1 COMPLIANCE GROUP KYC / AML / CFT PROCEDURE MANUAL
2 TABLE OF CONTENTS 1. PREAMBLE INTRODUCTION APPLICABLE LAWS AND REGULATIONS Anti-Money Laundering Act, Offence of Money Laundering (Section 3) Punishment for Money Laundering (Section 4) Procedure and Manner of Furnishing Information by Financial Institutions (Section 7) Liability for Failure to File Suspicious Transaction Report and for Providing False Information (Section 33) Disclosure of Information (Section 34) [Tipping Off] Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations for Banks/DFIs Issued By State Bank of Pakistan (Revised and Issued on 13 September 2012) KNOW YOUR CUSTOMER KNOW YOUR CUSTOMER GUIDELINES Customer Profiling Controls and Precautions Customer Acceptance and Identification Type of Customers NBP will not accept Risk Assessment Review of High Risk Accounts General Principle Completion of Account Opening Requirements Customer Identity Verification Timing of Verification Discrepancies Uncovered During Identity Verification Ongoing Monitoring of Accounts Record Keeping TRANSACTION MONITORING TRANSACTION REPORTING Suspicious Transactions Defined... 36
3 7.2. Maintenance of Suspicious Transactions Register Reporting Of Suspicious Transactions Suspicious Transaction Report Flow Liability for Failure to File Suspicious Transaction Report Currency Transaction Reporting Filing of Currency Transaction Report Confidentiality of STR and CTR / Tipping Off Retention of Records Related to STR and CTR REMITTANCE TRANSACTIONS (INWARD/OUTWARD) SWIFT Message Type for Handling Outward Remittances SWIFT Message MT SWIFT Message for Cover Payments (MT 202 COV) CORRESPONDENT BANKING Correspondent Banking Client s Domicile Correspondent Banking Client s Business and Customer Base FOREIGN BRANCHES AND SUBSIDIARIES STAFF TRAINING EFFECTIVE DATE ANNEXURES ANNEXURE-I ANNEXURE-II ANNEXURE III ANNEXURE-IV ANNEXURE-V ANNEXURE-VI ANNEXURE-VII ANNEXURE-VIII ANNEXURE-IX ANNEXURE-X... 70
4 1 Compliance Group Document owner Compliance Group Version Control Version Number 03 Release Date 4 th March 2010 Revised Version Number 04 Revision / Amendment Date Availability Intranet and PDF copies Next Review Date This Procedure Manual will be subject to review on need basis. If there is no change in the KYC/AML/CFT procedure manual within one year, a note will be moved to renew the manual with no change. Instruction Circulars concerning AML/KYC/CFT issued by the Bank or the Regulatory Authorities from time to time shall become integral part of this manual. This Manual shall be available on intranet and shall be forwarded to Regional Heads and Compliance Officers to make sure its availability and thorough understanding at all the Branches. In addition, this Manual is to be distributed to the following persons, groups/ divisions **; Distribution List S. No. Group / Division 1 President 2 All Group Chiefs/ Divisional Heads 3 All Regional Chief Executive and Country Heads 4 All Regional Heads & Regional Compliance Officer 5 All Branch Managers 6 All Country Compliance & Money Laundering Prevention Officer (CC & MLPO) and all Principal staff colleges **This is a Bank-wide procedure manual that is to be adopted and followed across the Bank including Islamic Banking.
5 2 ABBREVIATIONS AOF ARC BBO BCO BM CAOP CDD CFT CIF CNIC CTR EBS EDD EU E-HRMC FATF FMU IBT NADRA NEC NICOP OFAC PEP POC RMA SBP SDD SNIC SSC STR SWIFT UN UNSC Account Opening Form Alien Registration Card Branch Back Office Branch Compliance Officer Branch Manager Centralized Account Opening Portal Customer Due Diligence Combating the Financing of Terrorism Customer Information File Computerized National Identity Card Cash Transaction Report Electronic Banking System Enhanced Due Diligence European Union Electronic Home Remittance Monitoring Cell Financial Action Task Force Financial Monitoring Unit Inter Branch Transactions National Database and Registration Authority National Executive Committee National Identity Card for Overseas Pakistanis Office of the Foreign Assets Control Politically Exposed Persons Pakistan Origin Card Relationship Management Application State Bank of Pakistan Simple Due Diligence Smart National Identity Card Specimen Signature Card Suspicious Transaction Report Society for Worldwide Interbank Financial Telecommunication United Nations United Nations Security Council
6 3 1. PREAMBLE Pakistan s Central Bank (State Bank of Pakistan) has issued Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations on September 13, 2012, emphasizing upon: Prevention of criminal use of banking channels for the purpose of Money Laundering and other unlawful trades. To ensure that a proper Procedure Manual framework on Know Your Customer and Anti- Money Laundering Measures is put in place, and To follow certain customer identification processes for opening of accounts and monitoring transactions of suspicious nature, keeping in view the possibility of use of money through these accounts for criminal and other unlawful purposes. All the measures for Anti-Money Laundering and Combating the Financing of Terrorism are governed by Anti Money Laundering Act 2010 which was enforced on March 27, 2010.
