acleda bank aml 2009

POLICY AND PROCEDURE ON AML / CFT -1-

POLICY ON

ANTI-MONEY LAUNDERING ANDCOMBATING THE FINANCING OF TERRORISM

71- INTRODUCTION

� Money Laundering is the conversion or transfer of property, knowing that such property is the proceeds of offence, for the purpose of concealing or disguising the illicit origin of the property or of helping any person who is involved in the commission of the offence to evade the legal consequences of his or her action. � Financing of Terrorism shall mean the willful provision of financial or other services with the intention that such services be used or in the knowledge that they are or may be used, in full or in part, for the purpose of supporting terrorism, terrorist acts or terrorist organizations.Generally, the process of money laundering comprises three stages, during which there may be numerous transactions that could alert a bank to the money laundering activity:i- Placement : the physical disposal of benefits of the offence or criminal conduct. ii- Layering : the separation of benefits of the offence or criminal conduct from

their source by creating layers of financial transactions designed to disguise the audit trail.

iii- Integration : the provision of apparent legitimacy to benefits of the offence or criminal conduct. If the layering process succeeds, integration schemes place the laundered funds back into the economy so that they re-enter the financial system appearing as normal business funds.

2- BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING AND FINANCING OF TERRORISM

� The Law on Banking and Financial Institutions of 1999 � The Law on the Anti-Money Laundering and Combating the Financing of

Terrorism of March 24, 2007 � Prakas on Anti-Money Laundering and Combating the Financing of Terrorism

of May 30, 2008

To adhere to the Law on Anti-Money Laundering and Combating the Financing of Terrorism and the Prakas on Anti-Money Laundering and Combating the Financing of Terrorism, all management of ACLEDA Bank Plc shall develop, administer, and maintain the following system and procedures:

a)- A system of internal control to ensure ongoing compliance with the law and relevant regulations of National Bank of Cambodia (NBC).

b)- Independent testing of compliance.


Terrorism, all management of ACLEDA Bank Plc shall develop, administer, and maintain the following system and procedures:

a)- A system of internal control to ensure ongoing compliance with the law and relevant regulations of National Bank of Cambodia (NBC).

b)- Independent testing of compliance. c)- Daily coordinating and monitoring of compliance by a designated person and

relevant staffs. d)- Training program shall be provided to all new recruits before they start to work

for the bank and refresher courses shall be conducted two times per annum for front-line (Teller, Customer Service Officer, Credit Officer, Trade Finance Officer, and Sale Officer) or relevant staffs.

2.1- All personnel of the bank shall pay attention to the official customers' identification and other necessary relevant supporting documents.

2.2- Opening anonymous accounts and account in fictitious names shall be prohibited. Make sure that no customer is allowed to open or operate an anonymous account or an account in a fictitious, false or incorrect name.

2.3- Should not open account for or conduct business with a shell-company, which does not conduct any commercial activities or have any form of commercial presence in the country but are legal entities through which financial transactions may be conducted.

2.4- Report to the Financial Intelligence Unit for cash transactions exceeding USD 10,000.00 (or 40 million Riels or foreign currency equivalent), within 14 days of the date of transaction, referred to article 28 of Prakas on Anti-Money Laundering and Combating the Financing of Terrorism by National Bank of Cambodia of May 30, 2008.

2.5- To ensure an effective system of internal control, the management of the bank shall establish a comprehensive procedure which is the process of internal control implementation, including know your customer policy (KYC), checking and controlling the new account opening and its transactions, and reporting the suspicious transaction.

2.6- The bank's internal or external auditors must: � Attest the overall integrity and effectiveness of management systems and control

fully comply with the Law and Parkas of NBC. � Test transactions in all areas of the bank with emphasis on high risk areas,

products, and services. � Access adequacy of the bank's process for identifying suspicious activity

2.7- The bank must maintain recorded documents and copies of documents involved in all forms of transactions for at least 5 years after the date of transaction and the accounts have been closed or the business relations with customer have ended.

2.8- The bank management shall ensure that appropriate personnel including senior managements and all relevant staffs are trained in all aspect of the regulatory requirements of the Prakas of NBC, internal policy and procedure on Anti-Money Laundering and Combating the Financing of Terrorism.

2.9- All levels of the bank management and staffs are obligated to report all types of suspicious transactions and shall be required to keep confidentiality of any information obtained on suspected customers' transaction and record has been made.

3 - DESIGNATION OF PERSONNEL TO BE RESPONSIBLE FOR IMPLEMENTING THE POLICY AND PROCEDURE


3.1- The bank management shall designate a bank's Compliance Officer as senior management (referred to article 36 of Prakas on Anti-Money Laundering and Combating the Financing of Terrorism) to be responsible for implementing the policy and procedure including the following duties:

� Updating policy and procedure � Providing training to staffs � Independent carrying out daily checking, coordinating, and monitoring

throughout the bank network � Receiving all suspicious transactions report (SRTs) from the entire network of

ACLEDA Bank Plc within 24 hours and independently submitting the report to Financial Intelligence Unit of Cambodia if there is reasonable ground of suspicion

3.2- Compliance Officer is responsible for developing a system of internal control to ensure ongoing compliance while Internal Audit Division and Human Resource Division are respectively for testing the compliance with the policy and procedure, and training personnel referred to point "d" of point 2 above.

4- MONITORING AND UPDATING THE ACLEDA'S BLACK LIST

Compliance Officer shall be responsible for recording and updating the ACLEDA's Black List for the bank's use as a whole. The sources of the black list shall derive from NBC and independent research into the US Treasury (OFAC) and/or other necessary sources. The updated list must be disseminated in the timely manner to the entire bank network and the action must be taken to prevent money laundering and financing of terrorism.

(2)

OPERATING MANUAL ON AML / CFT -1- 1

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711 -- INTRODUCTIONINTRODUCTION

This operating manual is solely aimed at enhancing the full adherence and ensuring all domestic and international financial transactions of ACLEDA Bank Plc. are not involved in money laundering or financing of terrorism. More importantly, we can evade the regulatory sanctions, and maintain good reputation of the bank on a timely and due basis in a full compliance with the existing policies, and other related regulations.

� The Law on Banking and Financial Institutions of 1999 � The Law on the Anti-Money Laundering and Combating the Financing of

Terrorism of March 24, 2007 � Prakas on Anti-Money Laundering and Combating the Financing of

Terrorism of May 30, 2008 � ACLEDA Bank's policy on Anti-Money Laundering and Combating the

Financing of Terrorism approved by the Board of Directors on October 02, 2009.

To fully comply with the policies and relevant regulations, all personnel of ACLEDA Bank must follow and implement the following procedures on Anti-Money Laundering and Combating the Financing of Terrorism.

22 -- THE DEFINITION OF MONEY LAUNDERING AND TERRORIST THE DEFINITION OF MONEY LAUNDERING AND TERRORISTFINANCINGFINANCING� Money Laundering is the conversion or transfer of property, knowing that such property is the proceeds of offence, for the purpose of concealing or disguising the illicit origin of the property or of helping any person who is involved in the commission of the offence to evade the legal consequences of his or her action. � Financing of Terrorism shall mean the willful provision of financing or other services with the intention that such services be used or in the knowledge that they are or may be used, in full or in part, for the purpose of supporting terrorism, terrorist acts or terrorist organizations. Generally, the process of money laundering comprises three stages, during which there may be numerous transactions that could alert a bank to the money laundering activity: i- Placement : the physical disposal of benefits of the offence or criminal conduct; ii- Layering : the separation of benefits of the offence or criminal conduct from

their source by creating layers of financial transactions designed to disguise the audit trail;


iii- Integration : the provision of apparent legitimacy to benefits of the offence or criminal conduct. If the layering process succeeds, integration schemes place the laundered funds back into the economy so that they re-enter the financial system appearing to be legitimate business funds.

33 -- IMPLEMENTATION OF ANTI-MONEY LAUNDERING AND COMBATING IMPLEMENTATION OF ANTI-MONEY LAUNDERING AND COMBATINGTHE FINANCING OF TERRORISMTHE FINANCING OF TERRORISM

33..11-- CUSTOMER DUE DILIGENCE MEASURECUSTOMER DUE DILIGENCE MEASURESound KYC policies are essential for protecting the safety and the soundness

of bank integrity and as a critical element in the effective management of bank risks. Prior to establishing business relations, such as opening accounts, taking stocks, bonds or other securities into safe custody, granting safe-deposit facilities, wire transfer or engaging in any other business dealings, designated and/or relevant staffs shall require customers to furnish the official original photo identification, passport and/or other necessary documents. Those official identification documents can supply the general information pertaining to applicants as follows:

� Full Name � Permanent and mailing address, telephone number, fax or mail � Date of birth � Nature of the business / Occupation � Nationality

3.1.1- INDIVIDUAL CUSTOMERS

In establishing a business relationship with an individual customer designated and/or relevant staffs shall require the individual to furnish the original and make copies of one or more of the following documents:

� National identification card � Passport; or � Identity document preferably bearing a photograph of the customer, issued

by an official competent authority. Prior to opening a new account for non-residential customer who doesn't have

the permanent address in Cambodia, designated / relevant staffs shall require the following documents:

� Passport � Confirmation letter from the local competent authorities / rental contract to

prove his/her address / confirmation letter from their competent management if s/he works in Cambodia.

3.1.2- CORPORATE CUSTOMERS

In establishing a business relationship with a corporate customer registered in Cambodia, designated and/or relevant staffs shall require the company / business to furnish the original and make copies of at least the following documents:

� Memorandum / Article of Corporation / Partnership � Business Registration Certificate / Certificate of Authority � Identification of account holders


� Board of Directors' / Directors' Resolution � Identification document of Directors / Shareholders / Partners � Authorization letter for any person to represent the company / institution

� Designated and / or relevant staffs shall conduct a basic research or enquiry on the background of such company / business to ensure that it has not been, or is not in the process of being dissolved or wound-up and be aware of the purpose of the account opening.

