Roles and Responsibilities
1 Board of Directors
As per the RBI guidelines the Board of Directors of the Bank is responsible for
ensuring that an effective KYC, AML and CFT programme is put in place by
establishing procedures and ensuring their effective implementation. The programme
set by the Board of Directors shall contain:
− Application procedures for AML measures developed by senior management;
− Roles and responsibilities;
− Training for bank officials;
− Systems and controls for implementation;
− Approving methodology for customer risk categorization; and
− Management oversight for the KYC, AML and CFT programme.
It is the responsibility of the Board of Directors to appoint the Principal Officer
(PO) of the Bank.
All pertinent KYC, AML and CFT topics must be discussed by the Board of Directors
in their quarterly meeting.
2 Senior Management/ Designated director
The Senior Management is tasked with the creation of policies and procedures and
their responsibilities include but are not limited to:
− Creation of KYC, AML and CFT policies subject to approval of the Board;
− Deployment of suitable personnel and providing them with sufficient authority
to ensure the effective implementation and administration of KYC, AML and
CFT programmes;
− Obtain periodic reports regarding transaction monitoring, KYC, AML and CFT
initiatives, identified compliance deficiencies and corrective actions taken; and
− Create updates or make changes to the existing policies and procedures
which will be required to be ratified by the Board of Directors.
3 Principal Officer
As per the guidelines7, the Principal Officer (PO) is the officer-in-charge vested with
the authority to ensure the overall implementation of the Bank’s KYC, AML and CFT
policy. The PO is also responsible for:
− Ensuring the monitoring and reporting requirements of the Bank under the
PMLA are met;
− Reviewing the adequacy of systems and controls with respect to KYC, AML &
CFT;
− Coordinating with regulatory and law enforcement agencies; and
− Assisting Senior Management and Compliance Groups in their function.
4 AML Compliance Group
The AML Compliance Group is responsible for all transaction monitoring related
activity at the bank level. It is comprised of the PO and Senior Managers from the
various departments of the Bank including Banking, Internal Audit and Compliance.
The group is responsible for:
− Receiving Transaction Alerts escalated by the Branch Manager (BM) and
either further escalating or closing out the report;
− Sampling of Transaction Alerts reports closed out by the BM to check for
correctness of BM decisions relating to transaction monitoring; and
− Providing periodic reports to Senior Management regarding compliance and
transaction related activities.
5 Audit and Compliance Department
The Bank’s internal audit and compliance department is responsible for the following:
− Providing an independent evaluation of the policies and procedures deployed
within the bank and their effectiveness; and
− Periodically checking the KYC, AML and CFT compliance levels at the
branches of the Bank and providing reports of the same to the audit
committee of the Board.
6 Customer Relationship Officer
The Customer Relationship Officer (CRO) or Account Opening Officer owns the
relationship with the customer and is responsible for:
− Information review and approval for all new customers. While certain portions
of the information collection process may be delegated to the Staff Assistant
(SA), the CRO remains ultimately responsible;
− Obtaining, maintaining and updating customer KYC information and
documentation in the Bank’s management systems;
− Interacting with the customer or customer contact in order to make sure that
the customer identification requirements are understood;
− Forming a reasonable belief regarding the true identity of the customers; and
− Performing periodic reviews and refresh of customer’s KYC information on
file.
7 Branch Manager
The BM at the bank is the branch level decision making authority for all KYC & AML
policy decisions. The responsibilities of the Officer include:
− Responsible for Implementation of KYC, AML and CFT policy at the Branch
level;
− Implements policy on closure or freezing of accounts for non-compliance;
− Responsible for submitting monthly Cash Transaction Reports; and
− Escalating transaction monitoring alerts from the branch level to the
Bank level.
8 .Staff
Bank staff that are interacting with customers and or handling customer
transactions/instructions will be a Bank’s strongest defence against money
laundering. Hence the communication of a Bank’s KYC, AML and CFT Programme
and related training in how to apply the programme, is key to the success of antimoney
laundering and counter funding of terrorism strategies. Therefore as much as
it is important for the Bank to communicate the KYC, AML & CFT Programme with
the staff, it is equally important for the staff to keep themselves updated with the
policies and procedures related to their role in the organisation
Bank staff is also obligated to report transactions that are suspicious of nature and
could be potentially money laundering or terrorist financing activity. An employee is
required to report transaction activity based on mere suspicion even if he or she is
not precisely sure about the underlying criminal activity or whether illegal activities
have occurred
1 Board of Directors
As per the RBI guidelines the Board of Directors of the Bank is responsible for
ensuring that an effective KYC, AML and CFT programme is put in place by
establishing procedures and ensuring their effective implementation. The programme
set by the Board of Directors shall contain:
− Application procedures for AML measures developed by senior management;
− Roles and responsibilities;
− Training for bank officials;
− Systems and controls for implementation;
− Approving methodology for customer risk categorization; and
− Management oversight for the KYC, AML and CFT programme.
