BFIU Circular No. 26: Instructions to be followed by schedule banks for prevention of money laundering, terrorist financing and proliferation financing

1 Bangladesh Financial Intelligence Unit Bangladesh Bank Head Office Dhaka Ref. No. 26 Ref. No. 26 BFIU Circular No. 26 Date: Managing Director / Chief Executive Officer All Schedule Banks operating in Bangladesh Regarding the issuance of instructions to be followed by schedule banks for the prevention of money laundering, terrorist financing and proliferation financing.

In order to ensure compliance with the relevant provisions of the Prevention of Money Laundering Act, 2012 and the Anti-Terrorism Act, 2009 and the rules framed thereunder, the following instructions are hereby issued to all schedule banks operating in Bangladesh under the powers conferred by Section 23(1)(d) of the Prevention of Money Laundering Act, 2012 and Section 15(1)(d) of the Anti-Terrorism Act, 2009:

1. Compliance Framework: 1.1 Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy: Each bank shall have its own AML/CFT policy, which shall be a combination of international standards, existing laws and rules in the country, and instructions issued by the Bangladesh Financial Intelligence Unit (BFIU). This policy shall be approved by the Board of Directors of the bank or, in applicable cases, the highest Management Committee. The bank shall inform all concerned parties about the said policy and take necessary steps for its implementation. Furthermore, the bank shall review the policy from time to time as part of its own risk management and amend or update it where necessary.

1.2 Declaration of Management Commitment to AML/CFT: (1) The Board of Directors, Chief Executive Officer, and other senior officials of each bank shall strive to strengthen institutional compliance mechanisms in light of their respective responsibilities and authorities as defined in the relevant laws and rules regarding the prevention of money laundering and terrorist financing. (2) The Chief Executive Officer of the bank shall issue a clear and actionable declaration of commitment to the prevention of money laundering and terrorist financing to all employees/officers of the bank on an annual basis; provide appropriate instructions for the implementation of the commitment; and ensure the implementation of compliance matters.

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2 1.3 Appointment of Compliance Officer and Others: (1) To keep the banking sector free from risks related to money laundering and terrorist financing, and to ensure proper compliance with existing laws, rules, and circulars and guidelines issued by the BFIU from time to time regarding this matter, the following arrangements shall be made in each bank: (a) Each bank shall establish a 'Central Compliance Committee' (CCC) at the Head Office led by a 'Senior Officer'. The said Committee shall report directly to the Managing Director or Chief Executive Officer of the bank. The said 'Senior Officer' shall be designated as the Chief Anti-Money Laundering Compliance Officer (CAMLCO). In this regard, the rank of the 'Senior Officer' shall not be lower than two (02) levels below the Managing Director/Chief Executive Officer of the bank. However, in the case of foreign banks, the said 'Senior Officer' must be a member of the highest Management Committee. In the event of a change in the CAMLCO, the BFIU shall be informed immediately. Before the CAMLCO assumes any other responsibility of the bank, the management must ensure that this will not disrupt the bank's program for the prevention of money laundering and terrorist financing. (b) Each bank shall have an Anti-Money Laundering and Combating the Financing of Terrorism Department (referred to by any name) consisting of an appropriate number of officers, considering the number of branches, business expansion and scope, customer base, and institutional risk, to perform the secretarial duties of the Central Compliance Committee and compliance matters related to the prevention of money laundering and terrorist financing. The Deputy Chief Anti-Money Laundering Compliance Officer (DCAMLCO) shall perform the duties as the head of the said department. It is mentioned that no officer shall be appointed below the rank of 'Deputy Manager' or 'Senior Vice President' in the position of DCAMLCO. (c) The Central Compliance Committee shall determine institutional channels and procedures under the bank's own policy for the prevention of risks related to money laundering and terrorist financing and review them from time to time. Under the supervision of the Central Compliance Committee and the CAMLCO, the AML/CFT Department shall ensure the implementation of the AML/CFT procedure on a weekly basis. (d) The CAMLCO and DCAMLCO must have a thorough understanding of existing laws, rules, instructions issued by the BFIU from time to time, and international standards regarding the prevention of money laundering and terrorist financing. (e) The functions of the AML/CFT Department and the responsibilities and authorities of the Central Compliance Committee, its members, the CAMLCO, and the DCAMLCO shall be clearly defined. (f) The Central Compliance Committee shall consist of a minimum of seven (7) members; such that senior officers or heads of various departments of the bank (such as: Human Resources Division, Credit Division, Retail and Corporate Banking Division, Foreign Exchange Division, Operations Division, Card Division, IT Division, etc., or similar divisions) shall be members. However, no officer of the Internal Audit Division can be a member of the Central Compliance Committee. The Central Compliance Committee and the Internal Audit Division shall perform their respective responsibilities regarding the prevention of money laundering and terrorist financing completely independently. (g) The Central Compliance Committee shall hold at least four (4) meetings per year on a quarterly basis. However, if necessary, the Committee may call any number of meetings at any time. In the said meetings, the current status of the bank's AML/CFT compliance shall be reviewed, necessary decisions shall be taken, and instructions shall be issued to be followed.

