements and other information to be collected in

respect of different categories of customers

d) Not to open an account or close an existing account where the bank is unable
to apply appropriate customer due diligence measures.

FIU IND stands for Financial Intelligence Unit - India (FIU-IND) is the central,
national agency responsible for receiving, processing, analyzing and
disseminating information relating to suspect financial transactions to
enforcement agencies and foreign FIU.

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Cash Transaction Report ( CTR) All cash transactions of the value of more
than Rs 10 Lacs or it’s equivalent in FC or series of cash transactions aggregating
Rs 10 Lacs or more in one month. Report to be submitted to FIU IND by 15th of
succeeding month.

Suspicious Transaction Report (STR) A transaction may be of suspicious

nature irrespective of the amount involved. There is no restrictions on
operations in the accounts where an STR has been made. There is no
periodicity of reporting suspicious transactions.

Non Profit Organisation ( NPOs) Transaction Report ( NTR) : NPO means any
organization that is registered as a Trust or society under Societies Registration
Act 1860 or any similar State Legislation or a company registered under Section
25 of the Companies Act 1956.

Receipt transaction of more than Rs 10 Lacs or equivalent in foreign currency in

NPO accounts is reported to FIU-IND .

"Customer risk" in the present context refers to the money laundering and
terrorist funding risk associated with a particular customer from a Bank's
perspective.

For risk categorization of customers, the IBA has provided a hybrid model
containing seven parameters .

(1) Customer Type ;

(2) Customer Profession ;

(3) Type of Business ;

(4) Product code ;

(5) Account Status ;

(6) Account vintage ;

(7) Deposit Balance (SB+CA+TD-).

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Customer Type means - Individual Salaried // Proprietorship concern / NGOs /
Trust / Private Ltd. Co. / Corporate / Associations / NRIs.

Customer Profession - Service/ Pensioner/ Accountant / Architect

/Contractor / Real Estate services /Agriculturist / Lawyer / HNI.

Type of Business : Central Govt. / State Manufacturing / Hotel / Import /

Export / Govt. / PSU Health services / NBFC.

Product code : SB Gen / FD Gen / SB CGA / SB NRO, NRE/FD / Staff / NRO,

NRE/FCNR.

Account Status : Active / Regular / Inoperative / dormant / Blocked /

Unclaimed.

Account vintage : One year and above // 6 months to less than one year /
Less than 6 months

Deposit Balance (SB+CA+TD) : Less than Rs. 25 lakh // 25.00 lakhs & above
to Rs. 100 lakh / Rs. 100 lakh above.

As per Sec 3 of Prevention of Money Laundering Act, ”Money Laundering” is an

offence committed by anyone who acquires, owns, possess or transfers any
proceeds of crim

or

knowingly enters into a transaction which is related to proceeds of crime,

either directly or indirectly

or

Conceals or aids in the concealment of the proceeds or gains of crime within

India or outside India commits the offence of money.

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For the purpose of KYC Norms, a 'Customer' is defined as a person who is
engaged in a financial transaction or activity with a reporting entity and
includes a person on whose behalf the person who is engaged in the
transaction or activity, is acting.

Designated Director means a person designated by the reporting entity

(Bank, financial institution, etc.) to ensure overall compliance with the
obligations imposed under chapter IV of the PML Act and the Rules.

Person : In terms of PML Act a 'person' includes an individual ; a Hindu

undivided family ; a company ; a firm ; an association of persons or a body of
individuals.

Transaction means a purchase, sale, loan, pledge, gift , transfer, delivery or the
arrangement thereof and includes- opening and operating of an account.

All customer profiles/accounts of NRIs, HNIs, PEPs, NGOs, Trusts, Cooperative

Societies, HUF, Exporters, Importers and Accounts having Beneficial Owners are
to be invariably categorised as High Risk. (irrespective of the lower risk category
(low/medium) allotted under other parameters in the Matrix.

Blocked Accounts and Unclaimed deposits are to be categorised as High Risk.

Accounts of dealers in jewellery, gold/silver/bullions, diamonds and other

precious metals/stones are to be categorised under High Risk.

Under vintage parameter, newly opened CASA accounts which have not
completed 6 months are to be categorised as High Risk.

Accounts in respect of which complaints received from Legal Enforcement

Authority or fraud is reported should be categorised under “High Risk”
category.

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Suggested Risk Categorization under Customer Type are as follows :

Individual, salaried- Low

Proprietorship concern/Pvt Ltd. Co./Corporates - Medium

NGOs/Trusts/Associations/NRIs- High

Suggested Risk Categorization under Customer Profession are as follows :

Service/Pensioner/Agriculturist – Low

Accountant/Architect/Lawyer – Medium

Contractor/Real Estate services/HNI- High

Suggested Risk Categorization under Type of Business are as follows

Central Govt./State Govt./PSU – Low

Manufacturing/Hotel/Health services – Medium

Imports/Exports/NBFC – High

Suggested Risk Categorization under Product Code are as follows :

SB Gen/FD Gen/Staff – Low

SB CGA – Medium

SB NRO, NRE/FD NRO, NRE/FCNR – High

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Suggested Risk Categorization under Account Status are as follows :

Active/Regular – low

Inoperative/dormant – Medium

Blocked/Unclaimed – High

Suggested Risk Categorization under Account Vintage are as follows :

Less than six months old – High

Six months to less than one year – Medium

One year and above – Low

(Account Vintage refers to age of the account).

Total risk will be assigned based on the highest risk carried by any of the
following 10 parameters –

(1) Customer Type,

(2) Customer Business/Profession,

(3) Account Status,

(4) Account Vintage,

(5) Product Code,

(6) Country of Residence,

(7) Economic Profile of Account Holder

(8) Regulatory guidelines such as PEP, Defaulters, Fraudsters

(9) Suspicious Transaction Report (STR) filed for the customer and (

10) AML alerts.

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Low Risk Customers also known as Level 1 customers.

Medium Risk Customers also known as Level 2 customers.

High Risk Customers also known as Level 3 customers.

Rating based on the deposits/account balance : (applicable to accounts which

have completed 6 months)

Account Types High Medium Low

Only SB Rs 2 lacs - & above Rs 1 lakh- & above Less than Rs 1

but less than Rs 2 lakh.
lacs.

Only Current Rs 5 lacs - & above Rs 2 lakh- & above Less than Rs 2
but less than Rs 5 lakh.
lacs.

Only Term Rs 10 lacs - & Rs 5 lakh- & above Less than Rs 5

Deposits above but less than Rs 10 lakh.
lacs.

(for current/SB accounts balance amount and for Term deposits, principle amount
shall be taken for consideration on the date of review).

Objective of PMLA ( Prevention of Money Laundering Act, 2002) - to prevent

money-laundering and to provide for confiscation of property derived from
money-laundering.

The Act and Rules notified there under impose obligation on banking
companies, financial institutions and intermediaries to verify identity of clients,
maintain records and furnish information in prescribed form to Financial
Intelligence Unit – India (FIU-IND).

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Non-Profit Organisations (NPOs)/ Non-Government Organisations (NGOs)
promoted by the United Nations or its agencies, and such international/
multilateral organizations of repute, may be classified as low risk customers.

The following customers are classified as Medium Risk Customers:

Gas Dealers // Car/boat/plane dealers // Electronics (wholesale) // Travel

agency // Telemarketers // Telecommunication service providers // Pawnshops //
Auctioneers // Restaurants, Retail shops, Movie Theatres, etc.// Sole practitioners
// Notaries // Accountants // Blind // Purdanashin.

Blind Person (customer) to be classified as Medium Risk Customer.

Purdanashin Customer to be classified as Medium Risk Customer.

Gas Dealers to be classified as Medium Risk Customer.

Travel Agency to be classified as Medium Risk Customer.

Notaries to be classified as Medium Risk Customer.

Accountants to be classified as Medium Risk Customer.

Retail Shops to be classified as Medium Risk Customer.

Movie Theatres to be classified as Medium Risk Customer.

Restaurants to be classified as Medium Risk Customer.

The following customers are classified as High Risk Customers:

Trusts, charities, NGOs and organizations receiving donations to be classified as

High Risk Customer.

Companies having close family shareholding or beneficial ownership to be

classified as High Risk Customer.

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Firms with sleeping partners to be classified as High Risk Customer.

Accounts under Foreign Contribution Regulation Act to be classified as High Risk

Customer.

Politically Exposed Persons (PEPs) to be classified as High Risk Customer.

Customers who are close relatives of PEPs and accounts of which a PEP is the
ultimate beneficial owner to be classified as High Risk Customer.

Those with dubious reputation as per public information available to be

classified as High Risk Customer.

Accounts of non-face-to-face customers to be classified as High Risk

Customer.

High Net worth Individuals to be classified as High Risk Customer.

Non-Resident customers to be classified as High Risk Customer.

Accounts of Cash intensive businesses such as accounts of bullion dealers &

jewellers to be classified as High Risk Customer.

Overall Risk grade for the customer will be the Highest Risk grade among the
chosen parameters.

A low risk category may be classified otherwise based on following illustrative list
of parameters considered as "High Risk" such as:

a) Unusual transaction/behaviour (Detailed in the KYC/AML/CFT policy)

b) Suspicious Transaction Reports (STR) for customer

c) Cash Transaction Report (CTR) for customer

d) Frequent Cheque returns etc.

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Review of Customer Risk Categorization - to be carried out not less than once
in six months i.e.as on 15th of May and November every year.

