KYC

-DHRUVA SAREEN
-955
What is KYC?

KYC (Know Your Customer) is a framework for

banks which enables them to know / understand
the customers and their financial dealings to be
able to serve them better.

Banking operations are susceptible to the risks of

money laundering and terrorist financing.

Therefore, banks are advised to follow certain

customer identification procedure for opening of
accounts and monitoring transactions of a
suspicious nature for the purpose of reporting it to
appropriate authority
 Contd.

 Reserve Bank of India has advised banks to

make the Know Your Customer (KYC)
procedures mandatory while opening and
operating the accounts and has issued the KYC
guidelines under Section 35 (A) of the Banking
Regulation Act, 1949.

 Any contravention of the same will attract

penalties under the relevant provisions of the
Act. Thus, the Bank has to be fully compliant
with the provisions of the KYC procedures.
 What KYC means?
 Customer?
One who maintains an account, establishes business
relationship, on who’s behalf account is maintained,
beneficiary of accounts maintained by intermediaries, and
one who carries potential risk through one off transaction

 Your? Who should know?

Branch manager, audit officer, monitoring officials, PO.

 Know? What you should know?

True identity and beneficial ownership of the accounts
permanent address, registered & administrative address,
sources of funds, nature of customers’ business etc.
When does KYC apply?

 Opening a new account.

 In respect of accounts where documents as per current KYC
standards have not been submitted while opening the initial
account.
 Opening a Locker Facility where these documents are not
available with the Bank for all the Locker facility holders.
 When the Bank feels it necessary to obtain additional
information from existing customers based on conduct of
account.
 When there are changes to signatories, mandate holders,
beneficial owners etc.
 For non-account holders approaching the Bank for high
value one-off transactions like Drafts, Remittances etc.
 KYC
KYC/Customer due diligence is an on-going process for
prudent banking practices, therefore the banks are
encouraged to:-
 Set up a compliance unit with a full time Head.
 Put in place a system to monitor the accounts and
transactions on a regular basis.
 Update customer information and records at reasonable
intervals.
 Chalk out plan of imparting suitable training to the staff of bank
periodically.
 Maintain proper records of customer identifications and clearly
indicate, in writing.
 Monitor and check unusually large cash transactions,
especially those which are out of character/ inconsistent with
the history.
Why KYC?

 To establish the identity of the client. This means

identifying the customer and verifying his/her identity by
using reliable, independent source documents, data or
information.

 To ensure that sufficient information is obtained on the

nature of employment/business that the customer
does/expects to undertake and the purpose of the
account.

 To prevent banks from being used, intentionally or

unintentionally, by criminal elements for money
laundering activities.
When does KYC apply?

KYC will be carried out at the following stages:

o Opening a new account.

o Opening a subsequent account where documents as per
current KYC standards have not been submitted while
opening the initial account.
o Opening a Locker facility where these documents are not
available with the bank for all the Locker facility holders.
o When the bank feels it necessary to obtain additional
information from existing customers based on conduct of the
account.
o When there are changes to signatories, mandate holders,
beneficial owners etc.
Are KYC requirements new?

 No ! KYC requirements have always been in place

and Banks have been taking KYC documents in
accordance with the guidelines issued by SBP from time
to time. SBP has revisited the KYC guidelines in the
context of the recommendations made by the
Financial Action Task Force (FATF) on Anti Money
Laundering Measures and Combating Financing of
Terrorism and enhanced the KYC Standards in line
with International benchmarks.

The Financial Action Task Force (FATF) was established in July 1989 by a
Group of Seven (G-7) Summit in Paris, initially to examine and develop
measures to combat money laundering.
Regulations

 PRUDENTIAL REGULATION XI: KNOW YOUR CUSTOMER

(KYC)

• Banks/DFIs are advised to fully comply with the

requirements of Prudential Regulation No. XI

• Non-compliance of instructions will attract penal

provision under the Banking Companies Ordinance,
1962.
 KYC Guidelines
 These guidelines are issued under Section 35 (A) of the Banking
Regulation Act, 1949 and any contravention of the same will attract
penalties under the relevant provisions of the Act. Banks are advised
to bring the guidelines to the notice of their branches and controlling
offices.
Towards Name proof Photo Identification Towards address proof