3 (2) The Central Compliance Committee shall submit a semi-annual report (January-June, July-December) to the Chief Executive Officer of the bank, containing information on the steps taken by the bank regarding the prevention of money laundering and terrorist financing, the progress of implementation, and recommendations. The said report shall include matters mentioned in 8.3 of this circular and any measures taken by the BFIU regarding the prevention of money laundering and terrorist financing. The report, along with the instructions and opinions of the Chief Executive Officer, shall be presented at the meeting of the Bank's Board of Directors or the highest Management Committee, and a copy of the report shall be sent to the BFIU within 2 (two) months of the end of the respective half-year. (3) In accordance with the instructions of the Central Compliance Committee, the AML/CFT Department shall issue instructions to be followed by branches, so that customer identification, transaction screening mechanisms, internal control mechanisms, and other related compliance policies and procedures are included in the prevention of money laundering and terrorist financing. (4) The Central Compliance Committee shall establish internal monitoring and control mechanisms by appointing Branch Monitoring Compliance Officers. In this regard, an experienced officer in each branch shall be appointed as the Branch Anti-Money Laundering Compliance Officer (BAMLCO). It is mentioned that the Branch Manager, the second-in-command of the branch, or an experienced senior officer responsible for departments such as General Banking/Foreign Exchange/Credit, etc., shall be appointed as the Branch Anti-Money Laundering Compliance Officer. The Branch Anti-Money Laundering Compliance Officer must have a thorough understanding of existing laws, rules, all instructions of the BFIU, and the bank's own policy regarding the prevention of money laundering and terrorist financing. The appointment letter of the Branch Anti-Money Laundering Compliance Officer shall clearly mention his/her jurisdiction and responsibilities. (5) The Branch Anti-Money Laundering Compliance Officer shall hold quarterly meetings with other concerned officers of the branch to review the current status of the branch's compliance in light of existing laws, rules, and other instructions of the BFIU regarding the prevention of money laundering and terrorist financing, and take appropriate measures. The matters to be discussed in the said meetings include:

• Customer Identification;
• Transaction Screening;
• Identification and reporting of suspicious transactions or programs;

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• Implementation of local sanctions and United Nations Security Council resolutions;
• Self-assessment programs;
• Record retention;
• Training, etc. The Branch Compliance Officer shall send the minutes of the quarterly meeting to the Anti-Money Laundering and Combating the Financing of Terrorism Department.

2. Customer Selection Policy: Each bank shall have a specific policy for customer selection, which may be part of the bank's main policy regarding the prevention of risks related to money laundering and terrorist financing. The said policy shall necessarily include the following matters along with other relevant issues: (1) No account shall be opened or operated in the name of a fictitious, anonymous, or number-only customer. Additionally, appropriate precautionary measures shall be taken to prevent accounts from being opened or operated in the name of fictitious, anonymous, or number-only customers; (2) No account shall be opened or operated for any person or entity listed under various resolutions of the United Nations Security Council suspected of involvement in terrorism and terrorist financing, or for any person or entity declared prohibited by the Government of Bangladesh; (3) No banking relationship shall be established with any 'Shell Bank' (in this context, 'Shell Bank' refers to any bank that has no physical presence in the country where it is registered or licensed, or is not subject to effective supervision and regulation by a financial group member); (4) Instructions issued by the BFIU from time to time regarding this matter shall be followed.