KYC exercise should be done at least every two (2) years for High Risk
customers.

KYC exercise should be done at least every eight (8) years for Medium Risk
customers.

KYC exercise should be done at least every ten (10) years for Low Risk
customers.

Customer Identification Procedure means undertaking client Due Diligence

(CDD) measures based on the Risk profile, while commencing an account based
relationship (whether regular or occasional).

Customer identification procedure to be carried out – While selling bank's own

product for more than Rs 50000/-.

Customer identification procedure to be carried out - During periodic review of

KYC.

Accept only the Officially Valid Documents (OVD) while opening of accounts/
periodical KYC up-dation.

A document is deemed to be an “Officially Valid Document” even if there is a

change in the name subsequent to its issuance, provided it is supported by a
marriage certificate issued by State Government or a Gazette notification.

Passport is a OVD in case of Individual Customer.

Driving License is a OVD in case of Individual Customer.

Aadhaar card or Proof of possession of Aadhaar number is a OVD in case of

Individual Customer.

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Voter Identity Card issued by Election Commission of India is a OVD in case of
Individual Customer.

Job Card issued by NREGA duly signed by an officer of the State Government is a
OVD in case of Individual Customer.

Letter issued by the National Population Register containing details of name and
address is a OVD in case of Individual Customer.

Certificate of incorporation is a OVD in case of Company.

Memorandum and Articles of Association is a OVD in case of Company.

Do not insist on a Company's Common Seal, unless there is a provision to that

effect in their Memorandum and Articles of Association.

Parameters for defining High Net worth Individuals - Customers with any of
the following:

1) Average balance of Rs. 100 lakh and above in all (SB+CA+TD) deposit
accounts.

2) Enjoying Fund based limits/term loans exceeding Rs. 100 lakh.

Registration certificate is a OVD in case of Partnership Firms.

Partnership deed is a OVD in case of Partnership Firms.

PAN Card of the Firm is a OVD in case of Partnership Firms.

Registration certificate is a OVD in case of Trusts and Foundations.

Trust deed is a OVD in case of Trusts and Foundations.

PAN number of the Trust is a OVD in case of Trusts and Foundations.

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For proprietary concerns, in addition to the OVD applicable to the individual
(proprietor), any two documents in the name of the proprietary concern are
required to be submitted as Activity Proof.

Though the default rule is that any two documents, mentioned above, should be
provided as activity proof by a proprietary concern, in cases where the banks are
satisfied that it is not possible to furnish two such documents, they would have
the discretion to accept only one document as activity proof.

Introduction is not mandatory for all the accounts, including those of legal
entities.

Aadhaar is not mandatory for opening SB account for Individual.

We may accept e- KYC service as a valid process for KYC verification.

Fresh photographs will be required to be obtained from minor customer on

becoming major.

In case a customer categorised as low risk is unable to submit the KYC

documents due to genuine reasons, she/he may submit the documents to
the Bank within a period of six months from the date of opening account.

Foreign students have been allowed a time of one month for furnishing the proof
of local address.

To open account for close relatives of low risk customers e.g. wife, son,
daughter and parents etc. who live with their husband, father / mother and
son, the utility bills which are in the name of close relatives can be accepted.

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Customers' name should be screened with UN list of terrorist individuals/ entities
before creation of new customer ID. If any resemblance is observed, transactions
are to be verified in such accounts and report those accounts to RBI/FIU-IND.

For opening of accounts of juridical persons, such as Government or its

departments, Societies, Universities and Local Bodies like Village Panchayats, a
certified copy of the following documents shall be obtained:

a) Document showing name of the person authorised to act on behalf of

the entity;

b) Officially Valid Documents for proof of identity and address in respect of

the person holding a power of attorney to transact on its behalf and

c) Such documents as may be required by the Bank to establish the legal

existence of such an entity/ juridical person.

Additional document pertaining to the nature of occupation/activity and

financial status (income) of the customer while opening of accounts, along
with OVDs and photographs should be obtained. If it is not possible to
provide a document related to occupations, such as, unemployed, housewife,
labour, street vendor, etc., the same need not be insisted.

In case proof of address furnished by the customer is not the local address or the
address where the customer is currently residing, the branch may take a
declaration of the local address .

Foreign remittance exceeding USD 1000 is not allowed into the accounts of
foreign students, within the period of first thirty days, when local address is not
verified.

If the address of the customer mentioned as per proof of address undergoes a

change, fresh proof of address may be submitted to the branch within a period of
six months.

PAN or Form 60 are mandatory for opening of accounts other than “small
accounts”.

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For Low Risk category, KYC requirement of proper identification and
verification on of proof of address would suffice.

For medium risk category, higher due diligence is required, which includes
customer's background, nature and location of activity, country of origin, source
of funds and their client's profile etc., besides identification.

High Risk category accounts require higher due diligence as per medium risk
category and such accounts require enhanced monitoring on an on-going basis.

Threshold limits are to be fixed as per limits mentioned by customer at the time of
opening the account and review the threshold limits once in 6 months.

Fresh proofs of identity and address need not be obtained at the time of periodic
up-dation from those customers who are categorised as 'low risk', in case of no
change in status with respect to their identities and addresses.

A self-certification by the customer to that effect should suffice in such cases

In case of change of address of low risk customers, they could merely

forward a certified copy of the document (proof of address) by mail/post,
etc. Branches need not insist on physical presence of such low risk customer at the
time of periodic up-dation.

If an existing KYC compliant customer of the bank desires to open another

account in the bank, there should be no need for submission of fresh proof of
identity and/or proof of address for the purpose.

Banks should impose partial freezing on KYC non-compliant accounts in a phased

manner by giving due notice.

Due diligence to be observed wherever notices are returned undelivered.

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The option of partial freezing is to be exercised after giving due notice of three
months initially to the customers to comply with KYC requirements and followed
by a reminder for further period of three months. Thereafter, partial freezing
should be imposed by allowing all credits and is allowing all debits with the
freedom to close the accounts.

If the accounts are still KYC non-compliant after six months of imposing
initial partial freezing, branches should disallow all debits and credits from/to
the accounts, rendering them inoperative.

Further, it would always be open to the branches to close the account of such
customers.

Non-account based customer, that is a walk-in customer, where the amount of

transaction is equal to or exceeds rupees fifty thousand, whether conducted as a
single transaction or several transactions that appear to be connected, the
customer's identity and address shall be verified.

A juridical person has been defined as an Entity, as a firm, that is not a single
natural person, as a human being, authorized by law with dues and rights,
recognized as a legal authority having a distinct identity, a legal personality

A juridical person also known as artificial person, juridical entity, jurisdiction

person, or legal person.

Walk-in customer is also known as Non-account Based Customer.

"Beneficial Owner” is the natural person who ultimately owns or controls a client.
and/or the person on whose behalf the transaction is being conducted, and
includes a person who exercises ultimate effective control over a juridical person.

In case of Companies,(Beneficial Owner”) “Controlling ownership interest” means

ownership of / entitlement to more than 25 per cent of the shares or capital or
profits of the company.

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In case of Partnership firm, (Beneficial Owner”)“Controlling ownership interest”
means ownership of / entitlement to more than 15% of the shares or capital or
profits of the Partnership Firm.

In case of an Unincorporated Association or Body of Individuals, (Beneficial

owner”) “Controlling ownership interest” means ownership of / entitlement to
more than 15% of the property or capital or profits of such Association or Body
of Individuals.

In other cases, (Beneficial Owner”)“Controlling ownership interest” is relevant

natural person who holds the position of senior managing official.

Politically exposed persons (PEPs) are individuals who are or have been entrusted
with prominent Public functions in a Foreign Country, e.g., Heads of States or of
Governments, Senior Politicians, Senior Government /judicial / Military Officers,
Senior Executives of State-owned Corporations, important Political Party Officials,
etc.

Persons of Foreign/Diplomatic Missions, located in India, also qualify as PEPs.

Persons holding prominent positions in multilateral agencies such as the United

Nations, World Bank etc., can also be construed as PEPs.

In the event of an existing customer or relatives of an existing customer

subsequently becoming a PEP, the decision to continue the business relationship
has to be taken by Executive.

Penalty of not less than rupees ten thousand extended upto one lakh rupees may
be levied by RBI on any of the employees for non-compliance of KYC/ AML / CFT
guidelines.

AML stands for Anti Money Laundering.

CFT stands for Combating Financial Terrorism.

Account of non face to face customers : This is opening of account without the
customer coming to the branch.

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In case of Non Face to Face Customer Account First credit should be by way of
account credit.

In case of Non Face to Face Customer Account, Documents should be

certified /or/attested.

Transactions using forged or counterfeit Indian Currency notes to be

reported under Counterfeit Currency Report (CCR).

Attempted transactions by customers ( where counterfeit or forged currency are

used) are to be reported under STR even if the transactions are not completed by
customers irrespective of the amount.

Records of transactions to be maintained for at least ten years from the date of
transaction.

Records pertaining to identification of the customer and his address to be

preserved for at least ten years after the business relationship is ended.

Accounts of Trusts/Charities/Organisations, receiving foreign funding should be

opened after permission of Ministry of Home Affairs.

Accounts of Trusts/Charities/Organisations, receiving foreign funding are treated

as High Risk.

Branches may transfer existing accounts at the transferor branch to the

transferee branch without insisting on fresh proof of address and on the
basis of a self-declaration from the account holder about his/her current
address, subject to submitting proof of address within a period of 6 months.