Passport where the address differs Telephone Bill

Voter’s Identity Card
PAN Card
Driving Licence
Govt. /Defence ID card *
ID cards of reputed employers *
Letter from a recognised public
authority or public servant
verifying the identity and residence
of the customer*
Bank account statement
Income/Wealth tax assessment
order
Credit Card Statement
Electricity Bill
Ration Card
Letter from employer*

*Subject to the satisfaction of the officer authorising the opening of the

account
•Note: Original should be produced for verification and copy, duly
attested by the verifying official, shall be kept along with the account
opening form.
The customer profile shall be updated, on
a periodical basis, as under:

 For low risk customers Once in three years

 For medium risk customers Every year
 For high risk customers Every year
Monitoring of Transactions

 On-going monitoring of transactions for identifying

suspicious and high value cash transactions (Rs. 10
lakhs)
 Special attention to all complex, unusually large
transactions and all unusual patterns which have no
apparent economic or visible lawful purpose.
 Prescription of threshold limits
 Review of risk classification
 Reporting to law enforcement authority
Risk Category

 High Risk Customers

 Medium risk customers
 Low risk customers
 Risk Management

 Proper systems and procedures to be in place to

enable the management to review effective
implementation of KYC norms
 Banks internal/concurrent auditors to verify
application of KYC procedures and to evaluate the
effectiveness of banks KYC policies and procedures
 A quarterly compliance report to be placed before
the audit committee.
High risk customer- due
diligence
 Accounts of Trusts
 Accounts of Companies and Firms
 Accounts opened by professional intermediaries
 Accounts of Politically Exposed Persons resident
outside India
 Non-Face-To-Face Transaction
 Correspondent Banking
KYC for Existing Accounts

 Revised guidelines to apply to all the existing

customers on the basis of materiality and risk
 Transactions in existing accounts to be continuously
monitored for review of CDD measures
 All existing accounts of companies, firms, trusts,
charities, religious organizations and other institutions
to be subjected to minimum KYC
Reports to be prepaid

 CTR- Cash Transaction Report

- For all cash transaction above Rs. 10 lakhs in a month
 STR- Suspicious Transaction Report
 Reports should be prepaid in E- Form
 Should be sent to RBI on each working last Friday
 Record Keeping
 Financial intermediaries should prepare and
maintain documentation on their customer
relationships and transactions to meet the
requirements of relevant laws and regulations, to
enable any transaction effected through them to
be reconstructed. In the case of wire transfer
transactions, the records of electronic payments
and messages must be treated in the same way as
other records in support of entries in the account.
 All financial transactions records should be
retained for at least five years after the transaction
has taken place and should be available for
perusal and scrutiny of audit functionaries as well
as regulators as and when required.
Relaxed KYC Procedure

 Relaxed KYC procedure refers to acceptance of

an introduction in full KYC procedure subject to
certain conditions prescribed.
 This relaxation is applicable for Low Income
Group customers, individuals falling under the
'No frill‘ category, persons affected by natural
calamities like floods, cyclone, tsunami, etc.
 Low Income group customers are those who
keep balances not exceeding Rs.50000/- in all
their accounts (FDR/CA/SB) taken together and
the total credit summation in all the accounts
taken together is not expected to exceed
Rupees One Lakh (Rs.100000/-) in a year.
Contd…
 For these customers, branches are permitted to open
accounts subject to the following conditions:
I. An introduction (in lieu of the KYC documents) from another
account holder who has been subjected to full KYC
procedure should be given.
II. The introducer's account with the Bank should be at least six
month's old and should show satisfactory transactions.
III. The photograph of the customer who proposes to open the
account and his address need to be certified by the
introducer.
 When, at any point of time, the total balance in all his/her
accounts (FDR/SB/CA) with the Bank taken together exceeds
Rupees Fifty thousands (Rs.50000/-) or total credit summation
in all the accounts exceeds Rupees one lakh (Rs.100000/-) in a
year, no further transactions will be permitted until the full KYC
procedure is completed.
Training & Education

Employee Training
 Banks should take steps to provide proper training to
its employees on the statutory/ regulatory
requirements and the internal policy & procedures so
that the risks are well understood and managed
 Employees should also be educated on the need for
proper handling of customer queries

Customer Education
 Distribution of pamphlets etc. may be considered
KYC Guidelines

Definition of Customer:

o A customer or entity that maintains an account

and/or has a business relationship with the bank;
o One on whose behalf the account is maintained
(i.e. the beneficial owner)
 KYC Guidelines

• The Bank/branch shall obtain satisfactory evidence duly

verified/authenticated by the branch manager and shall be
placed on record in respect of
(i) the true identity of the beneficial owners of all accounts opened
by a person, entity etc,
(ii) the real party in interest or controlling person/entity of the
account(s) in case of nominee or minors account.

