2. Functional Organogram of the Anti-Money Laundering Division of EXIM Bank.
Deputy Chief Anti Money Laundering Compliance Officer (DCAMLCO)
Conduct inspection as per
requirement of the Central
Compliance Unit (CCU)
+
Collection of report from thebranches on monthly, bi-
monthly and quarterly basis
+
Collection of replies regarding
enquiries of regulators within
the stipulated time
J
Preparation of schedule fortraining/norkshop
throughout the wfiole year
JInvestigation of SuspiciousTransaction Report (STR)
forwarded from Branches
Placing he report of STRbefore top management
for perusal and decision
Compilation of report of thebranches for onward submission
to Bangladesh Bank
Collecting CashTransaction Report (CTR)
from the Branches
I
I
IScrutinizing the Cash Transaction
Report reported by the branches forsubmission to Bangladesh Bank
+
Anangement of CentralCompliance Unit (CCU)
meeting on monthly basis
Invitation of guest
lecfurerc from
Bangladesh Bank
Review the compliance report ofBranch inspection conducting by
ICCD (lndependent TestingProcedures)
Anangement of training forthe officials of the Bank at
EXIM Bank Training &Research Academy or
regional basis
t
3. General lnformation:
3.1
3.2
3.3
The Head of Anti-Money Laundering Division (Deputy CAMLCO) reports it's all activities to DeputyManaging Director & CAMLCO, which has subsequently been informed to the Managing Director &cEo.The AML Policy of EXIM Bank has been approved by the Board of Directors and the same is beingupdated as and when required and in-case of any changes / modification brought by the regulators.
The AML issues of EXIM Bank are escalated as per flowchart:Branch Report ) Anti-Money Laundering Division ) Central Compliance Unit (CCU) ) ManagingDirector and CEO ) The Board Risk Management Committee (Monthly & Quarterly basis).
Summary report of "Self Assessment" (conducted by Branch) and "lndependent TestingProcedures" (conducted by ICCD) are being placed before Central Compliance Unit (CCU) of thebank. The key issues/ summary of AML reports are also placed to the Board Risk ManagementCommittee quarterly or as and when it's meeting takes place.
Workshops/Training Programs for AMUCTF awareness are being organized on regular basis for allExecutive/Officers of the bank. The trainers (in-house, external or from Central Bank) conducVdemonstrate their workshops/training materials using multimedia presentation for effective/successful communication among the participants of the training programs. Following issues areconsidered for organizi n g a training/workshop prog ramme:-
3.5.1 SelecVnominate participants from functional areas covering from Officers to Executives.
3.5.2 Cover all national and international sanctions / issues in the programs by illustration, casestudy, examples, etc. so that awareness can be developed among the participants onimpacts of the issues in their day to day operations.
3.5.3 Newly recruited employees are also brought under AML Training programs during theirorientation / foundation training.
3.5.4 All abstracts or curriculum of the training programs are being prepared targeting to achievethe objectives of the bank.
3.5.5 Evaluation of courses, trainers and participants are being done to evaluate the success ofthe programs.
For development of AMUCTF awareness, Anti-Money Laundering Division has been arrangingdaylong Workshops on "Prevention of Money Laundering and Combating Terrorist Financing" inparticipation of the officials of different branches. There were 632 participants in the said workshopsduring the year 2013. In 2014 the participants were 277 and it continues. In conducting the daylongtraining/workshop program EXIM Bank covers the following areas:
3.6.1 Definition of ML & TF, Causes & Consequences, Steps and Techniques, InternationalStandards, Legal Framework, Organizational Framework, Role of BFIU and ACC.
3.6.2 Money Laundering Prevention Act (MLPA)-2012, Anti Terrorism Act (ATA)-2009, AntiTerrorism (amendmentl Act-2012 & 2013 and FATF Recommendations.
3.6.4 Case study on: KYC, Risk Grading, Transaction Monitoring & TP, Self Assessment,Independent Testing Procedures, STR.