7 4 2. INTRODUCTION Modern Banking is offering a chain of products and services to customers worldwide round the clock. Globalized trade, state-of-the-art communication systems and computer technologies have made it possible for business and trade to diversify activities to meet global competitive edge feasibly and within predefined parameters and values. The rising desire to become financially sound, cutting corners and avoiding legitimate means of business and trade, created the urge for concealing funds and their movement. However, there are certain customers who are taking advantage of sophistication in banking technology and are carrying on unethical business i.e. Money Laundering. Money Laundering involves taking criminal proceeds and disguising their illegal source in anticipation of ultimately using the criminal proceeds to perform legal and illegal activities. Simply put, money laundering is the process of making dirty money look clean. According to The Financial Action Task Force (FATF), crimes such as illegal arms sales, narcotics trafficking, smuggling and other activities of organized crime can generate huge amounts of proceeds. Embezzlement, insider trading, bribery and computer fraud schemes can also produce large profits, creating the incentive to legitimize the ill-gotten gains through money laundering. The threat of trafficking in drugs, arms, refugees and the criminal activities of ransom, kidnapping, terrorism, etc. has strengthened and therefore spread black money to the various segments of society. Catering to the increasing money laundering menace, efforts are being made by various bodies to spread awareness of money laundering all around the globe. Regulatory institutions have necessitated the implementation of anti money laundering campaigns by central banks and financial institutions. The Governments all around the world have been involved in developing and enforcing regulations to put this illicit trade to end. Purpose of This Procedure Manual This Procedure Manual aims to provide procedural guidelines about the measures and individual legal obligations set out under The Financial Action Task Force (FATF) Recommendations, State Bank of Pakistan s Anti-Money Laundering/ Combating Financing of Terrorism Regulations as well as Customer Due Diligence for Banks and Core Principles for Effective Banking Supervision set out by Basel Committee on Banking Supervision while keeping intact the compliance of Anti-Money Laundering Act, The Procedure Manual also aims to aid the training of employees in spotting and reporting suspicious transactions. Through this Manual we aim to: 1. Put in place and implement a robust KYC process. 2. Describe the main symptoms of money laundering. 3. Understand the sources & Channels of money laundering. 4. Suggest controls & remedies.
8 5 5. Specify the requirements of State Bank regulations, 6. Describe the steps taken by National Bank of Pakistan to counter Money Laundering and Terrorist Financing. Procedure Manual Objectives To enable the bank to ensure that only legitimate and bonafide customers are accepted. To aid the bank in verifying the identity of customers using reliable and independent documentation. To enable the bank to monitor customers financial dealings. This would help the bank to mitigate the risk of its channels being used for Money Laundering. To enable bank in implementing processes to effectively manage the risks posed by customers trying to misuse facilities. To prevent criminal elements from using the bank for money laundering and terrorist financing activities. To put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws and regulations, and procedural guidelines. To take necessary steps to ensure that the relevant staff are adequately trained in KYC/AML/CFT procedures. Penalties Due to Non Compliance The Bank and its employees are expected to comply with legal requirements that also require reporting of suspicious transactions. Failure to comply could have serious implications for both the dealing officials and the Bank. This could include individual criminal penalties and disciplinary action. Role as a Prudent Banker Our role is to make sure that we all know, and follow at all times, the procedures which apply in each of the day-to-day operations we are involved in. These will include: Identifying customers thoroughly when opening accounts. Moving money around between accounts. Recording transactions. Reporting suspicious transactions. Communications with Employees There will be regular communication from the Compliance Head about AML/KYC issues to the staff of the bank.