� Designated and/or relevant staffs shall verify the identity of all signatures according to customer due diligence (CDD) for individual customers. When signatories change, attention should be taken to ensure that the identity of all current signatories has been verified.

� Before entering business relationship and opening a new account for companies, businesses or partnerships registered outside Cambodia, designated and/or relevant staffs shall:

� Require customers to provide the above comparable documents of customer registered in Cambodia. However, as different countries have varying standards of control, the originals or certified copies authenticated by notary public outside the country shall be used for verification. Attention should be paid to the origin of the documents and the background against which they are produced.

� Designated and / or relevant staffs that are responsible for opening new accounts for customers shall make enquiry about or be aware of the purpose of the account opening with ACLEDA Bank Plc located in Cambodia.

� Designated and/ or relevant staffs shall forward all relevant documents for account opening to Anti-Money Laundering (AML) Unit to clarify with Legal & Corporate Affair Division on the legality and appropriateness of the documentations. The AML Unit shall return the documents after they have been confirmed they are legitimate and complete by Compliance Officer and Legal & Corporate Affair Division, at Head Office.

� Where the customer or the owner of the controlling interest is a public company that is subject to regulate disclosure requirements i.e. a public company listed in a recognized stock exchange, it is not necessary to seek to identify and verify the identity of the shareholders of that public company.

� Bank competent management, designated and/or relevant staffs shall also understand the ownership and control structure of the corporate customers and determine the source of fund of the customer. This will assist bank in ascertaining any suspicion concerning the changes to the ownership or control structure and in developing the customer profile and expected activity through the company/business account.

3.1.3- BENEFICIAL OWNER

Designated or relevant staffs should conduct customer due diligence as stringent as the one imposed on individual customer when they suspect a transaction is conducted on behalf of a beneficial owner and not the customer who is conducting such transaction. Beneficial owner is the natural person (s) who ultimately owns or controls a customer and/or the person whose behalf a transaction is being conducted. It also incorporates those persons who exercise ultimate effective control over a legal person or arrangement.

3.1.4- NON-GOVERNMENT ORGANIZATION (NGO) AND FOUNDATION


In establishing a business relationship with a NGO or Foundation customer, designated and/or relevant staffs shall require the customers to furnish the original and make copies of at least the following documents:

� Memorandum / Article of NGO or Foundation � Authorized Letter of Functioning of organization � Identification of account holders � Board of Directors' / Directors' Resolution � Identification document of Directors � Authorization for any person to represent the institution / organization

� Designated / relevant staffs should require Non-government Organization or Foundation establishing business relationship to furnish the constitution document or other similar documents to ensure that it is properly constituted and registered.

� For non-government organization and foundation registered and based outside Cambodia, designated / relevant staffs shall require the customer to provide the authorization letter issued by Ministry of Foreign Affair and International Cooperation or competent authority in Cambodia.

� Designated and/or relevant staffs shall verify the identity of all signatures according to customer due diligence (CDD) for individual customers. When signatories change, attention should be taken to ensure that the identity of all current signatories has been verified.

� Designated/relevant staff should take steps to understand who control and makes decisions regarding the Non-Government Organization / Foundation, and the use of the funds.

3.1.5- TRUST AND NOMINEE ACCOUNTS

� Designated / relevant staffs need to establish whether the customer is acting on behalf of another person as trustee, nominee or agent.

� Designated / relevant staffs should ensure that customer due diligence requirements is completed for beneficial owner, when the trust or nominee account is established.

� Designated / relevant staffs should take reasonable measure to understand the ownership, control structures, the relationship among the relevant parties in handling a trust or nominee account, and obtain evidence of the identity of the settler, trustee, nominee, authorized signatories, persons exercising effective control and the beneficiary.

� Designated / relevant staffs require a written assurance from the trust or nominee that evidences of the identity of the beneficiaries has been obtained, recorded and retained, and that the trust or nominee is satisfied regarding the source of funds. In addition, identification information must be immediately available to bank upon request.

3.1.6- RELIANCE ON INTERMEDIARIES OR OTHER THIRD PARTIES FOR CUSTOMER DUE DILIGENCE OR INTRODUCED BUSINESS

� Designated / relevant staffs should be wary and ensure that they do not fall complacently and completely rely on the customer due diligence conducted by the intermediary or other third party because ultimate responsibility of customer due diligence always remains with the bank not the intermediary or third party.

� Designated / relevant staffs must be satisfied that the introducing intermediary / third party:


� Has carried out customer due diligence by identifying the customer and verify that identity using reliable, independent source of documents, data or information

� Has identified the beneficial owner and in respect of corporate customers understands the ownership and control structure of the customer

� Understands the purpose and nature of the business relationship � Has put in place a system to provide the bank with access to the

identification documents, data or other necessary documents upon request and without delay

3.1.7- NON-FACE TO FACE CUSTOMERS

For non-face to face customer, designated / relevant staffs shall require customers to provide identification / passport and other necessary documents pursuant to the customer due diligence measure for individual customers, cooperated entities, non-government organizations, and foundations. Authentication from the original copy should be made by notary public for the customer outside the country and local attorney at law or competent authority for the customer having originated in Cambodia.

3.1.8- CORRESPONDENT BANK AND RESPONDENT BANK

� Correspondent Bank: is a bank that regularly performs services for another financial institution usually located in another city or marketing area. For instance, ACLEDA Bank Plc opened a new nostro USD account with ABC Bank located in New York, U.S.A. Hence ABC Bank is the Correspondent Bank and ACLEDA Bank Plc is Respondent Bank.

Before establishing to open Nostro or Vostro Account and requesting / accepting the SWIFT Relationship Management Application (RMA) with Correspondent or Respondent bank outside Cambodia designated / or relevant staffs shall conduct the study research and satisfy the information gathered and ensure the threats of money laundering and financing of terrorism is not imposed on ACLEDA Bank Plc. through the opened account or correspondent/ respondent relationships.

For the Nostro account opening and requesting to establish or accepting RMA with correspondent / respondent bank, Financial Institution Department or designated / or relevant staffs shall conduct the customer due diligence and collect reliable information about the correspondent bank as the following:

� Background of counterpart (if possible) � Structure of board of director and management � Information of shareholder of the bank (if possible) � Products and business activities � Annual reports (if possible)For the Vostro account opening for correspondent inside or outside the

country, the Financial Institution Department or designated / or relevant staffs shall require the additional documents and information as stipulated in the above Nostro Account as the following:

� Commercial License � Banking License � Memorandum and articles of association


� Photo identification of account holders � Letter of Attorney or Board Resolution� Account opening requested letter of Director or Authorized person � AML / CFT Policy and Procedure or Certificate of Registration for Money

Laundering Regulation (comparable document) or completion the AML/CFT questionnaire (Appendix 1)

� Purpose of Vostro account opening with ACLEDA Bank Plc located in Cambodia

� Financial Institution Department or designed / relevant staffs shall pay close attention to the account opened for Financial Institutions which have insufficiently implemented the internationally accepted AML / CFT measures. It is strictly prohibited to open account or request / accept the RMA with the bank or financial institutions which have not implemented AML/ CFT measures because there may be heightened risks exposed to ACLEDA Bank Plc.

� Financial Institution Department or designed / relevant staffs shall ensure that such correspondent bank / respondent bank relationship do not include correspondent bank / respondent bank relationship or financial institutions that have no physical presence (Shell Bank).

� In case of ACLEDA Bank Plc. has not received the completed documents and relevant information as stipulated above for requesting or accepting RMA, but in urgent need of requesting or accepting RMA relationship, VP & Head of Financial Institution Department, Compliance Officer and Legal & Corporate Affair Division shall have a joint consultation and a decision match before reguesting or accepting RMA.

� For Vostro account opening or accepting the RMA relationships, Financial Institution Department, Compliance Officer and Legal & Corporate Affair Division shall jiontly examine and verify the accuracy and legality of the relevant documents.

� All Nostro / Vostro account opening or requesting/accepting RMA with correspondent bank / respondent bank, Financial Institution Department or designated / relevant staffs shall present the relevant documents to Anti-Money Laundering Unit to check and verify AML seal against the ACLEDA's Black List before being submitted to competent management for approval.

� President & CEO or Authorized person is a final authorizer for the Nostro account opening with correspondent bank.

� Financial Institution Department or designated / relevant staff shall file and retain the relevant copied documents of correspondent bank/ respondent bank.

3.1.9- MICRO FINANCE INTISTUTION LOCATED IN CAMBODIA

Before establishing a business relationship with Micro Finance Institution (MFI) located in Cambodia, designated / relevant staffs shall understand, and satisfy the information gathered and ensure that they are not exposed to the threat of money laundering and financing of terrorism.

3.1.9.1 Entering a business relationship with MFIs, designated / relevant staffs shall at least collect and assess the following information as below: � Business license or Authorized letter of entity functioning � Article and Memorandum � Photo Identification of account holder


� Board resolution or account opening requested letter of Director� Brief background and shareholders of MFI (if available)� Structure of Board of directors and management (if available) � Product and business activities � Policy and procedure of Anti-Money Laundering or completion the AML/CFT

questionnaire (Appendix 2)� Annual report (if available) � The purpose of account opening

3.1.9.2 Designated / relevant staffs should not establish relationship with MFIs which have insufficiently implemented the internationally accepted AML / CFT measures.

3.1.9.3 Designated / relevant staff shall check against ACLEDA's Black List before submitting to competent management for approval of account opening for MFIs. Prior consultation of Complaince Officer should be caried out in case the MFIs do not have the Policy and Procedure in place or having insufficiently implemented the AML/CFT measure.

