Summarised policy framework on Know Your Customer' (KYC), Antimoney Laundering (AML) and Prevention Of Money Laundering (PML) measures of the bank
The Bank has framed the KYC policies incorporating the following four key elements:
- Customer Acceptance Policy
- Customer Identification Procedures
- Monitoring of Transactions
- Risk Management
Customer Acceptance Policy
- The Bank would not establish any business relationship with anonymous or fictitious / benami entities, shell banks, unlicensed banks and/or non-banking financial institutions (NBFIs), other entities that provide banking services to unlicensed and Shell banks, Section 311 designated entities (as defined under USA PATRIOT Act), unlicensed/ unregulated remittance agents / entities, designated persons and entities, exchanges houses, casa de cambio, bureaux de change or money transfer agents, Non-account customers, Money or Value Transfer Services (MVTS)/ Money Services Businesses customers (MSBs), services to any non-bank entities who provides third party payment services to their customers like Third Party Payment Service Provider (PSPs), Virtual Asset Service Providers (VASPs), eCommerce Platforms etc., Red light businesses / Adult entertainment, Virtual Assets, Marijuana, Embassies/ Consulates, Gambling, Regulated and Unregulated charities, Used Car Dealers, etc.
- The Bank would not establish business relationship where the Bank is unable to apply appropriate customer due diligence (CDD) measures i.e. the Bank is unable to verify the identity and / or obtain documents required as per the risk categorisation, due to non-cooperation of the customer or non-reliability of the documents / information furnished by the customer.
- The Bank would exercise enhanced due diligence while establishing business relationship with Offshore customers, Correspondent Banks, Respondent Banks, Arms, defence, military, Atomic power, Nuclear power , General Trading Companies, Travel and Tour Companies , extractive industries, precious metals and stones industries, non-resident borrowers, trusts, NGOs and organizations receiving donations, companies having close family shareholding or beneficial ownership, firms with ‘sleeping partners’, Politically Exposed Persons (PEPs), non-face-to-face customers and those with dubious reputation as per public information available, Payment Service Provider, etc.
- The Bank would exercise due care before admitting new borrowers so as to ensure that the identity of the borrower does not match with any person or entity whose name appears in the sanctions lists circulated by the Reserve Bank of India.
Customer Identification Procedure (CIP)
The Bank has a detailed Customer Identification Procedure in place and obtains and verifies the documents depending upon the status of the customer. In case of non-face-to-face customers, apart from applying the usual customer identification procedure, certification of all the documents would be insisted upon.
Monitoring of transactions
- All the disbursements made to the customers and all the receipts from the customers would be by way of electronic transfers, crossed cheques, demand drafts and other proper banking channels only.
Records containing information
Exim Bank would maintain details pertaining to the identification of customers, debit and credits in loan accounts by using any form, transfer of funds including from and to nostro accounts, suspicious transactions and so on. The record would contain the date on which the transaction was conducted, the nature of the transaction, the amount and the currency in which the transactions was executed.
Retention of records
The transaction records referred as above shall be maintained for minimum period of five years from the end of the business relationship, depending on the nature of transactions.
Combating Financing of Terrorism and Sanctions Compliance
In terms of PMLA Rules, suspicious transactions should include inter alia transactions which give rise to a reasonable ground of suspicion that these may involve financing of activities relating to terrorism. As and when list of individuals and entities, approved by Security Council Committee established pursuant to various United Nations’ Security Council Resolutions (UNSCR), are received from Government of India, Reserve Bank circulates these to all banks and FIs. The updated list of such individuals and entities is available in the United Nations website. Before opening any new account, Bank will ensure that the name(s) of the proposed customer does not appear in the above lists.
Appointment of Principal Officer
Officer in the rank of Chief General Manager has been appointed as Principal Officer of Exim Bank who is responsible for monitoring and reporting of all transaction and sharing of information as required under the law for the purpose of KYC, AML and also for PML.
Contact Details are as under :
Ms. Manjiri Bhalerao
e-mail : manjiri@eximbankindia.in