9 6 3. APPLICABLE LAWS AND REGULATIONS The following laws and regulations deal with the issue of money laundering in Pakistan Anti-Money Laundering Act, 2010 Under the Anti-Money Laundering Act, 2010 the Government has established Financial Monitoring Unit (FMU) to properly monitor suspicious transactions for checking money laundering in Pakistan. The act of money laundering is a serious offence punishable under the provisions of the AML Act. Some of the important provisions extracted from AML Act, 2010 are mentioned below: Offence of Money Laundering (Section 3) A person shall be guilty of offence of money laundering, if the person: a) Acquires, converts, possesses or transfers property, knowing or having reason to believe that such property is proceeds of crime; or b) Conceals or disguise the nature, origin, location, disposition, movement or ownership of property, knowing or having reason to believe that such property is proceeds of crime. c) Holds or possesses on behalf of any other person, any property knowing or having reason to believe that such property is proceeds of crime; or d) Participates in associates, conspires to commit attempts to commit aid, abets, facilitates or counsels the commission of the acts Punishment for Money Laundering (Section 4) Whoever commits the offence of money laundering shall be punishable with rigorous imprisonment for a term which shall not be less than one year but may extend to ten years and shall also be liable to fine which may extend to one million rupees and shall also be liable to forfeiture of property involved in the money laundering, provided that the aforesaid fine may extend to five million rupees. In case of a company, every director, officer or employee of the company, found guilty under this section, shall also be punishable under this section Procedure and Manner of Furnishing Information by Financial Institutions (Section 7) Every financial institution shall file with the Financial Monitoring Unit (FMU), to the extent and in the manner prescribed by the FMU, Suspicious Transaction Report, conducted or attempted by, at or through that financial institution if the financial institution knows, suspects, or has reason to suspect that the transaction or a pattern of transaction of which it is a part: a) Involves funds derived from illegal activities or is intended or conducted in order to hide or disguise proceeds of crime; b) Is designed to evade any requirements of this section; or c) Has no apparent lawful purpose after examining the available facts, including the background and possible purpose of the transaction or involves financing of terrorism.
10 7 Provided that Suspicious Transaction Report shall be filed by the financial institution or reporting entity with the FMU immediately but, not later than seven working days after forming that suspicion. CTRs (Cash Transaction Report) on cash transactions exceeding Rs. 2.5 million shall be filed with FMU immediately but not later than seven working days, after the respective currency transaction. Every reporting entity shall keep and maintain a record of all transaction related to Suspicious Transactions Report and CTRs filed by it for a period of at least five years after the reporting date of transaction Liability for Failure to File Suspicious Transaction Report and for Providing False Information (Section 33) a) Whoever willfully fails to comply with the suspicious transaction reporting requirement or gives false information shall be liable for imprisonment for a term which may extend to three years or with fine which may extend to one hundred thousand rupees or both. b) In the case of conviction of a reporting entity, the concern regulatory authority may also revoke its license or take such other administrative action, as it deems appropriate Disclosure of Information (Section 34) [Tipping Off] a) The directors, officers, employees and agents of any reporting entity financial institution, non-financial business or profession or intermediary which reports a suspicious transaction or cash transaction pursuant to this law or any other authority, are prohibited from disclosing directly or indirectly to any person involved in the transaction that the transaction has been reported. b) A violation of (a) is a criminal offence and shall be punishable by a maximum of three years imprisonment or a fine which may extent to five hundred thousand or both. c) Any confidential information furnished by a financial institution, non-financial business and profession, intermediary or any other person under or pursuant to the provisions of this AML Act, shall, as far as possible, be kept confidential by the Financial Management Unit (FMU), investigation agency or officer as the case may be.