3.4
3.5
3.6
4. AML Examinations and Audit
4.1 Self Assessment:
As per section 6.5 of Guidance Notes on Prevention of Money Laundering provided by Bangladesh Bank,each branch of EXIM bank determines their position according to banks and National Money Launderingpolicy on the basis of the detailed "Self Assessment" answers against the questionnaire stated below:
Questionnaire Branch's opinion
1. What are the total no. of executive /officers of the Branch (as perdesignation)? What percentage ofexecutives / officers receivedinstitutional training?
2. Does the executives / officersaware about the Anti MoneyLaundering policies of the bank,procedures and program andBangladesh Bank guidelines withnational policies?
What is the process of evaluation?
3. Does meeting take place in thebranches at regular interval?
lf taken, at what interval? Does theagenda distribute to all for their concern?What important decisions taken in themeeting? How the decisions of themeeting complied?
4. Does the customer informationtaken satisfactorily regarding openingof individual, corporate and othersaccount (i.e. Current , Savings, S.T.D,Fixed Deposit, Special Scheme, FC,RFCD, NFCD)
How is the correctness of the informationevaluated? How is the informationpreserved in the Branch?
5. Does the branch classify theircustomer according to risk?
How much high risk account opened tillthe date? What are the steps taken by theBranch to open and maintain suchaccount?
6. Does the process of completion ofKYC procedures.. regarding accountopened before 30'n April 2OO2?
What is the percentage of completion ofKYC procedures by the Branch? What arethe steps taken by the branch to completethe matter by January, 2010?
7. Does the Branch updated KYCprofile by re-examining at fixedinterval?
How the examination completed and atwhat interval?
8. Does the Branch follow KYCprocedure regarding floating / walk-in-customer?
How the procedure completed?
9. Does the information of depositorand withdrawer taken regarding OnlineBanking according to the instruction ofBangladesh Bank?
How this monitoring proc€ss completed?
Questionnaire Branch's opinion
10. Does the Branch monitor thetransaction of the customer with TPaccording to risk gradation ortransaction above the fixed limit?
How is it taken?
11. How much Suspicious Transaction(STR) is detected by the Branch tilldate?
What kind of process introduced by thebranch to detect STR?
12. Does the Branch introduce anyprocess to detect structuring?
How the structuring is detected?
13. ls CTR sending regularly andcorrectly by the Branch to the CentralCompliance Unit?
How the correctness of the information isevaluated?
14. Does the Branch preserve MLPAct, circular, training record, statementand other AML related mattersseparately? Does the branch supplythe copy of Act and circular to allexecutives / officers?
lf done then write 'Yes' or if not done thenwrite'No'.
15. Does the Branch maintain anyPEPs account as per MoneyLaundering Prevention Circular-1 4?
lf yes then what kind of caution followedto open and maintain this account?
16. Were the weakness / irregularitiesmentioned in the inspection report ofHead office and Bangladesh Bankcomplied.
lf not complied, what are the drawbacks?
17. Does the branch monitor foreignremittance with other inward andoutward remittance?
How is it done?
Name, signature, date and seal of Branch AntiMoney Laundering Compliance officer
Name, signature date and seal of Branch Manager
N.B: All branches of EXIM Bank conduct the above evaluation process "Self Assessment" regularly andkeep its' records in the branch and also send the same to Anti-Money Laundering Division, HeadOffice on quarterly basis. After receiving quarterly report from branches, Anti-Money LaunderingDivision places the same to Central Compliance Unit(CCU) for perusal and discussion over thecompliance status. After that Anti-Money Laundering Division prepares a report on half yearly basisfor placing before Managing Director & CEO for his perusal and necessary instruction and finatlysubmits the report to Bangladesh Bank within 60 days of ending the half year.
Frequent & repeated checking & monitoring on the above issues and due/proper address/actions forcompliances, the AMUCTF activities of the branches have been achieved at "Satisfactory" ratinglevel.
4.2 lndependent Testing Procedures
As per section 6.6 of Guidance Notes on Prevention of Money Laundering provided by Bangladesh Bank,our Internal Control and Compliance Division (ICCD) evaluates branches Anti-Money Launderingcompliance status. Internal AML audit is being done by Internal Control & Compliance Division (ICCD) atevery branch through "lndependent Testing Procedures" as prescribed by the central Bank at lest once inevery year.