3.1.10- MONEYCHANGERS

� Designated / relevant staffs must pay special attention to and should conduct customer due diligence as stringent as the one imposed on individual customer, and ensure that the moneychangers who maintain account with ACLEDA Bank Plc are licensed by National Bank of Cambodia and only conduct legitimate currency exchange transactions, and ensure that the nature and volume of transaction in the moneychangers account reflect the nature of their business.

� Designated / relevant staffs shall promptly report to Compliance Officer if identify any discrepancies in the activities of the moneychangers account.

3.1.11- POLITICALLY EXPOSED PERSONS (PEPs)

� Politically Expose Persons shall mean any individual who is or has been entrusted with prominent public function is being conducted, including those persons who exercise ultimate effective control over a legal person or arrangement. � Designated / relevant staffs should conduct customer due diligence the existing and

new customers to identify whether they are Politically Exposed Persons for determining the level of AML/CFT risk.

� Once PEP is identified, designated / relevant staffs should take reasonable measures to establish the source of wealth and funds of such persons.

� The decisions to enter into business relationships with PEPs should be made by SVP&Head, Branch Manager, and/or staff who acting on behalf of the SVP&Head or Branch Manager.

� Designated / relevant staffs should be on-going monitoring and record the information collected from the customer and obtained through independent research, and fully understands the nature of business relationship and transaction activity.

3.1.12- CUSTOMER WHO USE PRIVATE BANKING

� Designated / relevant staffs should conduct customer due diligence to establish the customer requesting the private banking service does not engage in the money laundering or financing of terrorism.

� Designated / relevant staffs should conduct customer due diligence and require customer to provide the identification and other necessary documents according to


customer due diligence (CDD) for individual customers, incorporated entities, non-government, and foundation.

� The decisions to enter business relationships with or set account for the private banking customer should be made by SVP&Head, Branch Manager, and/or staff acting on behalf of the SVP&Head or Branch Manager.

33..22-- CUSTOMER ACCEPTANCE POLICY AND DESIGNED RISK BASED CUSTOMER ACCEPTANCE POLICY AND DESIGNED RISK BASEDAPPROACHAPPROACH

Designated / relevant staffs shall be clear on measure of customer due diligence (CDD) to identify the customers who pose a higher than average risk to the bank. In creating the risk profile of a customer type or an individual customer, designated / relevant staffs should at least take into consideration the following factors:

� The origin of the customer and location of the business � Background and personal particulars of the customer � Nature of the customer's business � Structure of ownership for a corporate customer, and � Any other information indicating the customer is of higher risk Following the initial acceptance of the customer, designated/relevant staffs

should continuously monitor the customer's account activity pattern to ensure it is in line with the customer profile. In case of unjustified and unreasonable differences, designated/relevant staffs shall reassess below listed characteristics of customer who have been identified with potentially higher money laundering and/or financing of terrorism risks:

� Money service business (remittance house, exchange house, money transfer agents and bank note traders)

� Casino and/or betting and other gambling related activities � Unregulated charities and other unregulated "not for profit" organizations

especially those operating on a cross-border basis.� Real estate agents � Dealers in precious metals and stones � Lawyers, notaries, other independent legal professional and accountants who

represents their client to prepare for or carry out transactions in relation to the following activities:

� Buying and selling of real estate � Managing of client's money, securities or other assets � Management of bank, savings or securities accounts � Creating, operating or managing of legal persons or arrangements,

and buying and selling of business entities � Customers that are Politically Exposed Person or "PEPs"

33..33-- UPDATING AND DISSEMINATING THE ACLEDA'S BLACK LISTUPDATING AND DISSEMINATING THE ACLEDA'S BLACK LIST� ACLEDA's Black List: is the consolidated list which derived from National Bank

of Cambodia (NBC) and U.S Treasury's website (OFAC list) or other nescessary sources, designed by ACLEDA Bank Plc to be used for the whole network before establishing a business relationship or providing any services to customers.


3.3.1- HEAD OFFICE

� After receiving the black list from NBC and independent research in U.S Treasury's website (OFAC list), Compliance Officer shall be responsible for updating and disseminating the ACLEDA's Black List to all relevant divisions, departments, centers, and branches.

� Compliance Officer shall send the soft copy of the list through e-mail to all related divisions, departments, center and branches on the notice-issued day.

� After receiving the letter, SVP & Head of Divisions, VP & Head of Departments / Centers involved shall urgently circulate the list to all the relevant staffs on the receiving date or not latter than one day within the working day.

� In case of receiving the letter but failing to obtain the ACLEDA's Black List in soft copy through E-mail, AVP & Manager of Teller Unit, AVP&Manager of Marketing Unit, AVP&Manager of Remittance Unit and/or other relevant AVP & Managers Unit shall promptly contact to Compliance Officer to find the appropriate remedy to resend on time.

3.3.2- BRANCHES LEVEL

� After receiving the letter, all branch managers shall urgently keep all relevant staffs informed about the new updated black List on the notice-issued day or not latter than one day within the working day.

� After getting informed by Branch Managers, all related AVP & Managers in each branch shall urgently make all relevant staffs known about the new updated black list on the notice-issued day or not later than one day within the working day.

� After receiving the soft copy of the list through E-mail, AVP & Manager of Teller Unit, AVP&Manager of Marketing Unit, AVP&Manager of Trade Finance Officer or other related AVP&Manager shall promptly circulate the list to all relevant staffs on the receiving date.

� In case of receiving the letter but failing to obtain the black list in soft copy through E-mail, AVP & Manager of Branch Teller, Branch Marketing officer, Branch Trade Finance officer and other relevant AVP & Managers of Branch shall promptly contact to Compliance Officer at Head Office to find the appropriate remedy to resend on time.

33..44-- ACCOUNT OPENINGACCOUNT OPENING3.4.1- REQUIREMENT OF IDENTIFICATION AND OTHER NECESSARY DOCUMENTS

� Prior to opening a new account for customers, designated / relevant staffs shall require customer to provide the official identification and/or other necessary documents as stringent as the one imposed on point 3.1 above.

� All account opening, designated / relevant staffs shall be fully aware of the purpose of the new account opening and nature of the customer business.

� Passport, Photo Identification, and other necessary documents shall have at least three months of validity.

� Opening anonymous accounts and account in fictitious names shall be prohibited. Make sure that no customer is allowed to open or operate an anonymous account or an account in a fictitious, false or incorrect name.

� Should not open account for or conduct business with a shell-company, which do not conduct any commercial activities or have any form of commercial presence in


the country but are legal entities through which financial transactions may be conducted.

3.4.2- CHECKING PROCESS OF ACCOUNT OPENING

� Before opening an account for customers, designated / relevant staffs carefully examine the adequacy of the documents and the information provided by the customers.

� Prior to opening all account types for customers and requesting to add new members from the account hoder, one relevant staff who first directly meets customer or fills in the form of account opening application for the customer or the officer who is responsible for inputting CIF of account opening in to T24 has to check and stamp AML on the "Specimen Signature for Personal Account" for individual's account or"Specimen Signature for all Customer Other than Personal Customer" for entity's account and sign initial adjacent on the top part of the AML seal after duly checking against ACLEDA's Black List to prove that applicant is not in the black list. (Appendix 3)

� For semi-online/off-line branches or district offices where ClickSaving Multi Userprogram is used to open account, checking shall be done by one relevant officer who first directly meets customer or fills in the form of account opening application for customer has to stamp AML on the "Specimen Signature for Personal Account" for individual's account or "Specimen Signature for all Customer Other than Personal Customer" for entity's account and sign initial adjacent on the top part of the AMLseal after duly checking against ACLEDA's Black List to make sure that applicant is not in the ACLEDA's Black List. (Appendix 3)

� The authorizer should not sign and approve of the Account Opening Application Form in case there is no AML stamped and signed initial of the first officer, in contrast, the authorizer shall be liable for the authorized transactions without having been checked and stamped AML.

� In case of finding the name of applicant looking similar or match to the ACLEDA's Black List, designated / relevant staffs must promptly contact to Anti-Money Laundering Unit, Head Office, for further checking and appropriate action in a timely manner.

� Designated / relevant staffs shall monitor the transactions in the customer account, and must promptly report to competent management or Compliance Officer if there is an inconsistency with the gathered information or expectation.

33..55-- REMITTANCE AND WIRE TRANSFERREMITTANCE AND WIRE TRANSFER3.5.1- REQUIREMENT OF IDENTIFICATION AND OTHER NECESSARY DOCUMENTS

� Prior to providing all service of remittance / wire transfer to customer, designated / relevant staffs shall require customer to provide the official identification and/or other necessary documents as stringent as the one imposed on point 3.1 above.

� All remittance / wire transfer, designated / relevant staffs shall be aware of or require customers to clarify the purpose of transfer, which seems to be reliable and reasonable, and fully understand the nature of customer business.

� Designated / relevant staffs shall require customer to provide relevant documents to support the remittance / wire transfer such as commercial contract, purchasing order, commercial invoice, or other relevant document based on the nature of the transactions.


� In case of finding the name of applicant or beneficiary looking similar or matching to the Terrorist List, designated / relevant staffs must promptly contact to Anti-Money Laundering Unit, Head Office, for further checking and appropriate action on a timely basis.

3.5.2- DOMESTIC TRANSFER

� For all kinds of remittance / wire transfer equal to or in excess of USD 1,000.00 (KHR 4 millions) and other equivalent currencies, designated / relevant staffs shall require customers to furnish the identification or other necessary documents as stipulated in 3.5.1 above of the customer due diligence measure.

� Competent management shall resolve whether to conduct the transaction or not should be based on the compliance with customer due diligence measure, where the customer doesn't possess photo identification and other necessary document or never used to have the document kept at the bank either.

� Where the customer has held account or provided the photo identification or other necessary documents to the bank, there is no need to require again from the customer, but make sure they can be found when needed. Designated / relevant staffs shall write down "KYC" or customer account below "Prepared by" on TRANSFER APPLICATION-Form 07.