KYC once done by one branch of a Bank should be valid for transfer of the
account within the Bank as long as full KYC has been complied for the
concerned account.

“In-Person verification” means customer to sign in the presence of Bank official

and the Bank Official has to affix signature and Staff No.

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eKYC : Under eKYC, the customer need not bring any document for opening of an
account. He/she has to inform his/her Aadhaar number only. He/she has to fill up
the Account opening Form and give a consent letter to undergo e-KYC process
and provide his/her fingerprint on the biometric reader.

Ensure e-KYC authentication of Aadhaar through only either Biometric

authentication or OTP based authentication facility only.

All cross border wire transfer of the value of more than Rs 5 lakhs are to be
reported to Financial Intelligent Unit (FIU-IND) on monthly basis.

Records of ALM to be preserved for 10 years.

Suspicious Transaction Report ( STR) - A transaction may be of suspicious nature

irrespective of the amount involved.

There are no restrictions on operations in the accounts where an STR has been
made.

There is no periodicity for reporting suspicious transactions.

FATF stands for Financial Action Task Force.

Correspondent Banking is the provision of banking services by one bank (the

“correspondent bank”) to another bank (the “respondent bank”).

Banks should not enter into a correspondent relationship with a “shell bank”.

Shell Bank is bank which is incorporated in a country where it has no physical

presence and is not affiliated to any regulated financial group.

UAPA stands for Unlawful Activities (Prevention) Act, 1967.

The United Nations periodically circulates the following two lists of

individuals and entities suspected of having terrorist links, and as approved
by its Security Council (UNSC) - (a) The “ISIL (Da’esh) &Al-Qaida Sanctions List” -
associated with the Al-Qaida. and (b) The “1988 Sanctions List” - associated with
the Taliban.

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UNSCRs stand for The United Nations Security Council Resolutions.

In case of Accounts of Married Women - a document shall be deemed to an -

OVD even if there is a change in the name subsequent to its issuance, provided it
is supported by a marriage certificate issued by the State Government or a
Gazette notification, indicating such a change of name.

Accordingly, accept a copy of marriage certificate issued by the State

Government or Gazette notification indicating change in name, together with a
certified copy of the “OVD” in the existing name of the person while establishing
an account based relationship or while undergoing periodic up-dation exercise.

Small Accounts: If a person who wants to open an account and is not able to
produce any of the OVDs or the documents applicable in respect of simplified
procedure, bank shall open a Small Account.

BCSBI stands for Banking Codes And Standard Board Of India .

BCSBI is a registered society formed on the recommendations of committee on

Procedures and Performance Audit on Public Services by S S Tarapore Committee.

BCSBI is Voluntary Code,

Demographic information includes information relating to the name, date of

birth, address and other relevant information of an individual, but shall not
include race, religion, caste, tribe, ethnicity, language, records of entitlement,
income or medical history. (defined in the Aadhaar Act)

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“Regulated Entities” (REs) means

a) All Banks

b) All India Financial Institutions (AIFIs)

c) All Non-Banking Finance Companies (NBFC)s, Miscellaneous Non-

Banking Companies (MNBCs) and Residuary Non-Banking Companies
(RNBCs).

d) All Payment System Providers (PSPs)/System Participants (SPs) and

Prepaid Payment Instrument Issuers (PPI Issuers)

e) All authorised persons (APs) including those agents of Money Transfer

Service Scheme (MTSS), regulated by the Regulator.

“FATCA” means Foreign Account Tax Compliance Act of the United States of
America (USA) which, inter alia, requires foreign financial institutions to report
about financial accounts held by U.S. taxpayers or foreign entities in which U.S.
taxpayers hold a substantial ownership interest.

“IGA” means Inter Governmental Agreement between the Governments of India

and the USA to improve international tax compliance and to implement FATCA of
the USA.

“KYC Templates” means templates prepared to facilitate collating and reporting

the KYC data to the CKYCR, for individuals and legal entities.

CIDR stands for Central Identities Data Repository is defined in the Aadhaar Act,
means a centralised database containing all Aadhaar numbers issued along with
the corresponding demographic information and biometric information of such
individuals and other information related thereto.

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“Central KYC Records Registry” (CKYCR) means an entity established to receive,
store, safeguard and retrieve the KYC records in digital form of a customer.

Biometric information”, as defined in the Aadhaar Act, means photograph,

finger print, Iris scan, or such other biological attributes of an individual as may be
specified by Aadhaar (authentication) regulations.

”Enrolment number” or “Enrolment ID” is a 28 digit Enrolment

Identification Number allocated to residents at the time of enrolment of
Aadhaar.

“E-KYC authentication facility”, means a type of authentication facility in which

the biometric information and/or OTP and Aadhaar number securely submitted
with the consent of the Aadhaar number holder through a requesting entity, is
matched against the data available in the CIDR, and the Authority returns a
digitally signed response containing e-KYC data along with other technical details
related to the authentication transaction.

“Identity information”, in respect of an individual, includes individual’s Aadhaar

number, biometric information and demographic information.

“Resident”, as defined in Aadhaar Act, means an individual who has resided in

India for a period or periods amounting in all to one hundred and eighty-two
days or more in the twelve months immediately preceding the date of application
for enrolment for Aadhaar.

“Yes/No authentication facility”, as defined in Aadhaar Act, means a type of

authentication facility in which the identity information and Aadhaar number
securely submitted with the consent of the Aadhaar number holder through a
requesting entity, is then matched against the data available in the CIDR, and the
Authority responds with a digitally signed response containing “Yes” or “No”,
along with other technical details related to the authentication transaction, but
no identity information.

Page 24 of 77
“Common Reporting Standards” (CRS) means reporting standards set for
implementation of multilateral agreement signed to automatically exchange
information.

“Walk-in Customer” means a person who does not have an account based
relationship with the RE, but undertakes transactions with the RE.

“Customer Due Diligence (CDD)” means identifying and verifying the customer
and the beneficial owner.

“Customer identification” means undertaking the process of CDD.

“Non-face-to-face customers” means customers who open accounts without

visiting the branch/offices of the REs or meeting the officials.

“On-going Due Diligence” means regular monitoring of transactions in accounts

to ensure that they are consistent with the customers’ profile and source of funds.

“Periodic Up-dation” means steps taken to ensure that documents, data or

information collected under the CDD process is kept up-to-date and
relevant by undertaking reviews of existing records at periodicity prescribed by
the Reserve Bank.

“Wire Transfer” means a transaction carried out, directly or through a chain of

transfers, 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.

When the originator bank and the beneficiary bank is the same person or
different person located in the same country, such a wire-transfer is a
Domestic Wire Transfer,

If the ‘originator bank’ or ‘beneficiary bank’ is located in different countries such a

wire-transfer is Cross-border Wire Transfer.

Aadhar number shall not be sought from individuals who are not ‘residents’.

Page 25 of 77
In case an individual customer who does not have Aadhaar/enrolment
number and PAN and desires to open a bank account, banks shall open a
‘Small Account’.

The bank shall obtain a self-attested photograph from the customer while
opening Small Account.

While opening Small Accounts, the designated officer of the bank certifies under
his signature that the person opening the account has affixed his signature or
thumb impression in his presence.

Small Accounts are opened only at Core Banking Solution (CBS) linked branches
or in a branch where it is possible to manually monitor and ensure that foreign
remittances are not credited to the account.

In case of Small Accounts, ensure that the stipulated monthly and annual limits
on aggregate of transactions and balance requirements in such accounts are not
breached, before a transaction is allowed to take place.

The Small Account shall remain operational initially for a period of twelve months
which can be extended for a further period of twelve months, provided the
account holder applies and furnishes evidence of having applied for any of the
OVDs during the first twelve months of the opening of the said account.

The entire relaxation provisions shall be reviewed after twenty four months

The Small Account shall be monitored and when there is suspicion of money
laundering or financing of terrorism activities or other high risk scenarios, the
identity of the customer shall be established through the production of an OVD
and Aadhaar Number or where an Aadhaar number has not been assigned to the
customer through the production of proof of application towards enrolment for
Aadhaar which is not more than six months old, along with an OVD.

Page 26 of 77
In Small Accounts , Foreign remittance shall not be allowed to be credited into
the account unless the identity of the customer is fully established through the
production of an OVD and Aadhaar Number or the enrolment number which is
not more than six months old, where the person is eligible to enrol for Aadhaar
number has not been assigned an Aadhaar number.

High risk accounts have to be subjected to more intensified monitoring.

Simplified KYC norms for Foreign Portfolio Investors (FPIs)

Accounts of FPIs which are eligible/ registered as per SEBI guidelines, for the
purpose of investment under Portfolio Investment Scheme (PIS), shall be
opened by accepting KYC documents specified, subject to Income Tax
(FATCA/CRS) Rules.

Provided that banks shall obtain undertaking from FPIs or the Global
Custodian acting on behalf of the FPI that as and when required, the
exempted documents specified will be submitted.

Government of India has authorised the Central Registry of Securitisation Asset

Reconstruction and Security Interest of India (CERSAI), to act as, and to perform
the functions of the CKYCR.

Payment of cheques/drafts/pay orders/banker’s cheques, if they are

presented beyond the period of three months from the date of such
instruments, shall not be made.

“Money Mules” are used to launder the proceeds of fraud schemes (e.g.,
phishing and identity theft) by criminals who gain illegal access to deposit
accounts by recruiting third parties which act as “money mules.”