The questionnaire (lndependent Testing Procedures) of internalAML Audit are as follows:-
slNo.
Area Questionnaire Tools of verification Score Scoreobtained
1. BranchCompliance
Unit
1. whether branch has deployedan experienced and seniorofficer as Branch Anti-MoneyLaundering Compliance Officer(BAMLCO)
Check office order. BranchManager / 2nd officer or 3years experience as Head ofGeneral Banking should benominated as BAMLCO.
3
2. Does he receive any trainingregarding Anti MoneyLaundering activities in the lasttwo years? Does he awaresufficiently regarding AML law,Gircular and Guidance Note?
Verify on the basis of interviewand documents.
5
3. Does BAMLCO follow up andmonitor effectively at a regularinterval that Anti MoneyLaundering activities of thebranch complied meticulously.
Veriff the procedure andprocess of monitoring andfollow up by BAMLCO.
5
4. Does it sufficient that themeasure taken by the BAMLCOto monitor all accounts includingHigh Risk account?
Verify the process of monitorof all accounts including HighRisk account by BAMLCO.
3
5. Does the branch preserve anyPEPs account as per MoneyLaundering Prevention Circularno.-14?
Verify whether due diligence isfollowed as per AML Circularno.-14 to open and maintainsuch account.
3
2. Knowledge ofofficer/Staff
regarding AMLactivities
1. How many officer / Staffreceived training regarding AMLactivities?
It will be considered assatisfactory level, if thepercentage will stand 100.
5
2. Whether all officer / staffaware regarding bank's AntiMoney Laundering policy,procedure, program and nationalpolicy with guidelines ofBangladesh Bank?
Evaluate by taking interview atleast 20o/o officer of thebranch.
3
3. Whether a meeting took placepresided by the Branch Managerwith all officials at regular intervalto evaluate AML activities of thebranch?
Collect and veriff the minutesof that meeting.
5
slNo.
Area Questionnaire Tools of verification Score Scoreobtained
3. Know YourCustomer
(KYc)
KYC of Account Holder
1. Whether KYC is takenproperly on individual, corporateand others account? How is itverified and whether it isproperly recorded or not?
Examine 23 accounts of eachtype. In that case evaluatewhether the instruction of AMLcircular and section 5.6-5.13 ofGuidance Notes is complied ornot.
4
2. Does the branch classify theircustomer according to risk?
3. Whether additionalinformation is collected for HighRisk account?
Examine Whether the process ofclassification is in accordance toAML circular or not.
Examine what types ofinformation taken in this regardand are they sufficient?
4
J
4. What is the progress ofcollecting KYC of the accountopened on or before 3dh April,2002?
Whether it will be completedbefore 31"t January,2O1O as perAML circular 06 or not andevaluate on the basis of Branch'sprogress.
)
5. Does the branch updatedcustomer's KYC Profile at aregular interval?
Evaluate on the basis of KYCProfile reexamination andupdating process.
5
lC/C of Floating Customer
1. Does the branch follow KYCprocedure of floating / walk incustomer (DD, TT, onlinedeposit etc.)?
Collecting information is whetherrelated to AML circular, circularletter; it will be justified.
aJ
4. TransactionProfile
obtaining andmonitoring
1. Does the branch monitoractual transaction with declaredtransaction of the customer?
Minimum 10 (Ten) accountsstatement to be examined toveriff the process.
5
2. Does the branch monitorinward and outward remittanceincluding foreign rem ittance?
Examine at least ten (10)relevant cases and RFGD A/C.NFCD A/C of huge transaction.
5
3. Does the branch review andupdate TP at a regular interval.
Examine such 10 samples of TPreviewed and updated andevaluate the effectiveness.
5
5. SuspiciousTransaction
Report (STR)and Cash
TransactionReport (CTR)
1. Does all the employees of thebranch are aware aboutSuspicious Transaction Report(srR)?
Examine the concept regardingthis issue of the branchemployee under Chapter Vlll ofGuidance Notes.
aJ
2. How many SuspiciousTransaction Report (STR)reported to BAMLCO / CCU?
Examine the documents. lf noSTR is forwarded to BAMLCO/CCU, it will be considered asdissatisfactory. Evaluate,whether any process developedby the branch to detect STR.
aJ
SINo.