3. Customer Identification, Due Diligence and Others: 3.1 Definition of Customer: In the risk management of money laundering and terrorist financing, 'Customer' refers to the following persons or entities: (1) Any person or entity that maintains an account with the bank or has a business relationship; (2) The beneficial owner (BO) of the bank account or business relationship (directly or indirectly on whose behalf the account is operated. Detailed discussion on this is provided in the BFIU Circular No. B-01).; (3) Any professional intermediary (lawyer, law firm, chartered accountant, etc.) appointed by an account holder, trust, or actual beneficiary of a transaction to operate an account under existing legal frameworks; (4) The relevant person or entity in the case of high-value transactions (transactions that may pose a risk to the reputation of the institution or create other risks compared to normal transactions based on the profession/profile of the relevant person or institution) or financial transactions occurring in a single transaction by any person or entity; (5) Persons or entities defined by the BFIU from time to time.

5 3.2 Risk-Based Approach: (a) Each bank shall conduct its own risk assessment regarding money laundering and terrorist financing at specified intervals in accordance with the instructions of the Bangladesh Financial Intelligence Unit in Circular No. B-01 'Risk Assessment of Money Laundering and Terrorist Financing Risks of Banks'. In the said risk assessment, the nature of business, customers, products or services, country, and geographical location shall be considered. The said risk assessment report shall be used by the bank for the prevention of money laundering and terrorist financing risks. (b) In cases where high risk of money laundering, terrorism, or terrorist financing is identified according to the risk assessment report, the bank shall take Enhanced Due Diligence (EDD). (c) In cases where low risk of money laundering, terrorism, or terrorist financing is identified or consistent with low risk indicators according to the risk assessment report, the bank may take Simplified Due Diligence (SDD). (d) Each bank shall take necessary Due Diligence (DD) considering the risk, importance, and relevance of existing customers. Additionally, considering when due diligence was previously performed and what type or amount of information was collected, the bank shall determine the timing for performing or reassessing due diligence for existing customers.

3.3 Customer Identification (CIP): In the process of customer identification and verification for money laundering and terrorist financing risk management, the following matters shall be ensured: (1) In opening a customer's account, the account opening form issued by the Banking Regulation and Policy Department of Bangladesh Bank shall be used. However, considering the convenience of using modern technology, in applicable cases, the use of modern technology or assistance as mentioned in BFIU Circular No. B-01 'Use of Modern Technology in Customer Identification Process (CIP)' shall be used. In cases where opening an account through electronic means is not possible, a hard copy of the account opening form may be used. (2) Complete and accurate information regarding customer identification shall be collected. To ensure that the banking system is not exposed to the risk of money laundering or terrorist financing, each bank shall have a thorough understanding of the purpose of the account opening by the customer and perform the verification process of customer identification-related information or data. In this regard, 'complete' refers to the collection of all necessary information for customer identification verification of the account applicant or account holder customer. On the other hand, 'accurate' refers to such complete information whose accuracy has been verified from a reliable and independent source; (2) If another person operates the account on behalf of the customer, it shall be ensured that the said person is duly authorized, and complete and accurate information regarding their identification shall be collected; (3) In the case of accounts operated on behalf of the customer by trustees and professional intermediaries, their legal status shall be reviewed and their authenticity determined, and complete and accurate information regarding the identification of all concerned parties shall be collected; and (4) In the case of providing transaction facilities to someone other than the account holder (e.g., DD, TT, MT, Pay Order, or online transactions, etc.), instructions mentioned in other sections of this circular shall be followed. In this regard, 'someone other than the account holder' refers to a customer who is not the bank account holder.