� Designated / relevant staffs shall be aware of or ask customers about the purpose of the transfer conducted, and the nature of customer business.

3.5.2.1 CHECKING PROCESS OF DOMESTIC TRANSFER

� For local transfer transactions equal to or in excess of USD1, 000 (4 millions Riels or foreign currency equivalent) shall be checked seriously by one relevant officer or teller who meets and receives Transfer Application Form from customer must check and stamp AML and sign initial adjacent on the top part of the AML seal on the Transfer Application-Form 07 in order to prove that the transaction is thoroughly checked against the ACLEDA's Black List, and applicant or beneficiary is not in the black list. (Appendix 4)

� Stamping AML shall be undertaken on the first and second page of Transfer Application (Form 07), and the third page for the customer's copy is not required.

� Exception of stamping AML:� Inter-Account transfer � Transfer to personal account � Transfer to repay loan to the bank � Transfer to current account for revenue and expense of the government

� The authorizer should not sign and approve of the Transfer Application Form in case there is no AML stamped and signed initial of the first officer, in contrast, the authorizer shall be liable for the authorized transactions without having been checked and stamped AML.

3.5.3- OVERSEA TRANSFER

3.5.3.1 OUTBOUND TRANSFER VIA SWIFT

� All transactions, designated / relevant staffs shall require customer to provide such photo identification and/or other necessary documents, and relevant information in point 3.5.1 above.

� For transfer transaction below USD 500 (Riel 2 millions) or other equivalent currencies, competent management shall be at his or her discretion to provide


service or not to customer having no the identity documents or necessary documents kept at the bank, which is supposed to fully rely on the customer due diligence measure.

3.5.3.1.1 CHECKING PROCESS OF SWIFT

� All overseas transactions shall be checked by one relevant officer or teller who directly meets and receives SWIFT WIRE TRANSFER APPLICATION from customer need to thoroughly check and stamp AML and sign initial adjacent on the top part of the AML seal on SWIFT WIRE TRANSFER APPLICARION to prove that the transaction is rigorously checked against ACLEDA's Black List before the service has been delivered to customers. (Appendix 4)

� AML shall be stamped on the first and second page of SWIFT WIRE TRANSFER APPLICATION and the third page for the customer copy is not required.

� The authorizer should not sign and approve of the SWIFT WIRE TRANSFER APPLICATION in case there is no stamped AML and initial signature of the first officer but, on the contrary, the authorizer shall be liable for the authorized the transactions without having been checked and stamped AML.

� For the Head office, Anti-Money Laundering Unit shall check and stamp AML on all oversea wire transfer the Remittance Unit has published from the oversea short term account in the system T24. The Remittance Unit or relevant staff must not process the data into the SWIFT system if there is no AML stamped by Anti-Money Laundering Unit, on the other hand, the authorizer shall be liable for the authorized the transactions without having been checked and stamped AML.

3.5.3.2 OUTBOUND TRANSFER VIA WESTERN UNION (W.U)

� All transaction, designated / relevant staffs shall require customer to provide such photo identification and/or other necessary documents, and relevant information in point 3.5.1 above.

� For transfer transaction below USD 500 (Riel 2 millions) or other equivalent currencies, competent management shall be at his or her discretion to provide service or not to the customer having no the identity documents or necessary documents kept at the bank, which is expected to be fully compliant with the customer due diligence measure.

3.5.3.2.1 CHECKING PROCESS OF WESTERN UNION

� All W.U outbound transaction shall be checked by one relevant officer or teller who directly meets and receives the W.U application (To send Money) from customer need to thoroughly check and stamp AML and sign initial adjacent on the top part of the AML seal to prove that the transaction has been rigorously checked against ACLEDA's Black List before the service has been delivered to customers.(Appendix 4)

� To stamp AML is required on the first page of To Send Money form, the second page that is customer's copy is not required to stamp AML.

� The authorizer should not sign and approve of the W.U application (To Send Money) if discover there is no AML and sign initial of the first officer on the W.U application (To Send Money). On the other hand, the authorizer shall be liable for the approved transactions without having been checked and stamped AML.

33..66-- BANK DRAFTBANK DRAFT� Bank Draft: is a settlement tool designed by ACLEDA Bank Plc. for individual or

business customers to withdraw certain amount of money from ACLEDA's Nostro


Account maintained with correspondent banks abroad. Additionally, this kind of service is also a possible means of money laundering or financing of terrorism by some criminals who intend to move money from one place to another in a foreign country if we have not paid close attention to their identities, supporting documents and other necessary documents of the applicant and the beneficiary.

� Designated / relevant staffs shall pay close attention to the customer due diligence measure to establish that the applicant requesting the bank draft of ACLEDA Bank Plc. is consistent with his or her nature of business.

� Designated / relevant staffs shall require applicants to furnish the identity and supporting documents and other pertinent information as imposed on the individual customer, incorporated entities, and NGOs and foundations.

3.6.1- IDENTIFICATION REQUIREMENT AND OTHER NECESSARY DOCUMENTS

� For all Bank Draft transactions conducted for customers, designated / relevant staffs shall require them to furnish the identification and supporting documents and other pertinent information as stipulated in the customer due diligence mechanism for individual customer, incorporated entities, NGO, and foundations.

� For customers having account or documents kept at the bank, there is no need to make request from the customers again, but make sure it can be found when needed.

3.6.2- CHECKING PROCESS OF BANK DRAFT

� Prior to providing Bank Draft service for customers, designated/relevant staffs should obviously be aware of the purpose of transaction or make any enquiry indeed about the intention of using bank's services. Moreover, reliable supporting documents shall be required from customers.

� For all Bank Draft transactions conducted for customers, prior to sending relevant documents to Treasury Operation Unit in Operation Division, Head Office, one relevant officer or marketing officer who is responsible for preparing the documents for the customer shall check and stamp AML and sign initial adjacent on the top part of the AML seal on the application form to prove that the transaction has been thoroughly checked and the applicant or beneficiary is not found in the ACLEDA's Black List. (Appendix 5)

� Prior to submiting the documents to competent management for approval, TreasuryOperation Unit, Operation Division, shall examine the adequacy and accuracy of the involved documents and make sure AML stamped and initial signature of the first officer are properly stamped and signed.

� Authorizer who is entitled to make the final decision on whether to provide services to customer or not shall not sign and approve of the transactions if there is no stamp AML and initial sign on the application of the first officer who has prepared the documents. Otherwise, the authorizer shall be liable for the transactions which have not been checked and stamped AML properly.

� Designated / relevant staffs shall report to Compliance Officer at the Head Office, if discovered unusual or unexpected transactions compared with the nature of business or customer's occupation and other pertinent information gathered.

33..77-- TRADE FINANCE PRODUCTSTRADE FINANCE PRODUCTS� Trade Finance Product is an instrument to settle local and international trading between two or more partners (an exporter and an importer) through which most of transactions will be conducted on an agreed term and condition. The Trade Finance


products comprise of Letter of Credit, Bank Guarantee, Documentary Collection, Settlement of foreign bank cheque, buy-sell Traveler Cheque ....etc.

3.7.1 IDENTIFICATION REQUIREMENT AND OTHER NECESSARY DOCUMENTS

� Prior to delivering service to the customers, designated / relevant staffs shall require customers to furnish the identification or other necessary documents as stipulated in customer due diligence measure 3.1 above.

� Where the customer has held account or provided the photo identification or other necessary documents to the bank, it is not necessary to require those documents again from the customer, but make sure they can be found when it is needed.

� More addition relevant documents for each of the products shall be required from the customers.

3.7.2 CHECKING PROCESS ON TRADE FINANCE PRODUCTS

3.7.2.1 IMPORT UNIT

� For issuing all Letter of Credit (LC) or receiving the import documentary collection, designated / relevant staffs who are responsible for preparing documents for customer shall check and stamp AML and sign initial adjacent on the top part of the AML seal on the Application for Irrevocable Documentary Credit or Export Bill Collection which is obtained from the remitting bank to prove that all relevant information, merchandises, and parties do not appear in the Exclusion List and ACLEDA's Black List. (Appendix 6)

� Branch level, competent management who is entitled to make the final decision shall not sign and approve of the Application for Irrevocable Documentary Credit or Export Bill Collection if there is no AML stamped and initial signature on the application of the officer who prepares the documents for the customer. Otherwise, the authorizer shall be liable for the authorized transactions which are not checked and stamped AML properly. (Appendix 6)

� Head Office, designated / relevant staffs who are responsible for preparing the documents in Import Unit, Trade Finance Division shall check and stamp AML and sign initial adjacent on the top part of the AML seal on the Application for Irrevocable Documentary Credit or Export Bill Collection which has been received from the remitting bank to prove that all relevant information, merchandises, and parties do not appear in the Exclusion List and ACLEDA's Black List. Import Unit shall submit the relevant documents to Anti-Money Laundering Unit for additional checking against ACLEDA's Black List and sign initial adjacent on the bottom part of the seal to prove that the relevant parties do not in the ACLEDA's Black List. (Appendix 6)

� Head Office, competent management who is entitled to make the final decision shall not sign and approve of the Application for Irrevocable Documentary Credit or Export Bill Collection if there is no AML stamped and initial signature on the application of the first officer who prepares the documents and the second officer of Anti-Money Laundering Unit. Otherwise, the authorizer shall be liable for the authorized transactions which are not checked and stamped AML properly.