11 Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations for Banks/DFIs Issued By State Bank of Pakistan (Revised and Issued on 13 September 2012) State Bank of Pakistan has issued the following regulations on anti-money laundering and combating the financing for terrorism. R-1 Customer Due Diligence R-2 - Correspondent Banking R-3 Wire Transfers / Fund Transfers R-4 Reporting of Transactions (STRs/CTRs) R-5 Record Keeping R-6 Internal Controls, Policies, Compliance, Audit and Training
12 9 4. KNOW YOUR CUSTOMER The inadequacy or absence of KYC standards can subject banks to serious customer and counterparty risks, especially reputational, operational, legal and concentration risks. It is worth noting that all these risks are interrelated. However, any one of them can result in significant financial cost to banks (e.g. through the withdrawal of funds by depositors, the termination of inter-bank facilities, claims against the bank, investigation costs, asset seizures and freezing of assets and loan losses), along with considerable management time and energy to resolving problems that arise. Effectively devised KYC policy is the most important defense against the money launderers. While fulfilling legal requirements, the contents of regulatory requirements should be kept in view before establishing a customer/account opening relationship. Benefits of KYC The knowledge of the bank s customer base and business operations will also help the bank as under: a) Detect suspicious activity in a timely manner. b) Enable deeper analysis of potential and current clients. c) Promote compliance with all banking laws. d) Promote safe and sound banking practices. e) Minimize the risk of bank s channels being used for illicit activities. f) Protect the Bank s reputation & image. g) Bolster confidence among its customers, other banks, and bank regulators. h) Protect bank against negative legal consequences related to cooperating with entities supporting terrorism.
13 10 5. KNOW YOUR CUSTOMER GUIDELINES 5.1. Customer Profiling Customer profiling is a way to create a portrait of our customers to help make decisions concerning our service. Customers are broken down into groups of customers sharing similar goals and characteristics. Factors such as customers background, country of origin, public or high profile position, linked accounts, business activities or other risk indicators shall be considered while profiling customers. The main purpose of profiling is to understand our customer, particularly customer s source of wealth and the financial behavior in the account to highlight any unusual activities in his or her account/conduct. Every new customer shall be profiled in CAOP using judgment and information obtained through Customer Due Diligence (CDD)/KYC process. Change, if any, in customer profile (such as change of address, change in business, change in phone number, etc.) and their sources of funds should be recorded to maintain an updated knowledge about the customer and their businesses Controls and Precautions NBP will exercise sound controls, precautions and vigilance on KYC measures adopted to counter the money laundering menace. The Bank will develop and maintain necessary controls and precautions in its Banking Operations by different ways i.e. 1. Risk Assessment 2. Customer Acceptance and Identification. 3. On-Going Monitoring of Accounts. 4. Record Keeping Customer Acceptance and Identification Type of Customers NBP will not accept As a Policy, the Bank shall not deal / accept the following types of persons/entities as customer: The negative list shall include: Shell banks/companies Unregistered arms-related business Bearer share company
14 11 Accounts where the customer is acting on behalf of another customer to open an account. (The account shall be opened in the name of the person who is the beneficial owner of the funds in the account and not the benami/accounts with fictitious names)/ Anonymous or fictitious Accounts. Entities/persons appearing in OFAC/EU/UN lists and any other list recommended in each jurisdiction where NBP operates. Entities/persons appearing in negative/sanctioned lists. Proscribed entities and persons or those who are known for their association with such entities and persons, whether under the proscribed name or with a different name. Gamblers/Bookies Un-registered money changers/exchange companies. As per policy, bank will use the following sanction lists: 1. UN Sanctions list: List established and maintained by the Committee pursuant to resolutions 1267 (1999) and 1989 (2011) with respect to individuals, groups, undertakings and other entities associated with Al-Qaida. 2. Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List 3. EU-list 4. Sanction lists issued by the Ministry/regulators of the respective country where NBP Operates. 5. Banks Internal List Risk Assessment NBP Centralized Account Opening Portal (CAOP) Risk Rating Criteria 1 Keeping in view the inherent risks and in compliance with SBP s regulations, the Centralized Account Opening Portal is updated and aligned with SBP recommendations for risk categorization and ongoing monitoring. Accounts will be tagged as high-risk by CAOP on the basis of following criteria: 1 Instruction Circular No. 98 of 2012 ( CDD Measures for Establishing Business Relationship Ranking of Accounts Opened on the basis of KYC Risk Based Approach)