If it is established that an account opened and operated is that of a Money Mule,

it shall be deemed that the bank has not complied with these directions.

Account payee cheques for any person other than the payee constituent shall not
be collected.

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Banks shall, at their option, collect account payee cheques drawn for an
amount not exceeding rupees fifty thousand to the account of their
customers who are co-operative credit societies, provided the payees of such
cheques are the constituents of such co-operative credit societies.

Any remittance of funds by way of demand draft, mail/telegraphic

transfer/NEFT/IMPS or any other mode and issue of travellers’ cheques for
value of rupees fifty thousand and above shall be effected by debit to the
customer’s account or against cheques and not against cash payment.

The name of the purchaser shall be incorporated on the face of the demand draft,
pay order, banker’s cheque, etc., by the issuing bank.

@@@

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 Part 2

Multiple Choice
Questions & Answers
Answers are furnished at the end.

Page 29 of 77
01. What is KYC?

(a) Know Your Client (b) Know Your Company

(c) Know Your Customer (d) None of the above.

02. How many categories of risk are there under KYC?

(a) 1 (b) 2 (c) 3 (d) 4 (e) 5

03. Why KYC / AML guidelines required?

(a) To Prevent banks from being used intentionally or unintentionally by criminal

elements for money laundering.

(b) To prevent banks from being used intentionally or unintentionally by criminal

elements for terrorist financing activities.

(c) It enables banks to understand that customers and their financial dealings
better.

(d) All of the above

04. Which are the entities licensed under section 22 of Banking Regulation act to
which provisions of KYC policy of RBI will be applicable?

(a) Scheduled Commercial bank(SCB),

b) Regional Rural Banks (RRBs), Local area Bank(LABs)

(c) Primary (Urban) Co-operative banks (UCBs) and State & Central Cooperative
banks (SICBs/ CCBs)

(d) All of the above

Page 30 of 77
05. Which among the following is not a category of risk under KYC?

(a) Low Risk

(b) Medium Risk
(c) High Risk
(d) Normal Risk

06. KYC policy of the banks as per RBI directives should provide for

(1) Customer acceptance policy (2) customer identification procedure

(3) monitoring of transactions (4) risk management

(a) 1, 2 and 3 only (b) 1, 3 and 4 only (c) 2, 3 and 4 only (d) 1 to 4 all

07. Customer acceptance policy of the bank is framed so as to take care of which
are all aspects?

(a) No account is opened without applying appropriate customer due diligence

(b) No accounts opened in the name in anonymous/ fictitious /benami names

(c) No transaction or account based relationship is undertaken without following

the Customer Due Diligence procedure

(d) All specified mandatory information to be compulsorily to be obtained while

opening the account and during the periodic up-dations and optional/additional
information after opening the account with the consent of customer

(e) All of the above

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08. Which among the following is not an Officially Valid Document?

(a) Pass Port (b) Electricity Bill (c) Driving License (d) Voters ID Card.

09. Officially Valid Document for Limited purpose of proof of address are

(a) Utility Bill not more than 2 months old

(b) Property or Municipal tax receipt
(c) Pension / Family pension payment order issued to retired employees if it
contains address

(d) All the above

10. In case the address furnished in the proof of address undergoes a change,
what does the KYC policy stipulates?

(a) Customer to submit any Official valid documents for limited purpose of proof
of address.

(b) Customer shall submit any other officially valid documents for current address
with in3 months.

(c) Both of the above

(d) None of the above

11. To receive any benefit or subsidy notified under Section 7 of Aadhaar Act
which of the following is correct.

(a) Submission & Seeding of Aadhar Number to Account is Mandatory

(b) Any of the Official Valid Document can be submitted
(c) Submission of PAN is Mandatory.
(d) No Official Valid Document need to submit.

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12. What are the documents to be submitted by an individual for establishing an
account based relationship with the bank as per the guidelines?

(a) Proof of possession of Aadhaar Number, PAN Card / Form60

(b) Passport, Driving License, Voters ID issued by Election Commission
(c) Photograph
(d) Any of a or b and c

13. Which are the simplified documents acceptable in the case of Low Risk
customers for Customer identity?

(a) Identity card with applicant’s Photograph issued by Central/ State Government
Departments, Statutory/Regulatory Authorities, Public Sector Undertakings,
Scheduled Commercial Banks, and Public Financial Institutions or

(b) a letter issued by a Gazetted officer, with a duly attested photograph of the
person.

(c) a & b

(d) Any of the above

14. Which among the following cannot be accepted both as Identity and Address
Proof?

(a) PAN Card (b) Pass Port

(c) Driving License (d) Voter’s ID Card.

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15. Who is authorized to act as and perform the functions of CKYCR?

(a) Central Registry of Securitization Asset Reconstruction and Securities of

India(CERSAI)

(b) Department of CKYCR, Finance Ministry

(c) UIDAI
(d) RBI

16. What are the functions of CKYCR?

(a) Receiving, Storing, Safe guarding and retrieving KYC records in digital form
(b) Verifying the KYC compliance by the bank
(c) Issuing Aadhar
(d) None of the above

17. As per PML (Maintenance of Records) Rules 2005, bank shall file copy of the
client’s KYC records with the CKYCR within ……… days after commencement of an
account based relationship with a client.

(a) T +5 days (b) T+ 9 days (c) T+15 days (d) None of the above

18. Documents to be scanned and uploaded for CKYCR

(a) ID proof & Address

(b) Proof of Identity, Proof of Address, Cropped up Signature and Photograph
(c) Signature and Photograph
(d) Application

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19. What is the ceiling for acceptance of cash for the purchase of DD?

(a) Rs.50000 (b) Less than Rs.50000

(c) Rs.20000 (d) Rs.10000

20. Introduction of customer to bank is …………………. for opening accounts under

PML Act and Rules or the RBI‟s extant instructions

(a) Not mandatory (b) Mandatory

(c) Manager Discretion (d) None of the above.

21. Before opening the account branches have to verify the prospective account
holder’s details in CKYC package under the option……………………………

(a) Customer Unique Identification Code (b) CKYC Management

(c) Aadhaar Verification (d) Account opening

22. Which of the following is correct for CKYC data uploading?

(a) Any one of father’s name/ spouse’s name or mother’s name only is mandatory
(b)Father’s name is mandatory if PAN is not submitted
(c) Maiden name field is optional
(d)All the above is correct

23. Who is an HNI?

(a) Hindu Non-Indian (b) Hindu North Indian

(c) Hindustan Nuclear Industry (d) High Net-Worth Individual

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24. KYC updating is to be done at which branch?

(a) Only in the base branch (b) Any of the branches of our Bank
(c) Aadhar centre (d) Branch where account was opened

25. A lady who is belonging to Mumbai shifted to Delhi on marriage approaches

the bank for opening an account. Bank finds that a customer’s name differs from
the OVD submitted for opening. Which of the document bank can accept to open
the account?

(a) A copy of marriage certificate issued by the State Government

(b) Gazette notification indicating the change in name
(c) Copy of OVD stipulated
(d) a & c or b & c

26. For Low Risk customers, KYC up-dation is to be done once in years?

(a) 3 (b) 5 (c) 8 (d) 10

27. For Medium Risk customers KYC up-dation is to be done once in_____years?

(a) 3 (b) 5 (c) 8 (d) 10

28. For High Risk customers KYC up-dation is to be done once in____years?

(a) 3 (b) 5 (c) 8 (d) 2

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29. What is the maximum validity period for operations permissible in small
account?

(a) 24 months which can be extended for a period of 6months

(b) 12 months which can be extended by another 12 months provided the

account holder applies and furnishes evidence of having applied for any OVD

(c) Maximum 12 months within which period the customer has to submit the
OVDs.

(d) None of the above.

30. What is UIDAI?

(a) Union Industries Development Authority of India

(b) United Industries Development Authority of India
(c) Unique Identification Authority of India
(d) United India Draught & Accident Insurance

31. What is CTR?

(a) Central Tax Return (b) Cash Transaction Report

(c) Cheque Truncation Return (d) Cheque Transfer Report

32. What STR?

(a) Suspicious Transaction Report (b) Statutory Tax Return

(c) Sundry Transaction Report (d) Suspense Transaction Report

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33. For opening of Partnership firms, which are the following documents can be
obtained?

(a) Registration certificate if Registered (b) Partnership Deed

(c) PAN number of the firm (d) All the above

34. To open Trust account, which of the following documents to be obtained?

(a) License from RBI (b) Registration certificate (if registered) &Trust Deed
(c) PAN of the Trust (d) b & c

35. What is FIU-IND?

(a) Finance Insurance United India (b) France Italy USA &India
(c) Financial Inclusion Undertaken in India (d) Financial Intelligence Unit –INDIA

36. In respect of Trust account, which of the following documents are stipulated
for Customer Due Diligence of the person holding an attorney to transaction its
behalf?

(a) One copy of OVD containing of Identity & Address of Authorized person
(b) One Recent photograph of Authorized person
(c) Form 60 or PAN number of the authorized person
(d) All of the above

Page 38 of 77
37. Documents to be obtained from any juridical persons such as Government or
its departments, Societies, Universities etc. as per KYC policy?