3.7.2.2 EXPORT UNIT

� For issuing all LC or Export Bill Collection under condition of Documentary Collection or Documentary Credit, designated / relevant staffs who are responsible for preparing documents shall check and stamp AML and sign initial adjacent on the top part of the AML seal on the copied of LC (MT700) or other equivalent messages to MT700 received from the issuing bank, or Application for Irrevocable


Documentary Credit or Export Bill Collection to prove that all relevant information, merchandises, and parties are not in the Exclusion List and ACLEDA's Black List.(Appendix 7)

� Branches level, competent management who is entitled to make the final decision shall not sign and approve of the Application of Request for Processing of Documents Presented Under Export Letter of Credit or for Collection if there is no AML stamped and initial signature of the first officer who prepares the documents for customer on the copied of LC (MT700) or other equivalent messages to MT700 obtained from the issuing bank. Otherwise, the authorizer shall be liable for the transactions which are not checked and stamped AML properly. (Appendix 7)

� Head Office, designated / relevant staffs who are responsible for preparing the documents for the customer of Export Unit, Trade Finance Division shall check and stamp AML and sign initial adjacent on the top part of the seal on the copied of LC (MT700) or other equivalent messages to MT700 received from the issuing bank or Application of Request for Processing of Documents Presented Under Export Letter of Credit or for Collection to prove that all relevant information, merchandises, and parties are not in the Exclusion List and ACLEDA's Black List. Export Unit shall submit the relevant documents to Anti-Money Laundering Unit for additional checking against ACLEDA's Black List and sign initial adjacent on the bottom part of the seal to prove that the relevant parties do not appear in the ACLEDA's Black List. (Appendix 7)

� Head Office, competent management who is entitled to make the final decision shall not sign and approve of the transaction if there is no AML stamped and initial signature of the two relevant officers of Export Unit and an officer of Anti-Money Laundering Unit on the Application of Request for Processing of Documents Presented Under Export Letter of Credit or for Collection or the copied of LC (MT700) or other equivalent messages to MT700 obtained from the issuing bank.Otherwise, the authorizer shall be liable for the authorized transactions which are not checked and stamped AML properly.

3.7.2.3 GUARANTEE UNIT

3.7.2.3.1 ISSUING DOMESTIC GUARANTEE

� For issuing all Domestic Guarantee, designed / relevant officers who are responsible for preparing documents for the customer shall apparently check and stamp AML and initial signature adjacent on the top part of the seal on the Application Form for Issue Guarantee (Domestic Only) to prove that the relevant information, documents, and parties do not match the Exclusion List and ACLEDA's Black List. (Appendix8)

� Competent management who is entitled to make the final decision shall not sign and approve of the Application Form for Issue Guarantee (Domestic Only) if there is no presence of AML and initial signature of the officer who is responsible for preparing the documents for the customer. On the contrary, the authorizer shall be liable for the transactions which are not checked and stamped AML properly.

3.7.2.3.2 ISSUING OVERSEAS GUARANTEE

� For issuing all Overseas Guarantee, designated / relevant officers or the first officer who is responsible for preparing the document for the customer shall thoroughly check and stamp AML and initial sign adjacent on the top part of the seal on Application Form for Issue Guarantee (Overseas Only) to prove that the relevant information, documents, and parties are not in the Exclusion List and ACLEDA's Black List. (Appendix 9)


� Branch level, competent management who is entitled to make the final decision shall not sign and approve of the Application Form for Issue Guarantee (Overseas Only) if there is no AML stamped and initial signature on the copied application of the first officer who prepares the documents for the customer. Otherwise, the authorizer shall be liable for the transactions which are not checked and stamped AML properly. (Appendix 9)

� Head Office, the first officer / relevant staffs who is responsible for preparing the documents for the customer of Guarantee Unit, Trade Finance Division shall submit the relevant documents to Anti-Money Laundering Unit for additional checking against ACLEDA's Black List and sign initial adjacent on the bottom part of the seal to prove that the relevant parties are not in the ACLEDA's Black List. (Appendix 9)

� Head Office, competent management who is entitled to make the final decision shall not sign and approve of the Application Form for Issue Guarantee (Overseas Only) if there is no AML stamped and initial signature of the two relvant officers as mentioned above on the documents. Otherwise, the authorizer shall be liable for the transactions which are not checked and stamped AML properly.

3.7.2.3.3 RECEIVING OVERSEAS GUARANTEE

� For receiving all Overseas Guarantee, the first officer / relevant officers who are responsible for preparing the document for the customer shall thoroughly check and stamp AML and sign initial adjacent on the top part of the seal on the copied of the Overseas Guarantee to prove that the relevant information, documents, and parties are not in the Exclusion List and ACLEDA's Black List. (Appendix 10)

� Head Office, the first officer / relevant staffs who are responsible for preparing the documents for the customer of Trade Finance Division shall send the relevant documents to Anti-Money Laundering Unit for additional checking against ACLEDA Black List and sign initial adjacent on the bottom part of the seal to prove that the relevant parties are not in the ACLEDA's Black List. (Appendix 10)

� The competent management who is entitled to make the final decision shall not sign and approve on the copied document of Receiving Overseas Guarantee if there is no presence of AML and initial signature of the officer who prepares the documents for the customer of Trade Finance Division and an officer of Anti-Money Laundering Unit. Otherwise, the authorizer shall be liable for the transactions which are not checked and stamped AML properly.

3.7.2.4 BUYING FOREIGN BANK CHEQUE

� For purchasing all Foreign Bank Cheque, designated / relevant officers who are responsible for preparing the document for the customer shall thoroughly check and stamp AML and sign initial adjacent on the top part of the seal on the Application of Purchase Foreign Cheque to prove that the beneficiary and drawer is not in the ACLEDA's Black List. (Appendix 11)

� The competent management or the relevant units involved in clearing the foreign cheque shall not approve or settle the cheque if there is no AML stamped and initial signature of the officer who has prepare the documents for the customer. Otherwise, the authorizer shall be liable for the transactions which are not checked and stamped AML properly.

3.7.2.5 BUYING TRAVELLER CHEQUE (T.C)


� For all purchasing of individual Traveler Cheque (TC) from customer designated / relevant officers shall try to know the beneficiary and require customer to furnish the photo identification and/or other necessary documents as stipulated in customer due diligence measure 3.1 above.

� All transactions of purchasing TC exceeding USD 1,000 (or its equivalent in any other currencies) designated/relevant staffs who prepares the documents for customer shall thoroughly check and stamp AML and initial sign adjacent on the top part of the seal of Application For Purchase of Individual Traveller Cheque to prove that the beneficiary is not in the ACLEDA's Black List. (Appendix 12)

� The competent management or the relevant units involved shall not approve or settle the cheque if there is no presence of AML seal and initial signature of the officer who prepares the documents for the customer. On the other hand, the authorizer or relevant unit involved shall be liable for the transactions which are not checked and stamped AML properly.

3.7.2.6 SELLING TRAVELLER CHEQUE (T.C)

� Selling Traveler Cheque (TC) to individual or corporate customer exceeding USD 1,000.00 (or its equivalent in any other currencies) designated / relevant officers shall try to know the applicant (purchaser) and the photo identification and/or other necessary documents shall be furnished by the customer as stipulated in customer due diligence measure 3.1 above.

� Designated/relevant staffs who prepare the documents for the customer shall closely check and stamp AML and initial sign adjacent on the top part of the seal of Seller's Copy No.1 and Seller's Copy No.2 of the Purchase Record to prove that the applicant is not in the ACLEDA's Black List. (Appendix 13)

� The competent management or relevant units shall not approve or issue TC for the customer if there no AML stamped and initial signature of the first officer who prepares the document for the customer. Otherwise, the authorizer or relevant unit involved shall be liable for the transactions which are not checked and stamped AML properly.

33..88-- TRANSACTION MONITORING PROCESSTRANSACTION MONITORING PROCESSTransaction monitoring is to identify transactions that appear to be suspicious,

within the point of 3.9 REPORTING PROCESS OF SUSPICIOUS TRANSACTIONS.Designated / relevant staffs shall regularly keep ongoing monitor on relevant activities in the course of customer's business relationship. The nature of this monitoring will depend on the nature of the customer's business. The purpose of this monitoring is for designated/relevant staffs to be vigilant at any significant changes or inconsistencies in the pattern of transactions. Inconsistency is measured against the stated original purpose of the account such as the declared transaction profile of the customer. Possible areas to be monitored could be:

� Transaction type � Frequency of deposit and withdrawal, wire transfer, and/or other services� Unusually large amounts � Geographical origin/destination � Changes in account signatories

33..99-- REPORTING PROCESS OF SUSPICIOUS TRANSACTIONSREPORTING PROCESS OF SUSPICIOUS TRANSACTIONS


� Suspicious Transaction: shall means a transaction that involves funds suspected to be the proceeds of offense, or funds related to the financing of terrorism. (Theexample of suspicious transaction in Appendix 14)

All levels of the bank management and staffs are encouraged to report all types of suspicious transactions. To effectively track down the suspected transactions engaged in the money laundering and financing of terrorism, designated / relevant staffs shall do as follows:

� Understand or be aware of the nature of customer business and / or occupation

� The purpose of the customers' transaction � Expected activities and nature of customers' transaction with the bank � Independent research and profiling � Regularly monitor and promptly report unusual transactions.

3.9.1- HEAD OFFICE

� Compliance Officer at the Head Office is nominated to receive all the suspicious transactions from the entire ACLEDA Bank Plc.

� Compliance Officer shall be obliged to independently submit the information of suspected transactions to National Bank of Cambodia (Financial Intelligence Unit of Cambodia) within the 24 hours after the reporting has been received and there is a reasonable ground of suspicion. (The reports formats of suspicious transaction are set out in Appendix 15)

� The Compliance Officer can not submitting the suspicious transaction report to the Financial Intelligence Unit, NBC if those transactions doesn't constitute reasonable ground but s/he shall record his/her opinion.

3.9.2- BRANCHES LEVEL

� Branch Manager is the faciliator and report to Compliance Officer at Head Office after receiving all types of the suspicious report withing their own branch.

� In the event that urgent disclosure is required, particularly when the account concerned is part of an on-going investigation, an initial notification should be made by telephone or Fax to Compliance Officer.