• The Banks shall obtain “Introduction” on the new account to assess

the prospective customer’s/account holder’s integrity,
respectability and the nature of business etc.
( Introducer is an existing account holder of the same branch )
 KYC Guidelines

• The Banks are also advised that KYC/customer due diligence is

not a one time exercise to be conducted at the time of entering
into a formal relationship with customer/account holder.

• Each Bank shall formulate and keep in place, in writing, a

comprehensive Know-Your-Customer policy duly approved by
their Board of Directors and in case of branches of foreign banks,
approved by their head office.

• State Bank of Pakistan, during the course of inspection, would

particularly check the efficacy of the KYC system put in place by
the banks and its compliance by all the branches and the staff.
 KYC Guidelines

Training & Education:

Employee Training
• Banks should take steps to provide proper training to its employees on
the statutory/ regulatory requirements and the internal policy &
procedures so that the risks are well understood and managed.
• Employees should also be educated on the need for proper handling of
customer queries.

Customer Education
• Distribution of pamphlets etc. .may be considered
KYC Guidelines

REGULATION-XI

• OPENING OF ACCOUNTS
Banks shall make all reasonable efforts to determine
the true identity of every would be account holder.
Towards this end, banks shall institute effective
procedure and methods for obtaining proper
identification from the new customers.
 KYC Guidelines
All reasonable efforts shall be made to determine true identity of every
prospective customer. The following minimum set of documents must be
obtained from various types of customers/ account holder(s).

Individuals:
(i) Attested photocopy of national identity card or passport of the individual.

(ii) In case the NIC does not contain a photograph, the bank should also
obtain, in addition to NIC, any other document such as driver’s license etc
that contains a photograph.
(iii) In case of a salaried person, attested copy of his service card, or any other
acceptable evidence of service, including, but not limited to a certificate
from the employer.
(iv) In case of illiterate person, a passport size photograph of the new account
holder besides taking his right and left thumb impression on the specimen
signature card.
KYC Guidelines

Partnership:

(i) Attested photocopies of identity cards of all partners.

(ii) Attested copy of “Partnership Deed” duly signed by
all partners of the firm.
(iii) Attested copy of Registration Certificate with Registrar
of Firms. In case the partnership is unregistered, this
fact should be clearly mentioned on the Account
Opening form.
(iv) Authority letter, in original, in favor of the person
authorized to operate on the account of the firm.
KYC Guidelines

Joint Stock companies:

Certified copies of:

(i) Resolution of Board of Directors for opening of account
specifying the
person(s) authorized to operate the company account.
(ii) Memorandum and Article of Association
(iii) Certificate of Incorporation.
(iv) Certificate of Commencement of Business.
(v) Attested photocopies of identity cards of all the
directors.
KYC Guidelines

Clubs, Societies and Associations:

(i) Certified copies of

Certificate of Registration.
By-laws/Rules & Regulations.
(ii) Resolution of the Governing Body/Executive Committee
for opening of account authorizing the person(s) to
operate the account and attested copy of the identity
card of the authorized person(s).
(iii) An undertaking signed by all the authorized persons on
behalf of the institution mentioning that when any
change takes place in the persons authorized to operate
on the account, the banker will be informed immediately.
KYC Guidelines

Agents Accounts:
(i) Certified copy of “Power of Attorney”.
(ii) Attested photocopy of identity card of the agent.

Trust Account:
(i) Attested copy of Certificate of Registration.
(ii) Attested copies of NIC of all the trustees.
(iii) Certified copies of Instrument of Trust.
Advantages of KYC

 Sound KYC procedures have particular relevance to the

safety and soundness of banks, in that:

1. They help to protect banks’ reputation and the integrity

of banking systems by reducing the likelihood of banks
becoming a vehicle for or a victim of financial crime
and suffering consequential reputational damage;

2. They provide an essential part of sound risk

management system (basis for identifying, limiting and
controlling risk exposures in assets & liabilities
 Risk Management

The Board of Directors of the bank should ensure that an

effective KYC programme is put in place by establishing
appropriate procedures and ensuring their effective
implementation.