(a) Document showing name of the person authorized to act on behalf of the
entity

(b) OVD and PAN or Form 60 of the authorized person

(c) Documents required to establish the legal existence of such entity
(d) All of the above

38. When is customer’s day is observed ?

(a) 2nd October every year (b) 15th of Every Month

(c) 2nd Wednesday of every month (d) Last Friday of every month

39. What is AML?

(a) Automobile Maintenance Loan (b) Anti-Money lending

(c) Anti-Money Laundering (d) Amul Milk Limited

40. Which account can be opened in Bank with simplified KYC norms

(a) Fixed Deposit (b) Recurring Deposit

(c) NRE (d) Basic Savings Bank Deposit Account

41. While opening the account branches have to verify the name of the proposed
account holder with terrorist list uploaded in the system. who is bringing out the
list?

(a) List approved and circulated by United National Security Council.

(b) FIU-IND (c) RBI (d) None of the above

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42. What is the periodicity for review of risk categorization of accounts and in
which month it is being done?

(a) At least once in six months as on 15th of May &November

(b) At least once in 24 months from the date of opening the account/ last Review

(c) At least once in 12 months from the date of opening the account/ last review

(d) Bi-Monthly, Feb, Apr, June, Aug, Oct, Dec

43. In case of Joint Accounts, whose KYC documents are to be obtained?

(a) First named person (b) Authorized signatory

(c) All the joint account holders (d) Anyone

44. In the case of low risk customers, which of the following statements are true?

(a) Fresh proof of identity and address shall not be sought when there is no
change in status of identity and address, as per the self-certification submitted.

(b) A certified copy of proof of address forwarded through mail/post shall be

acceptable, in case of change of address.

(c) Physical presence of low risk customer shall not be insisted upon.

(d) All of the above

45. During periodic up-dation, fresh photograph would be obtained from

customer for whom the account was opened when they were , on their becoming

(a) Minor becoming a major (b) NRI, Domestic

(c) Student, Employee (d) General to Senior citizen

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46. All transactions involving receipts by these Non Profit Organisations of value
more than Rs…… or its equivalent in foreign currency is to be reported to FIU-IND
centrally from Head Office

(a) 10 lacs (b) 5 lacs (c) 20 lacs (d) 25 lacs

47. Who is an HNI as per KYC guidelines?

(a) A person with an average balance of Rs.2lakhs & above in SB/Rs.5 Lakhs &
above in CA/ Rs.10 Lakhs & above in Term Deposit

(b) Enjoying fund based limit of Rs.30 Lacs &above

(c) Average balance of Rs.100 Lacs in all accounts (CA+SB+TD) and enjoying Fund
based limit or Term loan of Rs.100 Lacs

(d) Average balance of Rs.100 Lacs in all accounts(CA+SB+TD) or enjoying Fund

based limit or Term loan of Rs.100 Lacs

48. What are the enhanced due diligence to be exercised in the accounts of non-
face-to- face customers?

(a) Certification of all documents presented

(b) Calling for additional documents

(c) First payment to be effected through the customer’s KYC compliant account
with another bank.

(d) All of the above

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49. As per the KYC policy enhanced due diligence to be applied in the case of

(a) Non face- to-Face customers (b) Politically exposed persons(PEPs)

(c) a & b (d) Members of SHGs

50. Politically exposed persons (PEP’s), referred under KYC Policy, are individuals
who have been entrusted with prominent public functions in

(a) A foreign country (b) Within India

(c) Anywhere in the world (d) Indian Govt official on foreign tour

51. PEP’s include

(a) Senior politician

(b) Heads of states/Governments, senior executives of state-owned corporations

(c) Senior government/judicial/military officials

(d) All of the above

52. If account is opened for a low risk customer without proper due diligence, in
what time the customer verification should be completed

(a) 15 days (b) One month (c) 3 months (d) 6 months

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53. In respect of Self-Help Groups (SHGs), which of the following statements are
correct, as per KYC guidelines?

(a) KYC verification of all the members of SHG to be carried out while opening the
SB account.

(b) KYC verification of all the office bearers to be taken.

(c) KYC verification of the members to be taken, at the time of credit linking of
SHGs.

(d) b & c.

54. What type of accounts can be opened for foreign students studying in India?

(a) NRO account

(b) NRE account
(c) BSBD account
(d) Any of the above.

55. What are the documents to be verified for a foreign national student?

(a) On the basis of passport with visa and immigration endorsement, which bears
the proof of identity and address in the home country;

(b) The admission letter from an educational institute in India; and photographs.

(c) In the case of Pakistani nationality, approval letter from Reserve Bank of India
is needed for opening the account.

(d) All of the above

Page 43 of 77
56. What is the provision available to the bank under KYC, if the foreign student
studying in India is unable to provide the local address, at the time of opening the
accounts?

(a) To obtain the declaration from the student for providing the local address
within a period of 30days.

(b) Pending verification of address, permit remittance to the account not

exceeding USD1000,

(c) subject to a cap of Rs. 50,000/- on aggregate during the 30 days period.

(d) She/he is a low risk customer, hence six months’ time may be permitted.

(e) Bank can proceed as per ‘a’ and ‘b’.

57. Which of the following statement is correct in respect of STR filed accounts?

(a) On filing the STR operations in the account to be stopped.

(b) Due notice to be sent to the account holder regarding filing of STR.

(c) If the party does not submit satisfactory clarification regarding suspicious
transactions within a period of three months branch has to stop operations in the
account.

(d) Bank should not put any restriction on operations in the account and the bank
has to keep the fact of filing of STR strictly confidential.

58. While opening the account branches have to verify the name of the proposed
account holder with terrorist list uploaded in the system. The exercise is put in
place in compliance of which act?

(a) Section 51A of the Unlawful Activities (Prevention) UAPA Act 1967,
(b) BR Act (c) RBI (d) None of the above

Page 44 of 77
59. Who /what is Money mules?

(a) Money Exchangers

(b) It is a sort of payment bank dealing purely in currency.
(c) Coin dispensers
(d) Accounts of third parties recruited illegally, accessed by criminal, to launder
the proceeds of phishing and identity theft

60. What is UCIC?

(a) Union of Credit Information Companies

(b) Unique Corporate Identification Code
(c) Unique Customer Identification Code
(d) Unlimited Connections International Corporation

61. Which of the following group of customers, will be categorized as a low risk
customer, as per Provisions of KYC

(a) Govt. Dept. A joint stock company (b) Partnership firm, a salaried employee
(c) A salaried employee, govt. dept. (d) All the options are correct

62. In cases where banks are acting as agents for selling third party products,
bank has to verify the identity of the walk-in customer for transaction of
above Rs. …

(a) Rs.1,00,000/- (b) Rs. 5,00,000/-

(c) Rs.2,00,000/- (d) Rs. 50,000/-

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63. Is the bank responsible for filing CTR/STR, in respect to transactions relating to
third party products with customers?

(a) The responsibility lies with the owner of the product.

(b) The bank is responsible for transactions of their account holders only.
(c) With respect to transactions, bank has to file the reports of the customers
including walk-in customers.

(d) None of the above.

64. Which is the Central Govt. Agency, which receives, analyses, processes and
disseminates the information regarding money laundering to appropriate national
and international authority?

(a) RBI (b) Financial Intelligence Unit-India

(c) RAW (d) Central Intelligence Bureau

65. In case of low risk customers full KYC is required to be done by the bank:

(a) Not less than 2 years (b) Not less than 5 years
(c) Not less than 10 years (d) Not required

66. Risk category review under KYC has to be undertaken by banks:

(a) Not less than once in 2 years

(b) Not less than once in 1 year

(c) Not less than once in 6 months
(d) Not less than once in 3 months

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67. In case of high risk customers, full KYC is required to be done by the bank:

(a) Not less than 5 years (b) Not less than 3 years
(c) Not less than 2 years (d) Not less than 1 year

68. KYC Templates are meant for what purpose?

(a) Templates prepared to facilitate collating and reporting the KYC data to the
CKYCR

(b) There are two templates one for individual and one for Legal entities

(c) Templates prepared to facilitate collating and reporting the KYC data to FIU-
IND

(d) a & b

69. KYC guide lines have been issued by RBI under the provisions of

(a) Section 35 of Banking Regulation Act

(b) Section 35-A of RBI Act
(c) Section 35-A of Banking Regulation Act
(d) Section 35-A Prevention of Money Laundering Act

70. What is the minimum balance that the banks can stipulate in a Basic savings
bank deposit?

(a) Account (b) No such conditions can be imposed

(c) Rs 10 (d) Rs100

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71. In a basic saving bank deposit account which of the following service can be
allowed

(a) Deposit and withdrawal of cash at bank branch as well as ATMs

(b) Receipt/credit of money through electronic payment channels

(c) By means of deposit/collection of cheques drawn by Central / State

government agencies and departments

(d) All the above

72. As per KYC policy of RBI which of the following instruments can be issued in
cash if the amount is Rs 50000/ or above

(a) Travelers cheque, demand draft (b) Demand drafts, mail–transfers

(c) Mail transfers, telegraphic transfers (d) None of the above

73. A person who does not have an account based relationship with a bank but
undertakes Transactions with a bank is called

(a) Shadow customer (b) Walk-in customer

(c) Money mule (d) Customer

74. Banks are to keep a close watch on large size cash debit or credit transactions
in deposit or loan accounts and keep a record of such transactions. For this
purpose, the large size transactions mean where the amount is

(a) Rs.10 lac and above (b) Above Rs.10lac

(c) Less than Rs.10 lac (d) All the above

Page 48 of 77
75. Monthly cash transaction report (CTR) is to be submitted by the bank to FIU
within