� The report, relevant documents and information of the transactions or customer shall be sent to Compliance Officer as his/her instruction.

� After reporting to Compliance Officer, Chief Teller / relevant staffs shall retain the relevant documents and information, and keep monitoring the customer until further notice or action taken by Compliance Officer.

33..1100-- CONFIDENTIALITY KEEPINGCONFIDENTIALITY KEEPING� All suspicious transactions are strictly prohibited to publicize or inform the involved

customers when the suspected transactions are submitted to the Compliance Officer or National Bank of Cambodia (Financial Intelligence Unit of Cambodia).

� The bank managements especially Compliance Officer shall ensure that when preparing and submitting a suspicious transaction report, the customer and the reporting of the matter remains confidential and is available only to staff, on a strict need to know basis.


� Violation of keeping confidentiality is a serious misconduct and/or shall be subjected by article 15 and article 29 of the Law of Anti-Money Laundering and Combating the Financing of Terrorism.

33..1111-- RECORD KEEPINGRECORD KEEPING� Operation Division, all relevant divisions/departments and branches of ACLEDA

Bank Plc must maintain records documents and copies of documents involved in all forms of transactions for at least 5 years after the date of transaction, the accounts have been closed or the business relations with customer have ended, referred to article 11 of the Law on Anti-Money Laundering and Combating the Financing of Terrorism.

� Where the records are subjected to an ongoing investigation or suspicious transaction submitted, they shall be retained beyond the retention period of five years (05 years) until it is confirmed by relevant authority that such records are no longer needed.

� Operation, relevant divisions/departments, and branches of ACLEDA Bank Plc shall retain the document as original or copies, on microfilm, or in electronic form which is safe and admissible when needed.

33..1122-- STAFFS TRAINING PROGRAMSTAFFS TRAINING PROGRAM� Training program shall be provided to all new recruits before they start to work for

ACLEDA Bank Plc. � Refresher training shall be conducted two times per annum to front-line staffs and

relevant staffs such as Chief Teller, Chief Marketing, Chief Trade Finance, Chief Credit Officer, Chief Accountant, and Chief Internal Auditors.

� Each branche chief shall set up two times per annum the refresher training to all relevant staffs under his/her response.

� Training Division is obliged to prepare the training program, material, and equipment where Compliance Officer lecture on the policy and procedure on anti-money laundering and combating the financing of terrorism and other relevant information.

� Operation Division, relevant divisions/departments, and branches of ACLEDA Bank Plc make sure all designated / relevant staffs have been trained and aware of the Policy and Procedure on Anti-Money Laundering and Combating the Financing of Terrorism.

� Operation Division, all relevant divisions / departments and branches of ACLEDA Bank Plc shall request Training Division or directly contact to Compliance Officer for any additional training sessions on Anti-Money Laundering and Combating the Financing of Terrorism.

3.12.1 NEW STAFFS

� Knowing a general background to money laundering and financing of terrorism, the requirement and obligation to identify and report suspicious transactions to the competent managements or Chief Branch Teller.

� New staff shall be aware of the benefit of Anti-Money Laundering and Combating the Financing of Terrorism and confidentiality keeping.

� Knowing the pattern of suspicious transactions and customer due diligence. 3.12.2 FRONT-LINE STAFFS

OPERATING MANUAL ON AML / CFT 1

UAppendix 1

UQUESTIONNAIRE ON AML / CFT

(For Correspondent Bank)

Please complete all questions and return your response.

Please confirm the areas of your organisation covered by responses to this survey:

Head Office & domestic branches: Yes � No � Domestic subsidiaries: Yes � No �

Overseas branches: Yes � No � Overseas subsidiaries: Yes � No �

If you have answered “no” to any of the above, please provide area of business excluded, including name, location and contact details. ................................................................................................................................................................. .................................................................................................................................................................

1. Institution Name:

2. Registration / Licence No:

3. Address:

Registered Office:

Principal place of business:

Location of Headquarters:

4. Website address:

5. Contact Name:

Contact Telephone:

Email address:

6. Do you have a “physical presence” or are you a regulated affiliate of an entity with a “physical presence”?

Yes � No �

For the purposes of this questionnaire “physical presence” means a place of business:- Located at a fixed address (other than solely an electronic address, a post

office address or an accommodation address); and - In a country in which the bank is authorised to conduct banking activities; and - Where the bank employs 1 or more individuals full-time and maintains

operating records related to banking activities; and - Where the bank is subject to inspection by the banking authority which

licensed the bank to conduct banking activities.

0BOwnership Structure

7. Are you publicly owned? Yes � No �

8. Are you listed on any stock exchange? If so, which? ................................................................................................................................

Yes � No �

9.If no, please attach a list of the beneficial owners of the bank (including their nominees, if their shares are held by nominees) who own, control or have power to vote for 20 percent or more of any class of voting securities or other voting interests; or of the 10 largest shareholders if no owner has greater than 20%.


1BDirectors

10. Please attach a list of the executive and non-executive directors of the main Board of Directors.

2BPolicies and Procedures Section A

11.Do you have a policy and procedures for prevention of money laundering and terrorist financing? If no, when will you expect to have it? ........................................................................................................................

Yes � No �

12. If yes, does this policy apply to all of the operations covered by this questionnaire?

Yes � No �

13. If requested, are you prepared to provide ACLEDA BANK Plc. with a copy of the policy?

Yes � No �

14. Do you verify the identity of all customers prior to providing accounts? Yes � No �

15.Do you verify the identity of all customers including “occasional customers”, prior to providing value transfer services (such as telegraphic transfers, bank cheques or trade transactions)?

Yes � No �

16. Please confirm that you provide banking services only to other banks/financial institutions with a “physical presence”?

Yes � No �

7BSection B

17. Do you have an employee training program for prevention of money laundering and terrorist financing requiring all staff to undertake training?

Yes � No �

If so, how frequently?............................................................................................

18. Do you have a policy and procedures for independent audit or testing of your anti-money laundering compliance?

Yes � No �

If so, how frequently are these audits/tests conducted? ................................................................................................................................

19. Do you have a Money Laundering Reporting Officer responsible for co-ordinating / monitoring compliance?

Yes � No �

If Yes, Please provide name and address ................................................................................................................................If no, to any question in Section B please provide comment if applicable. ................................................................................................................................

Reminder: Have you attached lists of beneficial owners (and nominees), your directors and your highest level of executive management - refer Questions 9 and 10 (if applicable)?

I confirm that I am authorised to complete this document.

Name :...........................

Title :...........................

Date :........./........./....... U


Appendix 2

UQUESTIONNAIRE ON AML / CFT

(For Micro Finance Institution)

Please complete all questions and return your response.

Please confirm the areas of your organisation covered by responses to this survey:

Head Office & domestic branches: Yes � No � Domestic subsidiaries: Yes � No �

Overseas branches: Yes � No � Overseas subsidiaries: Yes � No �

If you have answered “no” to any of the above, please provide area of business excluded, including name, location and contact details. ................................................................................................................................................................. .................................................................................................................................................................

1 Institution Name:

2 Registration / Licence No:

3 Address:

Registered Office:

Principal place of business:

Location of Headquarters:

4 Website address:

5 Contact Name:

Contact Telephone:

Email address:

6 Do you have a “physical presence” or are you a regulated affiliate of an entity with a “physical presence”?

Yes � No �

For the purposes of this questionnaire “physical presence” means a place of business:- Located at a fixed address (other than solely an electronic address, a post

office address or an accommodation address); and - In a country in which the institution is authorised to conduct activities; and - Where the institution is subject to inspection by the authority which licensed

the institution to conduct activities.

3BPolicies and Procedures Section A

7Do you have a policy and procedures for prevention of money laundering and terrorist financing? If no, when will you expect to have it? ........................................................................................................................

Yes � No �

8 If yes, does this policy comply with the Law and Prakas on Anti-Money Laundering and Counter the financing of Terrorism?

Yes � No �

9 If requested, are you prepared to provide ACLEDA BANK Plc. with a copy of the policy?

Yes � No �


10Do you verify the identity of all customers prior to providing accounts? If "no", please give comment:................................................................................................................................................................................................................

Yes � No �

11Do you verify the identity of all customers including “occasional customers”, prior to providing value transfer services (such as telegraphic transfers, bank cheques or trade transactions)?

Yes � No �

8BSection B

12 Do you have an employee training program for prevention of money laundering and terrorist financing requiring all staff to undertake training?

Yes � No �

If so, how frequently? ................................................................................................................................

13 Do you have a policy and procedures for independent audit or testing of your anti-money laundering compliance?

Yes � No �

If so, how frequently are these audits / tests conducted? ................................................................................................................................

14 Do you have a Money Laundering Reporting Officer responsible for co-ordinating / monitoring compliance?

Yes � No �

If "Yes", Please provide name, title, contact number, and address .............................................................................................................................................................................................................................................................................................................................................................................................

If no, to any question in Section "B" please provide comment if applicable. .............................................................................................................................................................................................................................................................................................................................................................................................

I confirm that I am authorised to complete this document.

Name :...........................

Title :...........................