 Responsibility should be explicitly allocated within the bank for

ensuring that the bank’s policies and procedures are
implemented effectively.

 Apart from the key elements the other things that a bank
should look into customer education, introduction of new
technologies, applicability to branches outside India and
appointment of principal officer.
 Violating KYC: RBI’s Stance

 Case : Aug 2012

TWO PUBLIC SECTOR BANKS AND ONE PRIVATE BANK WERE HELD
ACCOUNTABLE BY THE RESERVE BANK OF INDIA (RBI),
BANGALORE, FOR FAILURE TO EXERCISE DUE DILIGENCE IN
OPENING BANK ACCOUNTS THAT ENABLED ONLINE FRAUDSTERS TO
HACK INTO THE ACCOUNTS OF GENUINE CUSTOMERS AND WALK
AWAY WITH RS 6.60 LAKH, EXPOSING THE LAX IMPLEMENTATION
OF KNOW YOUR CUSTOMER (KYC) NORMS
 Contd.

 The cases were taken up by the RBI ombudsman after the

customers lodged complaints with him; the money trail was traced
to Mumbai and Coimbatore; the fraudsters had opened accounts
with fake employment letters, residence documents and given
fictituous telephone numbers.

 The banks were found guilty and went in for appeal to the appellate
authority (Deputy Governor, RBI) who upheld two of our verdicts

 In another case, a public sector bank was asked to suspend its

mobile banking services after its security systems were found to be
deficient.
 In all, the ombudsman received 3,486 complaints during
the year compared to 3,470 last year.
-failure to implement commitments made-1,209 .
-followed by those pertaining to credit and debit cards - 732
-other categories included levy of service charges without
prior permission, loans and advances and recovery agent
harassment.
-banks had wrongly rejected applications for education
loans, which were then rectified by the respective banks.

RBI ensures that the grievances are resolved and benefits

are restored to the customers, with occasional cases of
compensation to them.
 Money Laundering

o Money laundering is the process by which large amounts of illegally

obtained money (from drug trafficking, terrorist activity or other serious
crimes) is given the appearance of having originated from a
legitimate source.
What are the Risks in Banking Sector
today?

Types of risk in bank

 Credit risk
 Market risk
 Interest Rate risk
 Liquidity risk
 Investment risk
 Operational risk
 Technology risk
 Legal risk
 Reputation risk
 Criminal Activities
 Kidnapping
 Drug Trafficking
 Bribery/corruption
 Tax Evasion
 Serious crime or All crimes
 White collar crimes (including insides trading and
securities offences)/ Pink collar crimes
 Robbery and Fraud
 Gambling
 Organized crime
Extortion
Prostitution
Smuggling (arms, people, goods)
 What are the key stages of the
Money Laundering Cycle?

 Placement

◦ of criminal proceeds into the financial system

 Layering

◦ of transactions to confuse the audit trail and distance

the original source of funds (e.g. successive
transactions, international transfers, early termination
products, tax haven companies, genuine businesses).
 Integration
◦ of funds back into the real economy as “clean and
respectable money”
 PMLA Definition

 Offence of Money Laundering (section 3)

Whoever
 (a) acquires, owns, possesses or transfers any proceeds of crime; or
 (b) knowingly enters into any transaction which is related to proceeds of
crime either directly or indirectly; or
 (c ) conceals or aids in the concealment of the proceeds of crime
 Commits the offence of money laundering
Offences covered under PML Act, 2002
 Indian Penal Codes
 Narcotic Drugs and Psychotropic Substances Act, 1985
 Arms Act 1959
 Wild Life (Protection) Act, 1972
 Immoral Traffic (prevention) Act, 1956
 Prevention of Corruption Act, 1988
 Money Laundering
What are the risks to banks?
(i) Reputational risk
(ii) Legal risk
(iii) Operational risk
(iv) Concentration risk
All risks are inter-related and together have the potential of causing
serious threat to the survival of the bank
 What is Money Laundering?