15 12 High Risk Customer /Categorization 1. Politically Exposed Persons (PEPs) PEP is an individual who has been entrusted with prominent public functions in the country, such as: Prominent public functions Government ministers, Senior civil servants, Senior judicial & military officials, Senior executives of state owned corporations, Senior political party officials Their close family members which include spouses, children, parents, siblings and may also include other blood relatives and relatives by marriage. Their closely associated persons which include close business colleagues, personal advisors/consultants of the politically exposed person as well as persons who are expected to benefit significantly by being close to such a person. The term PEP does not extend to middle ranking individuals in the specified categories. Risks Associated with PEPs There is always a possibility, especially in countries where corruption is widespread, that such persons abuse their public powers for their own illicit enrichment through the receipt of bribes, embezzlement, etc. Accepting and managing funds from corrupt PEPs will severely damage the bank s own reputation and can undermine public confidence in the ethical standards of an entire financial center. Since such cases usually receive extensive media attention and strong political reaction, even if the illegal origin of the assets is often difficult to prove. In addition, the bank may be subject to costly information requests and seizure orders from law enforcement or judicial authorities (including international mutual assistance procedures in criminal matters) and could be liable to actions for damages by the state concerned or the victims of a regime. Under certain circumstances, the bank and/or its officers and employees themselves can be exposed to charges of money laundering, if they know or should have known that the funds stemmed from corruption or other serious crimes. Course of Action 1. All PEPs and their close associates or family member s accounts will be treated as High Risk Accounts and accordingly will need approval of Compliance Group Head office. Compliance Group Head office will accord approval on the recommendations of Regional Head & Branch Manager (Who must conduct the Enhanced due diligence of all high risk customers before requesting for approval from head office). Furthermore, branch management must obtain additional information on the customer (occupation, volume of assets); intended nature of
16 13 the business relationship; reasons for intended or performed transactions; additional information on the sources of funds or sources of wealth of the customer; All High Risk Accounts will be subject to enhanced monitoring of business relations with the customer and annual reviews. There is an exemption from marking as high risks based on PEPs fields for following nature of accounts: Financial Institution UN and its affiliated agencies Central/ Provincial /Local Government Accounts Provident Fund-Government Public Limited-Government 2. Threshold of transactions (for High Risk Categorization) Nature of Accounts Threshold in Rs. (Per Month) Housewife (1M) Other-Non Govt 50m partnership-registered 50m Private Ltd. 100m Proprietor 50m Salaried - Accounts. 5m Self Employed (5M) Student 500,000 Unemployed 500,000 partnership-un Registered 50m Minor (1M) Joint Accounts (5M) Retired person (1M) Average No. of Cash Deposits (Monthly basis) Up to 5 6 to to to 100 Over 100 No. of (non-cash transactions) Transfer Deposits/ Remittances (Monthly) Up to 5 6 to to to 100 Over Country of Origin/Residence/Business dealings Whenever countries/branches belonging to high risk list are selected from List of values defined in the (CAOP) module, account will be marked as high risk each time the record is committed.
17 14 High risk countries can be derived from: FATF identified high risk & non cooperative jurisdictions. (this list will be subject to change) Customers with place of birth, nationality or doing business with the following FATF identified High Risk & Non cooperative Jurisdictions will be marked as High Risk.(Minus Pakistan) Iran Democratic People s Republic of Korea (DPRK) Ecuador Ethiopia Indonesia Kenya Myanmar São Tomé and Príncipe Syria Tanzania Turkey Vietnam Yemen High Risk Branches: Following border area branches will be marked as high risk: S. No REGION BRANCH BRANCH CODE 1 Mirpur AK Takia Kohwan Goi Samahni Karela Majhan Lehri Athmuqam Chinnari Leepa Valley Kahuta Muzaffarabad AK Kailler Khurshidabad 1806 Kundal Shahi 0693 Gogdar Abbaspur Hajira Dhani Bombian Gilgit Sost Lahore East Main Branch Kasur Mardan Inayat Kaley Peshawar Khar Torkham Jamrud Bara Zargari Kacahi Shabqadar
18 15 7 D.I. Khan Parachinar Wanna Miran Shah Sadda Quetta Chaman Gawadar Taftan 1080 However, following types of customers will be exempt: Financial Institution UN and its affiliated agencies Internationally recognized NGO Central/ Provincial /local Government Accounts Provident Fund-Government Public Limited-Government Pensioners Staff /Employee Basic Banking Account holders Salary Accounts Accounts with intended turnover of less than 1M a month 4. Nature of Business Account will be marked as High Risk when following fields are selected in Does your Customer deal in field given in Business employment details tab Centralized Account Opening Portal (CAOP). High Risk accounts: For all High Risk accounts approval from Compliance Group Head office will be required. Compliance Group Head office will accord approval on the recommendations of Regional Head & Branch Manager (Who must conduct the Enhanced due diligence of all high risk customers before requesting for approval from head office). Following entities/customers will be high risk customer. FX(Exchange Company) Approved from SECP and SBP licensed only Religious Organization NGOs NPO Hospitals Madrasas Charitable organizations Trust Club Society Association Political Parties Accounts Embassies/Diplomat missions