Date :........./........./....... U


Appendix 3

UCHECKING FOR ACCOUNT OPENING

First VerifierAML


U

First VerifierAML


Appendix 4

UCHECKING FOR FUND TRANSFER (Domestic Transfer, Western Union "out", SWIFT "out")

Give to mother

Please put the purpose here

First VerifierAML


First VerifierAML


First Verifier

AML


AML

UAppendix 5UCHECKING FOR BANK DRAFT

U

First Verifier


Appendix 615BUCHECKING FOR DOCUMENTARY CREDIT

U

Second Verifier

First VerifierAML


Appendix 716BUCHECKING FOR L.C or COLLECTION

U

Second Verifier

First VerifierAML


Appendix 8 and 9UCHECKING FOR ISSUING GUARANTEE

U

Second Verifier

First VerifierAML


Appendix 10UCHECKING FOR RECEIVING GUARANTEE

U

Second Verifier

First VerifierAML


Appendix 11

Bak2es~IsMuTijmUlb3TanbR>tbreTs APPLICATION FOR PURCHASE OF FOREIGN CHEQUES

elaknayk /nayika FnaKar The Manager Gasyd%an:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Address:

kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Date:

eQ`aHKNnI : Account Name

elxKNnI : Account No. TwkRVk'\nmUlb3TanbR>t: Amount of Cheques

eyIg/}sUmP9ab'CUnmkCamYynUvc3ab'edIm\nmUlb3TanbR>tbreTs niges~IsMu elak/G~k TTYlTijmUlb3Tan bR>tenH eday � dkkM\resvaCamun � dkkM\resvaeBlbBa|(lTwkRVk'Cak'Es1gcUlKNnIrbs'eyIg/} . I/We enclose original foreign cheques and would request you to purchase the cheques with recourse to me/us and credit the proceeds less your charges to my/our account or charges at the time of purchasing.

eyIg/}sUmp1l'siT?iCUn elak/G~k dknUvcMnYnTwkRVk'Cak'Es1g\nmUlb3TanbR>t nigkM\resvaep!gÔBI ;NBn?KNnIrbs'eyIg/} k~-gkrNIEdlmUlb3TanbR>tRtUvVnbg4ilRtLb'mkvij . You are authorised to debit our account together with any incidental charges for cheques that have been returned unpaid by the issuers. ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ht/elxaGtifiCnAuthorised Signature

UsMrab'FnaKar For Bank's use only lk&xN@bBa(|lTwkRVk': P7amÔ /p1l'CUnbn8ab'BIVnTijcMnYn,,,,,,,,\f^ Approved for credit* immediately / after...........days.

erobcMeday : GnuBa0ateday : Recommended by: Approved by: ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, U

AML


Appendix 12

Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn EdlmanTMhMTwkRVk'elIsBI¢,»»»dul7ar rhUtdl'¶,»»»dul7ar

APPLICATION FOR PURCHASE OF INDIVIDUAL TRAVELLER CHEQUES MORE THAN $1,000.00 TO $5,000.00

elaknayk /nayikasaxa FnaKar The Manager Gasyd%an:,,,,,,,,,,,,,,,,,,,,,,, Address: kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,, Date: eQ`aHGtifiCn : Customer Name:

Currency Denomination Serial Number Unit Amount

Total:

nagx6-M / x6-MVT es~IsMuelaknayk / nayika edIm3ITTYlTijmUlb3Tanb>RteTscrN_ EdlmanTMhM TwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .

sUmelaknayk / nayika TTYlnUvkareKarBd*x5g'x5s'GMBInagx6-M / x6-MVT .

GnuBa0atieday: bJ9ak'eday: erobcMeday Approved by: Verified by: Prepared by: BM Chief Teller Teller

.................................. ................................. ........................................./........./............. ........../........./............ ........../........./..........

For Branch

AML


For Branch

Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn EdlmanTMhMTwkRVk'elIsBI ¶,»»»dul7ar

APPLICATION FOR PURCHASE OF INDIVIDUAL TRAVELLER CHEQUES MORE THAN $5,000.00

eKarBCUnelaknaykhirJ0b3TanBaNiC9km ̀To: Senior Vice President & Head, Trade Finance Division Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al Address: ACLEDA Bank, Headquarters kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,, Date: eQ`aHGtifiCn : Customer Name:


Total:

nagx6-M / x6-MVT es~IsMuelaknaykhirJ0b3TanBaNiC9km` edIm3ITTYlTijmUlb3Tanb>RteTscrN_EdlmanTMhMTwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .

sUmelaknayk TTYlnUvkareKarBd*x5g'x5s'GMBInagx6-M / x6-MVT .

GnuBa0atieday: bJ9ak'eday: erobcMeday Approved by: Verified by: Prepared by: SVP&Head,TFD BM Branch....... Chief Teller Branch........

.................................. ................................. ........................................./........./............. ........../........./............ ........../........./..........

AML


Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn EdlmanTMhMTwkRVk'elIsBI¢,»»»dul7ar rhUtdl'¢»,»»»dul7ar

APPLICATION FOR PURCHASE OF INDIVIDUAL TRAVELLER CHEQUES MORE THAN $1,000.00 TO $10,000.00

eKarBCUnelaknaykRbtibt1iRbtibt1ikarTo: Senior Vice President & Head, Operation Division Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al Address: ACLEDA Bank, Headquarters kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,, Date: eQ`aHGtifiCn : Customer Name:


Total:

nagx6-M / x6-MVT es~IsMuelaknaykRbtibt1iRbtibt1ikar edIm3ITTYlTijmUlb3Tanb>RteTscrN_EdlmanTMhMTwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .


GnuBa0atieday: bJ9ak'eday: erobcMeday Approved by: Verified by: Prepared by: SVP&Head,OPD Chief Teller Teller

.................................. ................................. ........................................./........./............. ........../........./............ ........../........./..........

For OPD

AML


Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn EdlmanTMhMTwkRVk'elIsBI ¢»,»»»dul7ar

APPLICATION FOR PURCHASE OF INDIVIDUAL TRAVELLER CHEQUES MORE THAN $10,000.00

eKarBCUnelaknaykhirJ0b3TanBaNiC9km ̀To: Senior Vice President & Head, Trade Finance Division Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al Address: ACLEDA Bank, Headquarters kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,, Date: eQ`aHGtifiCn : Customer Name:


Total:

nagx6-M / x6-MVT es~IsMuelaknaykhirJ0b3TanBaNiC9km` edIm3ITTYlTijmUlb3Tanb>RteTscrN_EdlmanTMhMTwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .


GnuBa0atieday: bJ9ak'eday: erobcMeday Approved by: Verified by: Prepared by: SVP&Head,TFD SVP&Head,OPD AVP&Mgr Teller OPD

.................................. ................................. ........................................./........./............. ........../........./............ ........../........./..........

For OPD

AML


Bak2es~IsMuTijmUlb3TanbR>teTscrN_rbs'PaKITIbI APPLICATION FOR PURCHASE OF THIRD PARTY

TRAVELLER CHEQUES

elaknayk /nayika FnaKar The Manager Gasyd%an:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Address: ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,

kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Date: eQ`aHKNnI : Account Name

elxKNnI : Account No. TwkRVk'\nmUlb3TanbR>t : Amount of Cheques

eyIg/}sUmP9ab'CUnmkCamYynUvc3ab'edIm\nmUlb3TanbR>teTscrN_ niges~IsMu elak/G~k TTYlTijmUlb3TanbR>tenHeday � dkkM\resvaCamun � dkkM\resvaeBlbBa|(lTwkRVk'Cak'Es1g cUlKNnIrbs'eyIg/} . I/We enclose original traveller cheques and would request you to purchase the traveller cheques with recourse to me/usand credit the proceeds less your charges to my/our account or charges at the time of purchasing.

eyIg/}sUmp1l'siT?iCUn elak/G~k dknUvcMnYnTwkRVk'Cak'Es1g\nmUlb3TanbR>t nigkM\resvaep!gÔBI;NBn?KNnIrbs'eyIg/} k~-gkrNIEdlmUlb3TanbR>tRtUvVnbg4ilRtLb'mkvij . You are authorised to debit our account together with any incidental charges for cheques that have been returned unpaid by the issuers. ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ht/elxaGtifiCnAuthorised Signature

sMrab'FnaKar For Bank's use only lk&xN@bBa(|lTwkRVk': P7amÔ /p1l'CUnbn8ab'BIVnTijcMnYn,,,,,,,,\f ̂Approved for credit* immediately / after...........days.

erobcMeday,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, GnuBa0ateday:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Recommended by: Approved by:

AML


UAppendix 13

U

AML


Appendix 14

UEXAMPLES OF SUSPICIOUS TRANSACTIONS

1- UCash Transactions, Deposit and Withdrawal� Unusually large cash deposits made by an individual or company whose ostensible

business activities would normally be generated by cheques and other instruments. � Substantial increases in cash deposits of any individual or business without apparent

cause, especially if such deposits are subsequently transferred within a short period of time, out of the account and/or to a destination not normally associate with the customer.

� Company accounts whose transactions, both deposits and withdrawals, are denominated in cash rather than the forms of debit and credit normally associated with commercial operations (e.g. cheques, Letters of Credit, Bills of Exchange, etc.)

� Customers who constantly pay in or deposit cash to cover requests bankers' draft, money transfers or other negotiable and readily marketable money instruments.

� Customers who seek to exchange large quantities of low denomination notes for those of higher denomination.

� Branches of banks and financial institutions that have a great deal more cash transactions than usual (Head Office statistics detect aberrations in cash transactions).

� Customers whose deposits contain counterfeit notes or forged instruments. � Customers transferring large sums of money to or from overseas locations with

instructions for payment in cash. � Purchasing or selling of foreign currencies in substantial amounts by cash settlement

despite the customer having an account with the institution. � Customers making large and frequent cash deposits but cheques drawn on the

accounts are mostly to individuals and firms not normally associated with their retail business.

� Deposits for a business entity in combinations of monetary instruments that are atypical of the activity normally associated with such a business.

� Mixing of cash deposits and monetary instruments in an account in which such transactions do not appear to have any relation to the normal use of the account.

� Multiple transactions carried out on the same day at the same branch of a financial institution but with an apparent to use different tellers.

� The structuring of deposits through multiple branches of the same financial institution or by groups of individuals who enter a single branch at the same time.

� The deposit or withdrawal of cash in amounts which fall consistently just below identification or reporting requirements.

� The customer presents funds that have not been counted and upon counting reduces the fund involved to an amount just below what would trigger reporting or identification requirements.

� The deposit or withdrawal of multiple monetary instruments at amounts which fall consistently just below identification or reporting thresholds, particularly if the instruments are sequentially numbered.