Appears to
Illegally originate from
Conversion
obtained money legitimate
source

Drugs / Arms Trafficking

Criminal Activity
Terrorism
Extortion
 Money Laundering
'Any act or attempted act to conceal
or disguise the identity of illegally
obtained proceeds so that they
appear to have originated from
legitimate sources'.
In other words, it is the process used
by criminals through which they
make “dirty” money appear “clean”
Sec.3 of PML Act, 2002 defines ‘money
laundering’ as:
“whosoever directly or indirectly
attempts to indulge or knowingly
assists or knowingly is a party or is
actually involved in any process or
activity connected with the proceeds
of crime and projecting it as
untainted property shall be guilty of
the offence of money-laundering”
 Money Laundering
Money laundering generally refers to ‘washing’ of the proceeds or
profits generated from:
(i) Drug trafficking
(ii) Arms, antique, gold smuggling
(iii) Prostitution rings
(iv) Financial frauds
(v) Corruption, or
(vi) Illegal sale of wild life products and other specified predicate
offences
Money Laundering Process

PLACEMENT
LAYERING
INTEGRATION
Placement

Immersion or Soaking
The physical disposal of
bulk cash proceeds
derived from illegal activity
LAYERING

“Soaping / Scrubbing”
The separation of illicit
proceeds from their source
by creating complex layers of
financial transactions
These disguise the audit trail &
provide anonymity
 Integration
“Repatriation / Spin Dry”
Reinjecting laundered proceeds into
economy so that they reenter
financial system as normal business
funds
Provides an apparently legitimate
explanation to criminally derived
wealth
Typologies/ Techniques
employed
 Deposit structuring or smurfing
 Connected Accounts
 Payable Through Accounts
 Loan back arrangements
 Forex Money Changers
 Credit/ Debit cards
 Companies Trading and Business Activity
 Correspondent Banking
 Lawyers, Accountants & other
Intermediaries
 Misuse of Non-Profit Organisations
Financing of terrorism

 Money to fund terrorist activities moves through the

global financial system via wire transfers and in and
out of personal and business accounts
 It can sit in the accounts of illegitimate charities and
be laundered through buying and selling securities
and other commodities, or purchasing and cashing
out insurance policies.
Legal Sources of terrorist
financing
 legal or non-legal
 legal

 Collection of membership dues

 Sale of publications
 Cultural of social events
 Door to door solicitation within community
 Appeal to wealthy members of the
community
 Donation of a portion of personal savings
Illegal Sources

Kidnap and extortion;

Smuggling;
Fraud including credit card fraud;
Misuse of non-profit organisations
and charities fraud;
Thefts and robbery; and
Drug trafficking
Money Laundering Risks

What are the risks to banks?

(i) Reputational risk
(ii) Legal risk
(iii) Operational risk (failed internal processes,
people and systems & technology)
(iv) Concentration risk (either side of balance
sheet)
All risks are inter-related and together have
the potential of causing serious threat to the
survival of the bank
Reputational Risk:

 The potential that adverse publicity

regarding a bank’s business practices,
whether accurate or not, will cause a
loss of confidence in the integrity of the
institution
 Reputational Risk : a major threat to
banks as confidence of depositors,
creditors and general market place to
be maintained
 Banks vulnerable to Reputational Risk as
they can easily become a vehicle for or
a victim of customers’ illegal activities
Operational Risk

 The risk of direct or indirect loss resulting from

inadequate or failed internal processes, people and
systems or from external events
 Weaknesses in implementation of banks’ programmes,
ineffective control procedures and failure to practise
due diligence
Legal Risk

 The possibility that lawsuits, adverse

judgements or contracts that turn out to
be unenforceable can disrupt or
adversely affect the operations or
condition of a bank
 Banks may become subject to lawsuits
resulting from the failure to observe
mandatory KYC standards or from the
failure to practise due diligence
 Banks can suffer fines, criminal liabilities
and special penalties imposed by
supervisors
Concentration Risk

 Mostly applies on the assets side of

the balance sheet: Information
systems to identify credit
concentrations; setting prudential
limits to restrict banks’ exposures to
single borrowers or groups of related
borrowers
 On liabilities side: Risk of early and
sudden withdrawal of funds by large
depositors- damages to liquidity
 Penalties imposed on banks
Jan. 2006 ABM AMRO US$ 80 mio
Aug. 2005 Arab Bank US$ 24 mio
Feb. 2005 City National Bank US$750,000
Jan. 2005 Riggs Bank US$ 41 mio
Oct. 2004 AmSouth Bank US$ 50 mio
Sep. 2004 City Bank Japan Licence
cancelled
May. 2004 Riggs Bank US$ 25 mio
SUSPICIOUS TRANACTION