Area Questionnaire Tools of verification Score Scoreobtained
3. Does Cash TransactionReport (CTR) submitted by thebranch properly and accurately?
Examine documents in thisregard. Examine cash registerfor at least one month andevaluate the correctness of theCTR submitted for that month.
4
4. Does the branch develop anyprocess or procedure to detectStructuring as done by the clientto avoid CTR?
Evaluate by checking the branchaction in this regard.
4
6. Statementsubmitted to
ccu
1. How many statementssubmitted by the branch toCCU? Does the branchsubmitted statements timely?
Check documents and paper inthis regard. lf not submitted allstatements or make delay tosubmit, it will be treated asdissatisfactory.
3
2. Evaluation will be made onsample basis that theinformation included in thestatement is fully correct andcomplied.
Examine the documents, if theinformation is not fully complied itwill be treated as dissatisfactory.
2
7. Recordkeeping
'l. ls there any system topreserve customer information(KYC) and transaction relatedrecord according to MoneyLaundering Prevention Act-200925 (a, b), Regulatory Authorityand Bank's own policy.
Check at least 5 (five) close A/Cand veriff if the branch follow theguidelines of AML Act-2009,section 25 (a, b) in this regard.
2
2. Does the branch provideinformation as desired byregulatory authority or CCU?
Check documents. lf informationis not provided in time andaccurately, it will be treated asdissatisfactory.
2
8. Overallactivities of the
branchregarding AML
activities
'l. Does the branch managerplay proper role to implementAML program in branch thoughhe is not a BAMLCO?
Check the contents of minutes inthe meeting held at branch andtake interview of BranchManager.
1
2. Does the branch take anymeasures to rectiff theweaknesses and irregularitiesfound in the previous intervaland external audit report underAML program?
Check the previous audit reportand evaluate the steps taken torectiff the irregularities.
3
3. Whether overall performanceof the branch is satisfactory ornot?
Evaluate overall activities inaccordance to the AML activitiesby the branch.
2
Total 100
Overall performance score and rating of the branch:
Score Rating
91-100 Very Good
71-90 Good
56-70 Satisfactory
41-55 Marginal
40 and below Dissatisfactory
Internal Control and Compliance Division (ICCD) of EXIM Bank conducts the inspection according to theabove "lndependent Testing Procedures" questionnaire and comments with the rating as per securedscore. Thereafter ICCD sends a report to Anti-Money Laundering Division, Head Office on quarterly basis.After receiving quarterly report from ICCD, Anti-Money Laundering Division places the same to CentralCompliance Unit (CCU) for perusal and discussion over the compliance status. After that Anti-MoneyLaundering Division prepares a report on half yearly basis for placing before Managing Director & CEO forhis perusal and necessary instruction and finally submits the report to Bangladesh Bank within 60 days ofending the half year.
EXIM Bank's all branches have secured the score ranging 65-70 with "Satisfactory" ratings. There is nobranch having "Marginal" rating in EXIM Bank. Frequent & repeated checking & monitoring on the aboveissues and due/proper address/actions for compliances, the AMUCTF activities of the branches have beenachieved at'Satisfactory" rating level.
The overallAML activities of EXIM Bank is "Satisfactory" and appreciated by the regulators.
4.3 Last regulatory examination was made on 1210212013 (by central Bank)
4.4 Findings andlor corrective actions result frorn the most recent examination are as follows:-
4.4.1 Yearly announcement by the Managing Director & CEO of the Bank regarding prevention of moneylaundering to all the employees of the bank is being continued.
4.4.2 Regular updating of KYC of Correspondent Banks.
4.4.3 For more effectiveness of AMUCTF issues at branches, Transaction Monitoring with frequentinspection is being done by the AMLD and report to Central Compliance Unit of the bank.
4.4.4 Properly review 'Self Assessment" statement of branches and effective steps are being taken forbranches by the AMLD and report to Central Compliance Unit.