6 3.4 Customer Due Diligence (CDD-EDD): Customer Due Diligence or CDD-EDD refers to the verification of the identity of the customer (person or entity), the accuracy of the collected identification information or data, the verification of the source of funds, and the regular (periodic) examination of account identification information or data and transactions based on information, data, and documents obtained from reliable and independent sources. It is mentioned that proper customer identification and verification (CIP) is part of the CDD process. (1) Considering the risk associated with the customer, the following different stages of CDD shall be performed: (a) At the time of establishing a relationship with the customer; (b) During irregular (non-recurring) transactions of 5,00,000/- (Five Lakh) Taka or above by walk-in customers (non-account holders); (c) During the execution of irregular (non-recurring) transactions through wire transfer; (d) When there is sufficient reason to suspect that the information or documents previously collected for the identification of the customer are incomplete or inaccurate; and (e) When there is a suspicion that a transaction is related to money laundering or terrorist financing, and in this case, if performing CDD may lead to the leakage of information confidentiality (tipping-off), a Suspicious Transaction/Activity Report (STR) shall be filed without performing CDD. (2) Each bank shall collect sufficient information, subject to its satisfaction, to ensure the customer's identity and the intended purpose and nature of the business relationship with the bank. It is mentioned that the said CDD program performed by the bank shall be reviewed regularly (periodically). (3) Regular CDD programs shall be conducted to identify inconsistencies with the nature of the customer's business, the degree and type of risk, or, in applicable cases, the source of funds. The existing information of high-risk customers shall be updated after regular evaluation, review, or inspection. (4) The accuracy of the identification information or data of the customer or beneficial owner shall be verified at the time of establishing the business relationship or before withdrawing funds from the said account after opening the account. However, in the case of irregular customers, such programs shall be taken during the conduct of transactions. In cases where the risk of money laundering and terrorist financing is low or there are identified risk control measures, or where there is no need to disrupt or terminate the business relationship, the accuracy of the identification information or data shall be verified as soon as possible after the establishment of the relationship. (5) The beneficial owner (BO) of each account shall be identified. Subject to the satisfaction of the bank, the identity of the 'beneficial owner' of the account shall be verified based on information collected from reliable and independent sources. In this regard, the following matters shall be considered: (a) If a customer operates an account on behalf of another person, complete and accurate information regarding the identification of the said person, in addition to the customer, shall be collected and preserved; (b) If it appears that any person directly or indirectly controls or influences a customer, complete and accurate information regarding the identification of the said person shall be collected and preserved;

7 (c) In the case of a company, complete and accurate information regarding the identification of the person(s) who have control or ownership interest (voting/ownership rights) in the said company shall be collected and preserved; (d) If it is not possible to identify any person (nominee) fulfilling the appropriate instructions of clauses (b) and (c) above, the identity of the relevant senior management officer shall be identified, and their complete and accurate information shall be collected and preserved; and (e) In determining the beneficial owner of the account and taking steps in this regard, the matters mentioned in BFIU Circular No. B-01 'Identification of Beneficial Owners' shall be followed.

3.5 Simplified Customer Due Diligence (SDD): Simplified Customer Due Diligence may be taken in the following cases: (a) In the case of transactions below 50,000/- (Fifty Thousand) Taka by walk-in customers (non-account holders), the name and address of the sender or applicant and the recipient or beneficiary, and the telephone number of the sender or applicant shall be collected; (b) If a transaction is more than 50,000/- (Fifty Thousand) Taka or less than 5,00,000/- (Five Lakh) Taka, in addition to the information mentioned in clause (a), a verified copy of the photo ID of the sender or applicant or depositor or withdrawer shall be collected; (c) In the case of opening or operating accounts with low risk or low risk indicators for financial inclusion (such as government social security benefit accounts, student accounts, farmer accounts, and other small accounts); and (d) The simplified customer due diligence mentioned in BFIU Circular No. B-01 shall be followed in this regard.