19 16 Politicians PEPS (as defined in PEP definition) Local /foreign Diplomat Hotel /Restaurant Cinema/Theater Cash Based Business in high value items (Artifacts/Antiques, Diamonds, Art dealer, Precious Metals/Stones) Carpet Dealer Unlisted Real Estate Company/ Property dealers/ Real Estate Agents Travel Agent Transporters/Automobile dealer Jewelers Art Gallery 5. Age of Business In case the age of business is less than the six months, the following nature of accounts will be marked as high risk each time the record is updated: Self Employed Proprietor Partnership-Unregistered or Registered Review of High Risk Accounts Frequency of updating CIF to update customer data is one (1) year for accounts marked as "High Risk" whereas it is three (3) years for accounts marked as "Low Risk". 2 Branch Manager shall obtain the list of high risk accounts on bi-annual basis. Customer shall be contacted on telephone by relevant Branch Managers to reaffirm information uploaded in the CAOP CIF. In case, customer is not contactable on the numbers available, letter shall be written to the customer asking for any change in his/her contact information. In case of Return Mail, the account shall be debit blocked, under advice of Compliance Group. (Responsibility Branch Management) The review shall be completed within 30 days from the date it falls due. The review shall be entered in the relevant section in the CAOP CIF/KYC. Comments shall be mentioned giving brief details of changes made and reasons for the change, as appropriate. During the review exercise, account activity of the customer will also be reviewed by the Branch Manager. The Branch Manager will take a printout of the account activity and review transactions and match the same with the details as given in the CAOP-KYC/CIF. If the transactions do not match with KYC profile of the customer (for instance turnover of transactions is far more than given in transaction profile in KYC or customer is receiving money from countries not mentioned by him in the KYC), an explanation will be solicited from 2 Instruction Circular No. 36 of 2013 (EBS Based Account Opening Data Migration to CAOP After Required Data Cleansing Exercise)
20 17 the customer. If the explanation is not satisfactory, transaction / transactions in question will be escalated to Compliance on Suspicious Transaction Report. However, if the Branch Manager decides that the explanation given by the customer is plausible; customer profile shall be updated and authorized by Branch manager for the changes. Reason for changes shall be mentioned. The statement of account with any comments/annotations shall also be kept on record as audit evidence of the monitoring activity. Approval of High Risk Accounts: Approval of High Risk Accounts will be accorded by the Compliance Group Head Office on the recommendations of the Branch Manager and Regional Head/ (Business head in case of Islamic Banking Branches). Approval should be sought through communication to improve the turnaround time and to keep the Question Answer record intact in the mail. For getting approval from Head Office, should be sent to: and General Principle Bank will not open anonymous accounts or accounts in obviously fictitious names. It is the requirement of laws, regulations, agreements between supervisory authorities and bank or by self-regulatory agreements among other banks to identify, on the basis of an official or other reliable document, and record the identity of clients, either occasional or usual, when establishing business relations or conducting transactions Completion of Account Opening Requirements 3 Opening of a Bank Account is the first steps towards establishment of a Banker-Customer relationship with a prospective client. In the backdrop of rising concerns over the issue of financial institutions vulnerability against the menace of money laundering and terrorism financing, the process of opening of an account has become a highly sensitive activity where the Bank has to ensure for minimizing operational and reputational risks exposure due to failure of detecting true identity and ownership of the account, source of income / funds, tracking of transactions of suspicious nature and possible / potential linkage of accounts / transactions to individuals/entities which are either in the UNSC sanctions list or proscribed under Country s own law such as Anti-Money Laundering Act. Account Opening Process will stay the same as mentioned in Instruction Circular No. 106 of Centralized Account Opening Portal (CAOP). 1. The BCO will review the account against the documents gathered by Account Opening Officer. Further he will also ensure that the Names / Title of Account / Names of 3 Instruction Circular No. 106 of Centralized Account Opening Portal (CAOP)