(a) 45 days of close of the month (b) 30 days of close of the month
(c) 25 days of close of the month (d) 15 days of close of the month

76. Who among the following are certifying authority for certifying OVD of NRIs &
PIOs

(a) Notary of public abroad (b) Court magistrate

(c) Authorized officer of Bank (d) Any of the above

77. X has a current account with the bank and he agrees to receive a cheque of
Rs.10 lac from B and on the strength of this amount of Rs.10 lac, he
issues 5 cheques of Rs.1.90eachinthename of 5 different persons and retains the
balance amount as his commission such type of transaction is known as

(a) Money agency transaction (b) Money pipe transaction

(c) Money mule transaction (d) Money flow transaction

78. Which of the following customer does not fall under low risk category under
KYC guidelines?

(a) Salaried employees (b) Persons from lower strata of the society
(c) Govt departments (d) Trusts

79. Which of the following customers fall under the high risk category customers
for KYC purposes?

i. politically exposed persons of foreign origin

ii. companies having close shareholding
iii. Firms having sleeping partners
iv. high net-worth individuals

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(a) i to ii all (b) i to iii only
(c) i to iv only (d) i ii and iv only

80. As per KYC guidelines “Shell banks” means

(a) A bank having no existence but on paper only

(b) A bank incorporated outside India and having a branch in India
(c) A bank has no existence and it is not regulated by a regulating authority
(d) A bank incorporated outside India and banned by UNO to have operations
other than in country of incorporation

81. As per Prevention of Money Laundering Act, the banks are required to
maintain record of transactions for a period of --from date of cessation of the
transaction

(a) 2 years (b) 5 years (c) 10 years (d) 20 years

82. As per Prevention of Money Laundering Act, STR to be submitted within of

arriving at conclusion

(a) 7 days (b) 3 days (c) 15 days (d) 30 days

83. As per Prevention of Money Laundering Act, the banks are required to submit
CTR for transactions of Rs. ----------

(a) Rs.50 lac (b) Above Rs.5 lac (c) Above Rs.10 lac (d) Rs.100 lac

84. As per Prevention of Money Laundering Act, STR to be submitted for

transactions of Rs. -------

(a) Rs.10 lacs (b) Rs.15 lacs (c) Any amount (d) Rs 5 lacs

Page 50 of 77
85. Which of the following is the document for proof of customer identity and
address under KYC?
(a) Telephone bill (b) Aadhar number (c) Electricity bill (d) All the above

86. Which of the following is an important feature or small deposit accounts?

(a) Where the maximum balance shall not exceed Rs.50000/

(b) Total of credit entries in the account would not exceed Rs. 1 lac during year
(c) Monthly withdrawal is not more thanRs.10000
(d) a to c all

87. In a basic saving bank deposit account what is the maximum no. of cash
withdrawal (including ATM) transactions

(a) No ceiling (b) 2 (c) 4 (d) 10

88. Punishment for offenses under Prevention of Money Laundering Act is

prescribed as

(a) Fine up to Rs.3 lac and imprisonment ranging between 3 to 5 years

(b) Fine up to Rs.3 lac and imprisonment ranging between 3 to 7 years
(c) Fine up to Rs.5 lac and imprisonment ranging between 3 to 5 years
(d) Fine up to Rs.5 lac and imprisonment ranging between 3 to 7 years

89. All individual CASA accounts are eligible for CKYC ID; the CKYC ID will be
populated in the CIM50 Web page of CBS after ___ hours from the day of
scanning and uploading of CKYC data.

(a) 24 hours (b) 48 hours (c) 72 hours (d) 07 hours

Page 51 of 77
90. Which one of the following is incorrect?

(a) PAN card- Address Proof (b) Driving License as well as address proof
(c) Aadhar Card- ID as well as address proof (d) Electricity Bill- Address Proof

91.“Canara Small Savings Bank Deposit” features and restrictions stipulated by

RBI/Govt. of India are

(a) accounts where aggregate of all credits in a financial year does not exceed
Rs.1.00 lakh

(b) The aggregate of all withdrawals and transfers in a month does not exceed Rs.
10,000/-

(c) Where the balance at any point of time does not exceed Rs. 50,000/-

(d) All the above

92. During partial freezing of the account

(a) Debits are allowed but no credits are allowed

(b) Credits are allowed but no debits are allowed
(c) Both debit and credit are allowed with a memo
(d) Both debits and credits are not allowed

93. Which one is incorrect regarding total freezing of account?

(a) During this stage no debits and credits are allowed

(b) Making account in operative
(c) Credits are allowed but debits are not allowed
(d) Customers have right to close the account

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94. KYC documents for opening bank accounts of companies

(a) Certificate of Incorporation, Memorandum and articles of association

(b) Resolution from board of directors & power of Attorney granted to its
managers, officers or employees to transact on its behalf.

(c) Corporate Identification Number (CIN) and PAN of the company

(d) All the Above

95. Suspicious transaction means a transaction which

(a) Gives rise to a reasonable ground of suspicion that it may involve proceeds of
an financial offence regardless of the value involved

(b) Appears to be made in circumstances of unusual or unjustified complexity

(c) Appears to have no economic rationale or bona fide purpose

(d) All the above

96. Where the client is a partnership firm, which documents are not required?

(a) Registration Certificate (b) Memorandum of Association

(c) Partnership Deed (d) KYC of authorized signatories

97. Bank applies the CDD procedure at UCIC (Unique Customer Identification
Code) level. So, if an existing KYC compliant customer desires to open new
account, fresh CDD exercise is

(a) Not required (b) Mandatory

(c) Optional (d) Branch Manager discretion

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98. During the periodical review if the low risk category customer for whom
simplified procedure had been applied earlier, is re-categorized as “Moderate or
High Risk” what steps are to be taken by the bank?

(a) Customer has to submit Aadhar or PAN card/ Form 60 immediately

(b) In case Aadhar/PAN is not available any of the Govt. notified OVDs & Form 60
immediately

(c) In case party fails to comply bank to proceed with Partial Freezing/Closure

(d) Obtain (a or b) or proceed as per c

99. What is the full form of CKYC?

(a) Central Know Your Client. (b) Centre Know Your Customer.
(c) Central Know Your Customer. (d) Central Known Your Customer.

100. How many digits are there AADHAR card

(a) 12 (b) 10 (c) 8 (d) 14

101. What is the full form of FATF

(a) Financial Action Test Force (b) Finance Action Task Force
(c) Financial Actionable Task Force (d) Financial Action Task Force

102. Which of the following customer falls under Medium risk category under KYC
guidelines?

(a) Government Departments (b) Blind

(c) Salaried employee (d) HNI

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103. Bank shall ensure that records pertaining to the identification of the
customers and their address (Ex copies of documents like passports, identity
cards, driving licenses, PAN card, utility bills etc.) obtained while opening the
account and during the course of business relationship, are properly preserved for
at least ……. years after the business relationship is ended

(a) 5 years (b) 10 years (c) 8 years (d) 7 years

104. What is full form of CFT

(a) Combating Financing of Terrorist (b) Combating Financing of Terrorism

(c) Combating Finance of Terrorism (d) Combating Financial of Terrorism

105. Cross-border Wire Transfer Report (CWTR) is required to be filed by …..…… of

succeeding month for all cross border wire transfers

(a) 15th (b) 07th (c) 05th (d) 30th

106. Cross-border Wire Transfer Report (CWTR) is required to be filed by 15th of

succeeding month for all cross border wire transfers of the value of more than
Rupees ………. or its equivalent in foreign currency where either the origin or
destination of fund is in India.

(a) 5 Lacs (b) 10 Lacs (c) 15 Lacs (d) 20 Lacs

107. What is the full form of " IEC”?

(a) Importer Exporter Care (b) Importer Exporter Course

(c) Importer Exporter Code (d) Inland Export Care

108. What is the full form of CDD?

(a) customer due diligent (b) consumer due diligence

(c) customer diligence day (d) customer due diligence

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109. In terms of PML Act a person means

(a) An individual (b) Hindu Undivided Family

(c) A firm (d) All the above

110. Where the customer is a partnership firm, the beneficial owner is the natural
person(s), who, whether acting alone or together, or through one or more juridical
person, has/have ownership of/entitlement to more than …………… of capital or
profits of the partnership

(a) 15% (b) 25% (c) 10% (d) 20%

111. …………………………. means the capturing live photo of the customer and
officially valid document or the proof of possession of Aadhaar, where offline
verification cannot be carried out, along with the latitude and longitude of the
location where such live photo is being taken by an authorized officer of the bank.

(a) Digital KYC (b) CKYC

(c) KYC (d) Video based Customer Identification Process

112. Full form BSBD account

(a) Basic Standard Bank Deposit Account (b) Basic Self Bank Deposit Accounts
(c) Basic Savings Bulk Deposit Accounts (d) Basic Savings Bank Deposit Accounts

113. Out of the following which is not an Officially Valid Documents

(a) Passport (b) PAN card

(c) Aadhaar card (d) Voter Card

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114. Which of the following customer fall under HIGH risk category under KYC
guidelines?