3.6 Other Instructions Regarding CDD: (1) Each bank shall preserve information and documents after properly performing customer identification and CDD in the case of opening a customer's account. In this regard, the digital sample CIP form mentioned in BFIU Circular No. B-01 shall be used, or in cases where a digital CIP form cannot be used, the sample CIP form attached in Appendix "A" shall be used; (2) When using the sample CIP form/forms attached in Appendix "A" for the purpose of performing CIP by the bank, it shall in no way be considered as part of the account opening form or to be filled by the customer; (2) If a customer operates multiple accounts in one bank, to avoid repetition of customer identification and for the convenience of transaction screening, the bank may assign a Unique Customer Identification Number (UCIN) for the said customer. The said UCIN shall help in identifying all types of services provided to the customer by the bank and the bank, and in fully monitoring financial transactions; (3) In the risk management of money laundering or terrorist financing, the bank shall determine the expected amount of transactions of the customer's account itself. In this regard, the bank shall determine a specific type of transaction based on the customer's past transactions (6/12 months of transactions) and screen the customer's transactions based on the determined type. If a noticeable change is seen in the determined type of transaction by the bank, it shall be investigated. In applicable cases, the expected amount of transactions shall be corrected, or if there is suspicion, a Suspicious Transaction/Activity Report (STR) shall be filed. In this regard, the bank shall take care that the customer does not become a victim of harassment; (4) Updating the information obtained regarding customer due diligence in the customer identification process is an ongoing process. In this regard, based on the risk classification criteria mentioned in the CIP form, the updating process shall be performed every 05 (five) years for low-risk customers and every 01 (one) year for high-risk customers. As soon as any change in the customer's identification information is known, it shall be updated. Additionally, the customer's identification information may be updated at any time if a specific need is felt. Based on the updated information, the risk assessment of these accounts shall be reassessed immediately. Additionally, the method of determination shall also continue if any account is transferred from low risk to high risk; (5) In the case of providing banking services with priority facilities (VIP) to any customer by the bank, in addition to following other instructions regarding CDD, Enhanced Due Diligence regarding the customer shall be taken; (6) In the case of establishing and maintaining business relationships and conducting transactions with any person or entity (including legal representatives, financial institutions, and any institution) of countries that do not meet international standards for the prevention of money laundering and terrorist financing or have significant deficiencies (such as countries listed by the Financial Action Task Force (FATF) as Jurisdictions with Strategic AML/CFT Deficiencies and Countries under Increased Monitoring), Enhanced Due Diligence shall be taken, and in applicable cases, Enhanced Due Diligence shall be taken; (7) Before establishing a relationship with a foreign bank, the AML/CFT system of the relevant country shall be considered; (8) In the case of opening accounts for any foreign or non-resident Bangladeshi, the rules of the Foreign Exchange Regulation Act, 1947 and the instructions issued by Bangladesh Bank thereunder shall be followed; (9) In the case of accounts or transactions related to cross-border trade, the instructions of BFIU Circular No. 'Guidelines for Risk-Based Supervision of Cross-Border Trade' shall be followed.

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3.7 Actions if CDD cannot be performed: If CDD cannot be performed due to customer non-cooperation, or because the information/data collected regarding the customer is unreliable, or in other words, if satisfactory information regarding customer identification cannot be obtained and verified, the bank may take the following measures as necessary: (1) The bank shall not open an account for such a customer, shall not commence a business relationship, shall not execute transactions, or shall not terminate a business relationship; (2) The branch shall forward information regarding the non-opening or closure of accounts to the Money Laundering and Terrorist Financing Prevention Department (MLFPD), preserving the relevant account records. If necessary, the MLFPD shall take measures to inform all other branches of this information; and (3) The bank shall consider filing a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) regarding such customers, prospective customers, rejected persons, or entities, depending on the circumstances. (4) However, in cases where accounts are opened and managed for socially disadvantaged or specific groups of people, the BFIU shall issue instructions from time to time.

3.8 Enhanced Customer Due Diligence (Enhanced Customer Due Diligence - ECDD): Banks must adopt the following enhanced customer due diligence measures or ECDD for customers identified as high-risk (High Risk): (1) Collect additional information regarding customer identification from reliable and independent sources; (2) Take additional measures to verify the purpose of opening the account and the source of funds or wealth; (3) Regularly conduct more frequent monitoring of their account transactions; and (4) Obtain approval from the bank's Chief Money Laundering Prevention Compliance Officer, where applicable.

3.9 Actions regarding Persons with Significant Control (PSC): If a Person with Significant Control (PSC) is high-risk, the instructions mentioned in Section 3.8 of this circular must be followed regarding the opening and management of their accounts.

3.10 Actions regarding Politically Exposed Persons (PEP): In addition to following the applicable instructions mentioned in this circular regarding the opening and management of PEP accounts, the following measures must be taken where applicable:

1. Person with Significant Control (PSC) refers to "any individual who, directly or indirectly, exercises significant control over an entity, including but not limited to, individuals who own or control a majority of the voting rights in an entity, individuals who hold a majority of the board seats in an entity, or individuals who have significant influence or control over the management of an entity, such as senior managing officials."
2. Politically Exposed Person (PEP) refers to "an individual who is or has been entrusted with prominent public functions by a foreign country, including but not limited to, heads of state or of government, senior politicians, senior government or judicial officials, senior executives of state-owned corporations, important political party officials, and senior military officials." Source of items 1-2: Financial Action Task Force (FATF) Recommendations.