4.4.5 Instruction is being sent to branches by the AMLD, so that lapses not be repeated.
4.4.6 Arrange daylong TrainingMorkshop in participation of the officials of the branches who are yet toreceive any such formalTraining.
4.4.7 More importance is being given for AML TrainingMorkshop and evaluation after Training/Workshop
4.4.8 Updated information regarding AMUCTF is being communicated to all branches by the AMLD fromtime to time.
Customer Due Diligence:
Comply the minimum documentation requirements required for new clients: Copy of passporUNational lD Card/Driving License/Office lD CardMord Commissioner's CertincatJRny lD cardacceptable to the bank.
5.
5.1
5.2 ConducUEvaluate risk rating of all clients. The risk assessment made by using the Uniform l(YCProfile Form in which following seven risk categories are scored using a scale of 1 to 5 where scale4-5 denotes High Risk, 3- Medium and i-2 Low Risk:
5.2.1 Customer's Profession/Nature of the Business.
5.2.2 Net Worth of Customer.
5.2.3 Nature of Account.
5.2.4 Monthly expected amount of Transaction of the Account Holder.
5.2.5 Monthly expected Number of Transactions.
5.2.6 Monthly expected amount of Cash Transaction.
5.2.7 Monthly expected Number of Cash Transaction.
The risk scoring of less than 14 indicates "Low Risk" and equal or more than 14 indicates "HighRisk". The risk assessment scores are documented in the KYC Profile Form.
5.3 Volume of high risk Account is 1579 (up to June'2014).
5.4 All high risk clients including PEPs are subject to enhanced due diligence.
5.5 Customer Due Diligence/KYC information is updated at least annually.
6. Transaction Monitoring and Screening:
6.1 Transaction monitoring system is automated.
6.2 In-house automated system is developed for monitoring the transactions.
6.3 Automated system is available to find report generation when Customer declaration of Transaction
Profile limit exceeds.
6.4 Cash Transactions are incorporated into the automated system.
6.5 Monthly number of alert generated 15,OOO approximately.
6.6 Dedicated staffs are there to process alerts.
6.7 4 (four) SARs have been filed during the past years.
6.8 No Foreign currency transaction reports filed during the past years.
6'9 All procedures are in place to screen and prohibit transaction from entitles/countries that have
been sanctioned by the UN, OFAC or our Local Regulator.
6.10 Sanctions screening is being performed through in-house developed semi-automated software
system.
7. Other Information:
7.1 There is no instance of any negative news or regulatory enforcement actions as well as anyassociated corrective actions.
7.2 There is no changes in ownership or senior management in the past year.
l0
8. Special Risks:
8.1 We don't offer correspondent banking services to other bank's and we have no Vostro Account ofother banks at present as well. But we have Correspondent Relationship with 389 Banks in 106countries and we have regular on going KYC/AML process for all of them.
8.2 The risk management principles that the Bank uses in traditional operational areas and is beingapplied to assess and manage AML risk. A well developed risk assessment tools/tech techniqueassists in identifying the bank's AML risk profile. Understanding the risk profile enables the bank toapply appropriate risk management processes to the AML compliance program to mitigate risk.
8.3 Compliance is observed for MT202|MT202COV payment requirements at both checker/makerlevel.
8.4 There is no branch/subsidiary of EXIM Bank in sanction countries.
9. AdditionalComments:
9.1 Export lmport Bank of Bangladesh Limited is one of the compliant bank (lnternational standard) inrespect of AMUCTF compliance.
9.2 EXIM Bank Emphasises to develop it's all human resources knowledge base and well aware aboutstandard activities in respect of AMUCTF Laws/Rules/Regulations of home and abroad.
I, the undersigned, confirm to the best of my knowledge that the information provided in this call report iscorrect, accurate and presenting the status & effectiveness of Anti-Money Laundering & Anti TerroristFinancing activities of Export lmport Bank of Bangladesh Ltd.
Signature
Name
Designation
Date
Contact no.
E-mail
Deputy Managing Director & Chief Anti-Money Laundering Compliance Officer