2- UTransactions Involving Bank Accounts� Accounts that appear to act as pass through accounts with high volumes of credits

and debits and low average monthly balances. � Customers who wish to maintain a number of trustee or client accounts, which do

not appear consistent with the type of business, including transactions, which involve nominee names.

� The opening by the same person of multiple accounts into which numerous small deposits are make that in aggregate are not commensurate with the expected income of the customer.

� Any individual or company whose account shows no normal personnel banking or business related activities, but is used to receive or disburse large sums which have no obvious purpose or relationship to the account holder and/or his business (e.g. a substantial increase in turnover on an account).

� Reluctance to provide normal information when opening and account, attempts to reduce the level of information provided to the minimum or providing information that is difficult or expensive for banks and financial institutions to verify.

� Customers who appear to have accounts with several bank and micro finance institutions within the same locality, but choose to consolidate monies from such accounts on regular basis for onward transmission of the funds to another 3rd party account.

� Paying in large third party cheques endorsed in favour of the customer. � An inactive account containing a minimal sum suddenly receives a deposit or series

of deposits followed by daily cash withdrawals that continue until the transferred sum has been removed.

� Greater use of safe deposit facilities, which does not commensurate with the customer profile.

� Customer avoiding contact with employees of banks and financial institutions for transaction.

� Substantial increases in deposits of cash or negotiable instrument by a professional firm or company, using client accounts or in-house company, or trust accounts, especially if the deposits are promptly transferred between other client's company and trust accounts.

� Customers who decline to provide information that in normal circumstances would make the customer eligible for credit or for other banking services that would be regarded as valuable.

� Large number of individuals making payment into the same account without an adequate explanation.

� High velocity of funds through an account, i.e. low beginning and ending daily balances, which do not reflect the large volume of dollars flowing through an account.

� An account opened in the name of a money-changer that receives structured deposits (e.g. constant amount of deposit regularly).

� An account operated in the name of an off-shore company with structured movement of funds.


� Accounts that receive relevant periodical deposits and are inactive at other periods. These accounts are then used in creating a legitimate appearing financial background through which additional fraudulent activities may be carried out.

� An account for which several persons have signature authority, yet these persons appear to have no relation among each other (either family ties or business relationship).

� An account opened by a legal entity or an organisation that has the same address as other legal entities or organisations but for which the same person or persons have signature authority, when there is no apparent economic or legal reason for such an arrangement (for example, individuals serving as company directors for multiple companies headquartered at the same location, etc.).

� An account opened in the name of a recently formed legal entity and in which a higher than expected level of deposits are make in comparison with the income of the founders of the entity.

� An account opened in the name of a legal entity that is involved in the activities of an association or foundation whose aims are related to the claims or demands or a terrorist organisation.

� An account opened in the name of a legal entity, a foundation or an association, which may be linked to a terrorist organisation and that shows movements of funds above the expected level of income.

3- UInternational Banking / Trade Finance� Customer introduced by an overseas branch, affiliate or other bank based locations

of specific concern (for example, countries where production of drugs or drug trafficking may be prevalent, countries designated by national authorities, FATF's non-cooperative countries and territories, etc.).

� Use of Letter of Credit and other methods of trade finance to move money between countries where such trade is not consistent with the customer's usual business.

� Customers who make regular and large payments, including wire transactions, that cannot be clearly identified as bona fide transactions, or receive regular and large payments from countries which are commonly associated with the production, processing or marketing of drugs, prescribed terrorist organizations or tax havens.

� Building up of large balance, not consistent with the known turnover of the customer's business, and subsequent transfer to account(s) held overseas.

� Unexplained electronic fund transfers by customers on an in-and-out basis or without passing, through an account.

� Frequent requests for or paying in of travelers' cheques or foreign currency drafts or other negotiable instruments to be issued or originating from overseas.

� Customers sending and receiving wire transfer to/from tax haven countries, particularly if there are no apparent business reasons for such transfers or such transfers are not consistent with the customers' business or history.

4- UBanks and Financial Institutions Employees and Agents� Changes in employee characteristics, e.g. lavish life styles or avoiding taking

holidays.


� Changes in employee or agent performance, e.g. the salesman selling products for cash has a remarkable or unexpected increase in performance.

� Any dealing with an agent where the identity of the ultimate beneficiary or counterpart is undisclosed, contrary to normal procedure for the type of business concerned.

� Sudden strong performance by employees in special relationship/confidentialrelationship banking services such as trust or private banking services or sudden increase in the wealth/spending of such employees.

5- USecured and Unsecured Lending� Customers who repay problem loans unexpectedly. � Request to borrow against assets held by banks and financial institutions or a third

party, where the origin of the assets is not known or the assets are inconsistent with the customer's standing.

� Request by a customer for a bank and micro finance institution to provide or arrange financial contribution to a deal which is unclear, particularly, where property is involved.

� Customers who unexpectedly repay in part or full a mortgage or other loan in a way inconsistent with their earning capacity or asset base.

6- UWire transfer� Wire transfers ordered in small amounts in an apparent effort to avoid triggering

identification or reporting requirements. � Wire transfers to or for an individual where information on the originator, or the

parson on whose behalf the transaction is conducted, is not provided. � Use of multiple personal and business accounts or the accounts of non-profit

organisations or charities to collect and then funnel funds immediately or after a short time to a small number of foreign beneficiaries.

7- UCharacteristic of Customer or His/Her Business ActivityU

� Funds generated by a business owned by individuals or involved by multiple individuals of the same origin from countries of specific concern acting on behalf of similar business types.

� Shared address for individuals involved in cash transactions, particularly when the address is also a business location and/or does not seem to correspond to the stated occupation (for example students, unemployed, self-employed, etc.).

� Stated occupation of the customer does not commensurate with the level or type of activity (for example, a student or an unemployed individual who receives or sends large numbers of wire transfers, or who makes daily maximum cash withdrawals at multiple locations over a wide geographic area).

� Regarding non-profit or charitable organisations, financial transaction for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organisation and the other parties in the transaction.


� Unexplained inconsistencies arising from the process of identifying or verifying the customer (for example, regarding previous or current country of residence, country of issue of the passport, countries visited according to the passport, and documents furnished to confirm name, address and date of birth).

8- UTransaction Linked to Locations of Concern� Deposits are followed within a short time by wire transfers of funds, particularly to

or through a location of specific concern (for example, countries designated by national authorities, FATF non-cooperative countries and territories, etc.)

� A business account through which a large number of incoming or outgoing wire transfers take place and for which there appears to be no logical business or other economic purpose, particularly when this activity is to, through or from locations of specific concern.

� A customer obtains a credit instrument or engages in commercial financial transactions involving movement of funds to for from locations of specific concern when there appears to be no logical business reasons for dealing with those locations.

U


Appendix 15

UFORMAT OF SUSPICIOUS TRANSACTIONS REPORTS (STR)

ACLEDA Bank Plc.

9BSuspicious Transaction Report

10BNATURAL PERSONS 18BReporting Bank:

Name:

Branch:

Address:

Telephone:

Bank Reporting officer:

Name:

Designation:

Report Reference:

Contact Officer: (If different from Reporting Officer) Designation:

Customer's Particulars:

Name:

ID/Passport No:

Birth Date:

Nationality:

Address:

Telephone:

Occupation:

Employment Details:

Employer's Name:

Address:

Telephone:

4BBusiness Relationship(s) with Customer

Bank A/C No.:

Type of A/C:

Date A/C Opened:


A/c Balance (Dr/Cr)

As at date:

Other Business Relationship

Suspicious Transaction(s) 19BUAmount(Dr/Cr) Date

Description of Transaction (E.g. Funds transfer, source of funds, destination, etc)

Reason(s) for Suspicion:

Other relevant Information (Including Any Actions Taken):

Copies of the following documents are attached: Account opening form Account Statement Customer identification Documents Relevant Documents Supporting the Suspicious transactions

________________________________ (Signature of reporting officer) Date:

*Delete whichever is inappropriate


ACLEDA Bank Plc.

11BUSuspicious Transaction Report

12BCOPERATIONS

Reporting Bank:

Name:

Branch:

Address:

Telephone:


Name:

Designation:

Report Reference:

Contact Officer: (If different from Reporting Officer)

Designation:


Name:

Country of Registration:

Registration Date:

Registration No.:

Address:

Telephone:

Name of CEO


Bank A/C No.:

Type of A/C:

Date A/C Opened:

A/c Balance (Dr/Cr)

As At date:


Authorised Signatories' Particulars**

1- Name:

Birth Date:


Nationality:

ID/Passport No.:

Home Address:

**The reporting officer of the bank shall provide data on other authorised signatories, if any

Suspicious Transaction(s) Amount (Dr/Cr) Date Description of Transaction

(E.g. Funds transfer, source of funds, destination, etc)







13BACLEDA Bank Plc.

17BUSuspicious Transaction Report

14BPARTNERSHIPS / SOLE PROPRIETORS / FOUNDATION

Reporting Bank:

Name:

Branch:

Address:

Telephone:


Name:

Designation:

Report Reference: Contact Officer: (If different from Reporting Officer) Designation:


Name:

Country of Registration:

Registration Date:

Registration No.:

Address:

Telephone:

Name of Partnerships / Sole proprietors / Trustees or equivalent:


Bank A/c No.:

Type of A/c:

Date of A/c Opened:

A/c Balance (Dr/Cr)

As At date:




Authorised Signatories' Particulars**

1- Name:

Birth Date:

Nationality:

ID/Passport No.:

Home Address:

Occupation:

Employer's Name: (If applicable) Address:

**The reporting officer of the bank shall provide data on other authorised signatories, if any

Suspicious Transaction(s) Amount (Dr/Cr) Date

Description of Transaction (E.g. Funds transfer, source of funds, destination, etc)