(a) Blind (b) Purdanashin

(c) Government owned companies (d) Politically Exposed Persons (PEPs)

115. Risk rating of Customers is also based on the Deposits/account balance. If a

customer is maintaining a balance of Rs. 25 lakh & above but less than Rs.100
lakh then his risk rating will be:

(a) Low risk (b) Normal risk (c) Medium risk (d) High risk

116. Risk rating of Customers is also based on the Deposits/account balance. If a

customer is maintaining a balance of Rs.100 lakh & above then his risk rating will
be:
(a) Low risk (b) Normal risk (c) Medium risk (d) High risk

117. Risk rating of Customers is also based on the Deposits/account balance. If a

customer is maintaining a balance of Less than Rs.25 lakh then his risk rating will
be

(a) Low risk (b) Normal risk (c) Medium risk (d) High risk

118. Once new account completes 6 months then the account should be
categorized as medium subject to complying with other parameters. And the
account thereafter should go to low risk after …….. subject to complying with
other parameters

(a) 12 months (b) 6 months (c) 9 months (d) 3months

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119. Blocked Accounts and Unclaimed deposits shall be categorized as

(a) Low risk (b) High Risk (c) Medium risk (d) Normal risk

120. Under vintage parameter, newly opened CASA accounts which have not
completed ……months shall be categorised as High Risk, except accounts
pertaining to staff, ex-staff, pensioners, small accounts, Financial Inclusion and
Basic Savings Bank Accounts.

(a) 12 months (b) 24 months (c) 3 months (d) 6 months

121. The objective of KYC/AML/CFT guidelines is to prevent Bank from

a) being used intentionally or unintentionally, by criminal elements for money

laundering and terrorist financing activities.

b) KYC procedures also enable Bank to know/ understand the customers and their
financial dealings better and manage the risks prudently

c) being used intentionally or unintentionally, by criminal elements for terrorist

financing activities.

d) All the above

122. Designated Director mean

a) A person designated by the reporting entity (bank, financial institution, etc.) to

ensure overall compliance.

b) With the obligations imposed under chapter IV of the PML Act and the Rules
and includes the Managing Director or a whole-time Director duly authorized by
the Board of Directors if the reporting entity is a company.

c) Both a & b d) None of above.

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123. Which are the key elements of KYC policy of RBI? Select the most
comprehensive answer.

i. Customer Acceptance Policy (CAP)

ii. Customer Identification Procedures (CIP)
iii. Monitoring of Transactions
iv. Risk Management

a) only i (b) it iii iii & iv (c) iii &ii ( d) i. iii & iv

124. Customer acceptance policy of the bank is framed so as to take care of which
are all aspects?

a) No account is opened without applying appropriate customer due diligence/No

account is opened in the name in anonymous/ fictitious /benami names

b) No transaction or account based relationship is undertaken without following

the CDD procedure

c) All specified mandatory information to be compulsorily to be obtained while

opening the account and during the periodic up-dations and optional / additional
information after Opening the account with the consent of customer

d) All of the above.

125. Which one is not an OVD?

a. Job Card issued by NREGA duly signed by an officer of the State Government
b. Letter issued by the National Population Register containing details of name
and Address

c) Ration Card
d. Any other document as notified by the Central Government in consultation with
the Regulator

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126. Which among the following is not correct for ‘Small Account’

a. Balance at any time does not exceed Rs 50,000/-

b) Total withdrawal may permitted in a month up to Rs 25t000/-
c. Total Credit in a financial year does not exceed Rs 1 lakh
d. All the above.

127. What are the documents to be submitted by an individual for establishing an

account based relationship with the bank as per the guidelines?

a. Aadhaar, PAN Card / Form 60

b. In case is not available , PAN/Form 60 ,any other OVDs notified by the Govt for
establishing customer identity & customer’s address or in case of low risk
customers simplified documents stipulated

c. Photograph

d) Any of (i.e. a or b) along with c

128. In how many days foreign student has to submit the document of local
address and during that period what is the cap of credit as foreign remittance and
what is the cap for withdrawal limit

a. 30 Days and USD 10,000 & Rs 50,000

b. 45 Days and Rs 1,00,000/- Rs 25,000/-
c. 30 Days USD 1t000 and Rs 50t000
d. 30 Days USD 2,500 and Rs 50,000/-
e. None of the above

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129. Which are the simplified documents acceptable in the case of Low Risk
customers for Customer identity?

a. Identity card with applicant’s Photograph issued by Central/ State Government

Departments, Statutory/ Regulatory Authorities, Public Sector Undertakings,
Scheduled Commercial Banks, and Public Financial Institutions

b. a letter issued by a Gazetted officer, with a duly attested photograph of the

person.

c. Utility bill which is not more than two months old of any service provider.

d) a or b

130. Certifying Authorities to certifying OVDs (Official Valid Documents) of NRIs

(Non Resident Indians) & PIOs (Persons of Indian Origin) are,

a. Authorized officials of overseas branches of scheduled commercial banks

registered in India, branches of overseas banks with whom Indian banks have
relationship

b. Notary public abroad, Judge, Court Magistrate, Indian Embassy/Consulate

General in the country where the non – resident customer resides

c. Any Gazetted Officer in India

d) Any of a & b above

131. Documents to be scanned and uploaded for CKYCR

a. ID proof & Address

b. Proof of Identity Proof of Address Cropped up Signature and Photograph

c. Signature and Photograph

d. Application.

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132. In case of Married Women , any OVD shall be deemed to an ―officially valid
document even if there is a change in the name subsequent to its issuance,
provided it is supported by

a. Marriage certificate issued by the State Government

b. Gazette notification, indicating such a change of name

c) a or b

d) a & b

133. If customer is desirous of receiving any benefit or subsidy under any scheme
notified under Section 7 of Aadhaar Act 2016.

a) Submission & Linking of Aadhaar Number to Account is mandatory

b. Submission of any of Official Valid document will holds good

c. Submission of PAN card is Mandatory

d. Need no to submit any Official Valid Document.

134. What is the procedure for implementation of Section 51A of the Unlawful
Activities (Prevention) Act,1967 (UAPA)

a) freeze, seize or attach funds and other financial assets or economic resources
held by, on behalf of or at the direction of the individuals or entities Listed in the
Schedule to the Order, or any other person engaged in or suspected to be
engaged in terrorism;

b) prohibit any individual or entity from making any funds, financial assets or
economic resources or related services available for the benefit of the individuals
or entities Listed in the Schedule to the Order or any other person engaged in or
suspected to be engaged in terrorism;

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c) prevent the entry into or the transit through India of individuals Listed in the
Schedule to the Order or any other person engaged in or suspected to be
engaged in terrorism

d) All the above

135. The Unlawful Activities (Prevention) Act define Order means:

a) The order which have given power to state authority to search any one

b) “Order” means the Prevention and Suppression of Terrorism Order 2007

c) Both a & b

d) all the above

136.The consolidated list of the UAPA nodal officers should be circulated to the
nodal officer of IS-I Division of M A in (MHA stands for Ministry of Home Affairs)

a) July every year and on every change. b) August every year

c) Only on every change d) All the above

137. In case , the particulars of any customers match with the particulars of
designated individuals/entities, regarding funds, Financial Assets or Economic
Resources or related services held in the form of bank account, Stocks or
Insurance Policies etc. by what time Banks/stock exchange/ Insurance company
will report and to whom it will be reported

a) 24 hours with full particulars to MHA

b. 24 hours with full particulars to MEA (Ministry of External Affairs)

c. 48 hours with full particulars to MEA

d. need not be reported

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138. Review of Customer Risk Categorization

a. to be carried out not less than once in six months

b. as on 15th of May and 15th November every year

c. once in a year

d) a & b

139. Customer identification procedure to be carried out

I. While establishing the banking relationship

ii. While carrying out a financial transaction
iii. When the bank has a doubt about the authenticity or adequacy of the
customer Identification data, it has obtained.

iv. When bank sells third party products as agent

a. I & ii b. ii & iii c. i, iii & iv d) I, ii iii & iv

140. Where the client is a partnership firm, which documents are required?

(i) Registration Certificate

(ii) Partnership Deed
(iii) Any Officially Valid Document which contains proof of identity/address
in respects of managers, officers and employees holding an attorney to
transacts on its behalf. and
(iv) PANs or Form 60 as defined in the Income Tax Rules, 1962 issued to
the person holding an attorney to transact on behalf of the partnership

(a) i & iv (b) i, ii & iv (c) i , ii, iii & iv (d) only i & ii e. iii & iv

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141. Where the client is an unincorporated association or a body of individuals,
certified copies of following documents are to be submitted:

(a) Resolution of the managing body of such association or body of individuals

(b) Power of Attorney granted to the person who will transact on its behalf.

(c) Any Officially Valid Document which contains proof of identity/address in

respects of managers, officers and employees holding an attorney to transacts on
its behalf.

(d) PAN or Form 60 as defined in the Income Tax Rules, 1962 issued to the person
holding an attorney to transact on behalf of the unincorporated association or a
body of individuals.

(e) All the above

142. In respect of Trust which is not correct subject to Customer Due Diligence?

a) OVDs of any natural person exercising ultimate effective control over the trust
through a chain of control or ownership / Beneficiaries with 25% or more interest
in the trust.

b. OVDs of Trustees

c. OVDs of any natural person exercising ultimate effective control over the trust
through a chain of control or ownership /Beneficiaries with 15% or more interest
in the trust

d. OVD of the author of the trust.