(1) The bank must take appropriate measures to determine whether their customer or the beneficial owner of the account is a PEP (e.g., using open information sources, various databases, etc.); (2) Obtain approval from the bank's Chief Money Laundering Prevention Compliance Officer before establishing a business relationship with a PEP or maintaining an existing relationship; (3) In addition to taking the measures mentioned in (1) and (2) above, adopt the enhanced customer due diligence measures mentioned in clauses (1) to (3) of Section 3.8 of this circular; and (4) The above-mentioned instructions shall also apply to the family members of the PEP and persons closely associated with them (Close Associates). In this section, 'PEP' shall not include any intermediary or subordinate (Intermediary and Subordinate of PEP) person.

3.11 Actions regarding Heads or Senior Management of International Organizations: (1) If the head or senior management of an international organization is high-risk, the instructions mentioned in Section 3.8 of this circular must be followed regarding the opening and management of their accounts (in this context, 'senior management' refers to directors, deputy directors, board members, or persons holding equivalent positions holding important posts in the said organization).

3.12 Other Instructions Regarding PEPs: In the implementation of the provisions of Sections 3.9, 3.10, and 3.11, banks must follow the instructions mentioned in the BFIU's "Guidelines on Politically Exposed Persons (PEPs) and Other High-Risk Customers" issued from time to time.

3.13 Actions regarding Establishment of Correspondent Banking Relationships: Banks must comply with the following instructions regarding the establishment and maintenance of domestic correspondent banking relationships to ensure that the banking system is not used for money laundering or terrorist financing: (1) Before providing correspondent banking services, the bank must obtain approval from the Chief Money Laundering Prevention Compliance Officer after collecting information according to Appendix-B to ensure the nature of the business of the correspondent or respondent bank. Where applicable, necessary information may also be collected from open sources in addition to the information according to Appendix-B; (2) A relationship with a foreign bank may only be established or maintained with satisfaction that the correspondent or respondent bank is effectively supervised and regulated by a competent authority; (3) A correspondent banking relationship shall not be established or maintained with a shell bank; (4) The bank must ensure that the respondent bank is not providing services to, or maintaining a relationship with, any shell bank.

11 (5) Enhanced measures must be taken regarding the establishment or maintenance of correspondent banking relationships with banks of countries that have not met international standards for combating money laundering and terrorist financing or have significant deficiencies (e.g., countries listed as Jurisdictions under Action or Call for Action by the Financial Action Task Force (FATF) and High-Risk Jurisdictions with Strategic AML/CFT Deficiencies). Where applicable, appropriate and effective measures must be taken to implement the Additional Due Diligence Measures imposed by the APG. Detailed information must be collected regarding the beneficial owners of these banks and their policies and procedures for combating money laundering and terrorist financing; (6) Regarding the establishment of correspondent banking relationships with respondent banks that allow their customers to conduct transactions directly through the correspondent bank (i.e., Payable-Through Accounts): (a) It must be ensured that the respondent bank properly conducts CDD for its customers; and (b) It must be ensured that the respondent bank can provide CDD information regarding the specified customer upon request from the correspondent bank. (7) All existing correspondent banking relationships must be reviewed from time to time, and the instructions mentioned in this circular shall also apply in this context.

3.14 Instructions Regarding Agent Banking: Banks operating agent banking programs must comply with the following instructions: (1) The responsibility for complying with all applicable instructions regarding money laundering and terrorist financing lies with the agent as well as the concerned bank; (2) Remain vigilant in identifying and reporting suspicious transactions or activities of agents and customers; (3) Include money laundering and terrorist prevention programs within the agent banking compliance program and arrange for appropriate training for agents; and (4) Take the following steps for the appointment of agents and monitoring of their activities: (a) Follow an appropriate verification or selection process (Due Diligence) to ensure their complete and correct identification; (b) Determine their risk level (high, medium, and low) by considering the volume and number of transactions, geographical location, nature of business and ownership, and other rational factors, and monitor their transactions and activities based on the determined risk level; (c) Regularly (quarterly) perform the task of determining the risk level by the institution; (d) Verify the compliance status of agents regarding money laundering and terrorist financing prevention;

3. The verification process shall include checking the personal information of the selected agent for appointment and verifying whether they are involved in criminal activities.