It is the responsibility of the Board of Directors to appoint the Principal Officer
(PO) of the Bank.
All pertinent KYC, AML and CFT topics must be discussed by the Board of Directors
in their quarterly meeting.
2 Senior Management/ Designated director
The Senior Management is tasked with the creation of policies and procedures and
their responsibilities include but are not limited to:
− Creation of KYC, AML and CFT policies subject to approval of the Board;
− Deployment of suitable personnel and providing them with sufficient authority
to ensure the effective implementation and administration of KYC, AML and
CFT programmes;
− Obtain periodic reports regarding transaction monitoring, KYC, AML and CFT
initiatives, identified compliance deficiencies and corrective actions taken; and
− Create updates or make changes to the existing policies and procedures
which will be required to be ratified by the Board of Directors.
3 Principal Officer
As per the guidelines7, the Principal Officer (PO) is the officer-in-charge vested with
the authority to ensure the overall implementation of the Bank’s KYC, AML and CFT
policy. The PO is also responsible for:
− Ensuring the monitoring and reporting requirements of the Bank under the
PMLA are met;
− Reviewing the adequacy of systems and controls with respect to KYC, AML &
CFT;
− Coordinating with regulatory and law enforcement agencies; and
− Assisting Senior Management and Compliance Groups in their function.
4 AML Compliance Group
The AML Compliance Group is responsible for all transaction monitoring related
activity at the bank level. It is comprised of the PO and Senior Managers from the
various departments of the Bank including Banking, Internal Audit and Compliance.
The group is responsible for:
− Receiving Transaction Alerts escalated by the Branch Manager (BM) and
either further escalating or closing out the report;
− Sampling of Transaction Alerts reports closed out by the BM to check for
correctness of BM decisions relating to transaction monitoring; and
− Providing periodic reports to Senior Management regarding compliance and
transaction related activities.
5 Audit and Compliance Department
The Bank’s internal audit and compliance department is responsible for the following:
− Providing an independent evaluation of the policies and procedures deployed
within the bank and their effectiveness; and
− Periodically checking the KYC, AML and CFT compliance levels at the
branches of the Bank and providing reports of the same to the audit
committee of the Board.
6 Customer Relationship Officer
The Customer Relationship Officer (CRO) or Account Opening Officer owns the
relationship with the customer and is responsible for:
− Information review and approval for all new customers. While certain portions
of the information collection process may be delegated to the Staff Assistant
(SA), the CRO remains ultimately responsible;
− Obtaining, maintaining and updating customer KYC information and
documentation in the Bank’s management systems;
− Interacting with the customer or customer contact in order to make sure that
the customer identification requirements are understood;
− Forming a reasonable belief regarding the true identity of the customers; and
− Performing periodic reviews and refresh of customer’s KYC information on
file.
7 Branch Manager
The BM at the bank is the branch level decision making authority for all KYC & AML
policy decisions. The responsibilities of the Officer include:
− Responsible for Implementation of KYC, AML and CFT policy at the Branch
level;
− Implements policy on closure or freezing of accounts for non-compliance;
− Responsible for submitting monthly Cash Transaction Reports; and
− Escalating transaction monitoring alerts from the branch level to the
Bank level.
8 .Staff
Bank staff that are interacting with customers and or handling customer
transactions/instructions will be a Bank’s strongest defence against money
laundering. Hence the communication of a Bank’s KYC, AML and CFT Programme
and related training in how to apply the programme, is key to the success of antimoney
laundering and counter funding of terrorism strategies. Therefore as much as
it is important for the Bank to communicate the KYC, AML & CFT Programme with
the staff, it is equally important for the staff to keep themselves updated with the
policies and procedures related to their role in the organisation
Bank staff is also obligated to report transactions that are suspicious of nature and
could be potentially money laundering or terrorist financing activity. An employee is
required to report transaction activity based on mere suspicion even if he or she is
not precisely sure about the underlying criminal activity or whether illegal activities
have occurred
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