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143. Who is a beneficial owner in a Company?

i. Natural persons who whether acting alone or together or through one or more
juridical Person has / have a controlling ownership interest or who exercise
control through other means.

ii. Natural persons who whether acting alone or together or through one or more
juridical person who has /have ownership of /entitlement to more than 15% of
the shares or profits of the company

iii. Natural persons who whether acting alone or together or through one or more
juridical person has / have the right to appoint majority of the directors or to
control the Natural persons

iv. Natural persons who whether acting alone or together or through one or more
juridical person who has /have ownership of /entitlement to more than 25% of
the shares or profits of the company

(a) I & iii (b) i, iii & iv (c) I & iii (d) i, ii, iii &iv

144. Periodic up-dation of KYC

a. 8 year for low Risk, 10 year for high Risk and 2 year for medium Risk customer

b. 2 year for low Risk, 10 year for high Risk and 8 year for medium Risk customer

c) 10 year for low Risk 2 year for High Risk and 8 year for medium Risk customer

d. 8 year for low Risk, 2 year for high Risk and 10 year for medium Risk customer

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145.For opening an account of a trust, certified copies of which of the following
documents shall be obtained:

a. Registration certificate.

b. Trust deed.

c. Identification information as mentioned under Section 15in respect of the

person holding a power of attorney to transact on its behalf.

d. all the above

146. During partial freezing of account

a. Debits are allowed but no credits are allowed

b) Credits are allowed but no debits are allowed
c. both debit and credits are allowed with memo
d. both debits and credits are not allowed

147. Total freezing of accounts mean

i. During this stage no debits and credits are allowed

ii. Making account in operative

iii. Credits are allowed but debits are not allowed

iv. customers have right to close the account.

a) i, ii & iv b. i, ii &iii c. i, ii, iii & iv d. i & ii

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148. Which is true in case of Cross Border Wire Transfer Report (CWTR) is required
to fled with FIU-IND

a. more that Rs 5 lakhs or its equivalent in foreign currency

b. where the origin and destination of fund is India

c. CWTR is required to file within 15th day of succeeding month with FIU- IND

d) All the above

149. Which statement is true for Simplified norms for Self Help Groups (SHGs)

(a) KYC verification of all the members of S Gs need not be done while opening
the Savings Bank account of the S Gs and KYC verification of all the office bearers
would suffice.

(b) As regards KYC verification at the time of credit linking of S Gs, no separate
KYC verification of the members or office bearers is necessary.

(c) KYC is not required for SHG members

(d) a & B are correct options

150. What type of accounts can be opened for foreign students studying in India.

(a) NRO
b. NRE account
c. BSBD account
d. Any of the above.

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151. What are the documents to be verified for a foreign national student?

a. Passport with visa and immigration endorsement, which bears the proof of
identity and address in the home country; the admission letter from an
educational institute in India;

b. Photographs

c. Undertaking to submit the local address within 30 days

d. All the above along with an approval letter from RBI In the case student is of
Pakistani nationality.

152. Correspondent banking is the provision of banking services

a. by one bank (the correspondent bank) to another bank (the respondent bank).

b. These services may include cash/funds management, international wire

transfers, drawing arrangements for demand drafts and mail transfers, payable-
through-accounts, cheques clearing etc.

c. Banks may take gather sufficient information to fully understand the nature of
business of the bank including information on management, major business
activities.

d. option a & b are correct

e. all the above are correct

153. IMB transactions fall under which risk

a. low risk b. High risk

c. medium risk d. not required to categorized in risk

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154. ATM transaction is categorized

a. low risk b. Medium risk

c. high risk d. not required to categorized in risk

155. Bank shall maintain record at least

a. 5 years for specified records where transactions are internal in nature

b. 8 years for specified records where customers transactions are recorded

c. Both a & b

d. All the above

156. Transaction means a purchase, sale, loan, pledge, gift, transfer, delivery or the
arrangement thereof and includes-

(a) opening of an account, deposits, withdrawal, exchange or transfer of funds in

whatever currency, whether in cash or by cheque, payment order or other
instruments or by electronic or other non-physical means;

(b) the use of a safety deposit box or any other form of safe deposit

(c) entering into any fiduciary relationship

(d) any payment made or received in whole or in part of any contractual or other
legal obligation or establishing or creating a legal person or legal arrangement

(e) All the above

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157. For small value accounts shall remain operational initially for period of
_____and there after further period of _______ If the holder of such an account
provides evidence before the banking company of having applied for any of the
OVD within _____ of the opening of the said account, within entire relaxation
provision to review in respect of the said account ____

a.12 months , 12 months, 6 months, 24 months

b. 12 mothst12 moths 12 months t 24 months

c. 12 months, 24 months, 6 months, 12 months

d. 12 months, 6 months, 6 months, 24 months

158. Since the ‘at par’ cheque facility offered by commercial banks to cooperative
banks is in the nature of correspondent banking arrangement

a. Bank should monitor and review such arrangements to assess the risks
including credit risk and reputational risk arising there from.

b. For this purpose, banks should retain the right to verify the records maintained
by the client cooperative banks/ societies for compliance with the extant
instructions on KYC and AML under such arrangements shall be retained by
banks.

c. Both a & b

d. All the above

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159. What is UCIC

a. Unique Customer Identification Code which help banks to identify the

customers.

b. avoid multiple identities

c. track the facilities availed, monitor financial transaction in holistic manner and
enable banks to have a better approach to risk profiling of customers. Banks have
been advised allot UCIC while entering into new relationships with individual
customers as also the existing customers.

d. All the above

160. Who is authorized to act as and perform the functions of CKYCR ?

a. Central Registry of Securitisation Asset Reconstruction and Securities of India

(CERSAI)

b. Department of CKYCR, Finance Ministry c. UIDAI d. RBI

161. If the current address of a customer is different from the address recorded in
the OVD, what is to be done?

a. A declarations shall be obtained from the customer indicating the address to

which all correspondence will be made and it shall be verified through positive
confirmation.

b. In case the identity information relating to Aadhaar number or Permanent

Account Number submitted by the customer does not have his current address,
such customer shall submit an officially valid documents.

c. Both a & b

d. Customer has to submit separate proof for current address.

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162. What are the enhanced due diligence to be exercised in the accounts of non-
face-to-face customers?

a. Certification of all documents presented

b. Calling for additional documents
c. First payment to be effected through the customer’s KYC compliant account
with another bank.

d. All of the above

163. During the periodical review if the low risk category customer for whom
simplified procedure had been applied earlier, is re-categorised as Moderate or
High Risk what steps are to be taken by the bank ?

a. Customer has to submit Aadhaar and PAN card /Form 60 immediately

b. In case Aadhaar /PAN is not available any of the Govt. notified OVDs & Form60
immediately

c. In case party fails to comply bank to proceed with Partial Freezing /Closure

d. Obtain (a or b) or proceed as per c

164. Unique Customer Identification Code (UCIC) helps bank

a. To identify a customer
b. Track the facility availed
c. Monitor financial transactions
d. Improve risk profiling
e. All the Above

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165. If customer is desirous of receiving any benefit or subsidy under any scheme
a. Submission and Linking of Aadhar Number to account is mandatory
b. Submission of any of Official Valid Document will holds good
c. Submission of PAN Card is mandatory
d. Need not submit any official valid document.

166. Which one of the following is incorrect?

a. PAN card- Address Proof
b. Driving License- ID Proof
c. Aadhar Card- ID as well as address proof
d. Electricity Bill- Address Proof

167. Which does not match as customers risk

a. Travel Agency- Medium Risk
b. NGO which supported by UNO- Low Risk
c. Restaurant, Retail Shop- Medium Risk
d. Blind- High Risk

168. Introduction of customer to bank is …………………. for opening accounts under

PML Act and Rules or the RBI‟s extant instructions.

(a) Not mandatory

(b) Mandatory
(c) Manager Discretion
(d) None of the above

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169. AML Stands for_________
a. Anti Monitory Limit
b. Anti Money Laundering
c. Always money laundering
d. Anytime Money Laundering

170. Money laundering is related to---------------------------

a. To reduce the number of families which lives below poverty line
b. To reduce the NPA of Banks
c. To reduce the Black Money
d. To reduce the unemployment rate.
e. None of these
@@@

Page 75 of 77
 Key
01 02 03 04 05 06 07 08 09 10
c c d d d d d b d c

11 12 13 14 15 16 17 18 19 20
a d c a a a a b b a

21 22 23 24 25 26 27 28 29 30
b d d b d d c d b c

31 32 33 34 35 36 37 38 39 40
b A d d d d d b c d

41 42 43 44 45 46 47 48 49 50
a a c d a a d c c a

51 52 53 54 55 56 57 58 59 60
d c d a d d d a d c

61 62 63 64 65 66 67 68 69 70
c d c b c c c d c b

71 72 73 74 75 76 77 78 79 80
d d b a d d c d c c

Page 76 of 77
81 82 83 84 85 86 87 88 89 90
b a c c b d c d a a

91 92 93 94 95 96 97 98 99 100
d b c d d b a d c a

101 102 103 104 105 106 107 108 109 110
d b a b a a c d d a

111 112 113 114 115 116 117 118 119 120
a d b d c d a a b d

121 122 123 124 125 126 127 128 129 130
d c b d c b d c d d

131 132 133 134 135 136 137 138 139 140
b c a d b a a d d c

141 142 143 144 145 146 147 148 149 150
e a b c d b a d d a

151 152 153 154 155 156 157 158 159 160
d e b b c e b d d a

161 162 163 164 165 166 167 168 169 170
c d d e a a d a b c

Page 77 of 77