12 (e) Conduct inspection/supervision activities on a weekly basis to verify the compliance status of high-risk agents regarding money laundering and terrorist financing prevention, and forward reports regarding this to the Money Laundering and Terrorist Financing Prevention Department; (f) Conduct inspection/supervision activities for medium and low-risk agents by the institution at intervals determined by the institution; (g) Publish an updated list of agents (based on January-June) on their own website; (h) Publish a separate list of cancelled agents based on various complaints/irregularities (based on January-June) on their own website; and (i) In the context of agent banking, the applicable instructions of the BFIU's "Guidelines on Agent Banking" may be followed.

3.15 Actions regarding Non-Apparent Customers (Non-Apparent Customers): Banks must formulate policies and procedures for assessing and mitigating the risk of money laundering and terrorist financing when opening accounts or providing services to non-apparent customers, and review them from time to time. In this context, the instructions of the BFIU's "Guidelines on Non-Apparent Customers" may be followed. It is noted that 'non-apparent customers' refers to those customers who open accounts and/or conduct transactions through the internet, through the bank's agents, or through their professional representatives (lawyers, accountants, etc.) without physically appearing at the bank branch.

3.16 Actions Regarding Adoption of New Services or Technologies: Banks must identify the money laundering and terrorist financing risks associated with any new product or service or technology based on technology (e.g., internet banking, electronic cards, e-KYC, SWIFT transaction platforms, etc.) introduced by the bank, or the development of existing products, services, or technologies; determine their magnitude; and take appropriate measures to mitigate the risks created by such products, services, or technologies. It is noted that the aforementioned measures must be taken before the introduction of newly invented products, services, or technologies, or the development of existing products, services, or technologies.

3.17 Protection of Confidentiality: Banks must ensure confidentiality regarding information related to the identification and reporting of suspicious transactions or activities, and also ensure appropriate confidentiality of information verified by the BFIU from time to time. In this regard, the instructions mentioned in Circular Letter No. 1 issued by the BFIU on 22/04/2018 must be followed.

4. Actions Regarding Bank Branches and Subsidiary Institutions Located Abroad: (1) Each bank must ensure proper compliance with the provisions of the Money Laundering Prevention Act, 2012, the Anti-Terrorism Act, 2009, and the rules and regulations issued thereunder, as well as the instructions issued by the BFIU from time to time, regarding their branches and subsidiary institutions located abroad;

13 (2) If a branch or subsidiary institution located abroad is unable to properly comply with the instructions mentioned in 4(1) for any reason, the said institution must take applicable measures for money laundering and terrorist financing risk management and immediately inform the BFIU of the inability; and (3) The instructions mentioned in this circular shall also apply to the Branch-Office (BO) of any bank licensed by Bangladesh Bank.

5. Transaction Monitoring: Considering the importance of transaction monitoring in identifying suspicious transactions, each bank must bring the following matters under supervision with utmost vigilance and caution regarding the monitoring of customer transactions: (1) Each bank must monitor customer transactions regularly through manual and/or automated methods; (2) All complex, unusual, and transactions that appear to have no economic or visible purpose must be scrutinized with greater importance to take steps to identify suspicious transactions/activities. Additionally, the indicators mentioned in the "Guidelines on Identifying Suspicious Transactions/Activities" and "Guidelines on Reporting Suspicious Transactions/Activities" must be considered; (3) In transaction monitoring, banks must remain vigilant to identify whether any activity (Transaction) is being organized in the branch as mentioned in Section 2(f)(i) of the Money Laundering Prevention Act, 2012; (4) In transaction monitoring, all domestic currency transactions and all transactions conducted through electronic means must be considered; and (5) In transaction monitoring, matters related to relevant resolutions of the United Nations Security Council, persons listed or organizations declared prohibited by the Government of Bangladesh, and countries that have not met international standards for combating money laundering and terrorist financing or have significant deficiencies must be considered.

