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The Board Directors of BRAC Bank views money laundering prevention as an integral part of the Bank's risk management strategy and not simply as a stand alone requirement that is being imposed by the legislation. Money laundering prevention is not viewed in isolation from Bank's other business systems and needs.
In recognition of the fact that financial institutions are particularly vulnerable to money launderers the BRAC Bank Board has developed a policy against which it will assess the adequacy of the internal controls and procedures to counter money laundering.
The policy reflects the Board of Directors commitment to comply with the Money laundering Prevention Act 2002, Bangladesh Bank Instructions and other related local and international regulations. It spells out senior management's responsibility in Anti Money Laundering Compliance and develops awareness at all levels of the Bank regarding the importance of the Bank's Anti Money Laundering Strategy.
The policy includes the development of
KYC policy /procedures before opening new accounts
Monitoring existing accounts for unusual or suspicious activities
Information flows
Risk classification
Reporting suspicious transactions
Hiring and training employees
It includes a description of the roles of the Anti Money Laundering Compliance Officers. It also emphasizes the responsibility of every employee to protect the Bank from exploitation by money launderers and describing the consequence of non-compliance with the applicable laws and the Bank's policy, including the criminal, civil and disciplinary penalties and reputation harm that could ensue from any association with money laundering activity.
The Board of Directors has approved a KYC policy for the Bank. The guiding principle of KYC is - Do business with reputable customers who are involved in legitimate business activities and whose income and wealth are derived from legitimate business.
The KYC policy includes the following:
Customer Acceptance criterion- Interview the customer by Bank Official and review of customer background, profession etc.
Customer Rejection Criterion- Interview the customer by Bank Official and review of customer background, profession etc.
Documents required for Individual /Corporate Account Open -for identification the customer
Address Verification-supporting documents or physical verification
Transaction Profile etc.-Based on customer source of income
For monitoring the customer transaction and reporting to the concerned department designated officials are assigned as follows:
Branch Anti Money Laundering Compliance Officer (BAMLCO): at Branch for reporting head office
Chief Anti Money Laundering Compliance Officer (CAMLCO): at Head Office for reporting to Bangladesh Bank
The Monitoring Systems
Cash transaction amounting BDT 3.00 lac and above (System generated report) is reviewed by BAMLCO daily
Transaction amount exceeding Estimated Transaction Profile (System generated report) is reviewed by BAMLCO monthly
Reporting System
If any transaction/customer activity is detected as suspicious or unusual the detecting officer reports it to BAMLCO with reason for suspicion
BAMLCO will review the suspicious report and put his/her comment. If s/he (BAMLCO) deems it as a suspicious s/he will forward to CAMLCO with his/her comment
CAMLCO will review the report forwarded by BAMLCO and put his/her comment. If s/he (CAMLCO) deems it as a suspicious s/he will forward to Bangladesh Bank (Central Bank) with his/her comment
Periodical Return
In addition to the immediate report of suspicious transactions, the following returns are to be submitted to Bangladesh Bank:
Monthly: Cash Transaction Report (CTR) amounting BDT 5.00 lac or more in a day Suspicious Transaction Report(STR) from CTR
Bi monthly: Transaction Amount BDT 1.00 crore or above in Non Resident Account in a period of 6 months (Statement-2) Significant Unusual Transaction Report (Statement-3)
Quarterly: Consolidated statement for the reports during the quarter (Appendix Gha: ML Circular -2)
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