 Suspicious transaction means a transaction whether or

not made in cash which, to a person acting in good
faith –
 gives rise to a reasonable ground of suspicion that it may
involve the proceeds of crime; or
 appears to be made in circumstances of unusual or
unjustified complexity; or
 appears to have no economic rationale or bonafide
purpose;
Suspicious Transactions

 Providing misleading information /

information not easily verifiable while
opening an Account
 Large cash withdrawals from: a dormant
or inactive account or account with
unexpected large credit from abroad
 Sudden increase in cash deposits of an
individual with no justification
 Employees leading lavish lifestyles that
do not match their known income
sources
Suspicious Transactions

 Large cash deposits into same account

 Substantial increase in turnover in a dormant account
 Receipt or payment of large cash sums with no
obvious purpose or relationship to Account holder / his
business
 Reluctance to provide normal information when
opening an Account or providing minimal or fictitious
information
Role of cash in money
laundering

Disguise the audit trail

Provide anonymity
Concealing true ownership
and origin of money
Control over money
Changing the form of money
 Cash Transactions

All cash transactions of the value of more

than rupees ten lakhs or its equivalent in
foreign currency

All series of cash transactions integrally

connected to each other which have been
valued below rupees ten lakhs or its
equivalent in foreign currency where such
series of transactions have taken place
within a month
 Cash Transaction Report

 Maintenance of records of transactions

 valued below rupees ten lakh or its equivalent in foreign currency
where such
 series of transactions have taken place within a month and
 the aggregate value of such transactions exceeds rupees ten lakh;
 Furnishing of CTR
 individual transactions below rupees fifty thousand may not be
included;
DUE DATES

 Cash Transaction Report

 by 15th of the succeeding month.

 Suspicious Transaction Report

 within 7 days of arriving at a conclusion that any
transaction is of suspicious nature.
 What KYC means?
 Customer?
 One who maintains an account, establishes
business relationship, on who’s behalf account
is maintained, beneficiary of accounts
maintained by intermediaries, and one who
carries potential risk through one off
transaction
 Your? Who should know?
 Branch manager, audit officer, monitoring
officials, PO
 Know? What you should know?
 True identity and beneficial ownership of the
accounts
 Permanent address, registered & administrative
address
 KYC DOES NOT MEAN

 Denial of Service to the Common Person

 Intrusive Behaviour
 Use of information for cross selling
 Harassment of customers- threatening to close down
the accounts arbitrarily
Measures to deter money
laundering
 Board and management oversight of AML
risks
 Appointment a senior executive as principal
officer with adequate authority and
resources at his command
 Systems and controls to identify, assess &
manage the money laundering risks
 Make a report to the Board on the operation
and effectiveness of systems and control
 Appropriate documentation of risk
management policies, their application and
risk profiles
Measures to deter money
laundering
 Appropriate measures to ensure that ML risks
are taken into account in daily operations,
development of new financial products,
establishing new business relationships and
changes in the customer profile
 Screening of employees before hiring and of
those who have access to sensitive
information
 Appropriate quality training to staff
 Quick and timely reporting of suspicious
transactions
Stages of the Money Laundering

1. Placement
Induction of illegal money into the financial
system
2. Layering
Multiple transactions to confuse the audit trail and
distance the original source of funds (e.g.
successive transactions, international transfers).
3. Integration
than integrating funds back into the real economy as
“clean and
Respectable money
Stages of the Money Laundering
 Money Laundering

Risks to banks?

(I) Reputational risk

(ii) Legal risk
(iii) Operational risk

All risks are inter-related and together have the potential of

causing serious threat to the survival of the bank
 Summary: Prevention of Money
Laundering
Observing Rules for
Bankers

Compliance with Customer

Money Laundering
Laws due Diligence
Prevention

Identifying
Irregular / Suspicious
Transactions
 Reports to be prepared

• CTR- Currency Transaction Report

For all cash transaction above Rs. 2.5 million.

• STR- Suspicious Transaction Report

e.g. Transactions which do not make economic sense.
Transactions inconsistent with the customer's business.
Transactions involving large amounts of cash.
Transactions involving transfers to and from abroad.

• FMU is the only designated agency in Pakistan to which suspicious

transaction reports (STRs) and currency transaction reports (CTRs)
shall be made.
Thank You