6. Submission of Cash Transaction Reports (CTR): Banks must follow the following matters regarding the submission of Cash Transaction Reports to the BFIU: (1) Each bank branch must examine the transactions of the previous month. If the amount of deposit or withdrawal (any type of cash deposit or withdrawal including online, ATM, etc.) in a single account on a single day through one or more transactions reaches 10 (ten) lakh Taka or its equivalent in foreign currency or equal value in domestic currency, it must be submitted monthly to the BFIU as a Cash Transaction Report through the respective Money Laundering and Terrorist Financing Prevention Department; (2) The monthly Cash Transaction Report must be submitted faithfully by the 21st of the following month using Form B using Form B (Form B can be downloaded from the web link: www.bfiu.gov.bd/bn/crptb); and (3) If any suspicious transaction is observed during the regular review of the Cash Transaction Report, it must be submitted to the BFIU as a Suspicious Transaction Report;

14 (4) The Cash Transaction Report of the branch must be preserved monthly at the concerned branch (however, if a bank preserves this information centrally, it must have branch access if necessary); (5) There is no need to submit a Cash Transaction Report for cash deposits in government accounts (various ministries, local government, and various government departments), government-owned institutions, semi-government, or autonomous institutions, but a Cash Transaction Report must be submitted for cash withdrawals as per regulations; (6) There is no need to submit a Cash Transaction Report for cash deposits in accounts operated for the purpose of collecting fees/tuition fees of educational institutions such as schools, colleges, universities, and government utility bills (electricity, water, gas, etc.), but a Cash Transaction Report must be submitted for cash withdrawals; and (7) There is no need to submit a Cash Transaction Report for inter-bank and inter-branch cash transactions.

7. Submission of Suspicious Transaction Reports (STR): Banks must follow the following matters regarding the submission of Suspicious Transaction Reports to the BFIU: (1) To implement the instructions mentioned in Section 25(1)(d) of the Money Laundering Prevention Act, 2012, and Section 16(1) of the Anti-Terrorism Act, 2009, all departments of the bank must remain vigilant and cautious in identifying suspicious transactions in the daily transactions or activities of customers; (2) In identifying suspicious transactions, bank staff must consider the definitions mentioned in Section 2(y) of the Money Laundering Prevention Act, 2012, and Section 2(16) of the Anti-Terrorism Act, 2009; (3) As soon as a suspicious transaction or activity is identified by any department of a bank branch, it must be informed in writing to the Branch Money Laundering Prevention Compliance Officer. The Branch Money Laundering Prevention Compliance Officer must immediately and appropriately investigate the reported transaction or activity, record and preserve the observations in detail. If the said transaction or activity is considered suspicious, it must be forwarded immediately to the Money Laundering and Terrorist Financing Prevention Department with necessary documents; (4) The Money Laundering and Terrorist Financing Prevention Department must review whether the suspicious transaction or activity received from the branch has been reported appropriately with necessary information/data or documents. Where applicable, additional information (if available) must be added, and the STR/SAR must be submitted immediately using Form B and following the instructions of Form B; (5) Even if a transaction or activity is not identified as suspicious by the branch management, if any transaction or activity is suspected to be suspicious by the Money Laundering and Terrorist Financing Prevention Department, it must be submitted as a Suspicious Transaction Report; (6) The bank must preserve the information of the Suspicious Transaction/Activity Report until further instructions are issued by the BFIU; and (7) In identifying and reporting suspicious transactions/activities, banks must follow the instructions of the BFIU's "Guidelines on Identifying Suspicious Transactions/Activities".

15 8. Self-Assessment and Independent Testing: To establish an effective system for combating money laundering and terrorist financing, the bank's internal audit department must appoint experienced staff to analyze self-assessment reports received from branches and to properly perform independent testing.

8.1 Actions of Branches: (1) Each branch must evaluate itself annually based on the checklist (Appendix-'G') determined for self-assessment; (2) Before finalizing the said evaluation report, the branch must organize a meeting chaired by the Branch Manager with the relevant staff of the branch. If the problems identified through discussion on the draft of the branch evaluation report in the meeting cannot be resolved by the branch management, the problems mentioned in the report must be forwarded to the Internal Audit Department of the Head Office and the Money Laundering and Terrorist Financing Prevention Department for resolution, and the progress of the recommendations sent to the Head Office for resolving the identified problems must be discussed in the next quarterly meeting.

8.2 Actions of the Internal Audit Department: (1) The Internal Audit Department must verify the self-assessment reports received from branches. If any risky matter is observed in any branch, immediate inspection of that branch must be arranged, and the matter must be informed to the Money Laundering and Terrorist Financing Prevention Department; (2) The Internal Audit Department must examine the money laundering and terrorist financing prevention activities of the concerned branch based on the checklist (Appendix-"G") determined in the Independent Testing Procedure during the execution of inspection/supervision activities of various branches according to their own and regular weekly inspection/supervision schedule, and forward a report to the concerned branch after determining the branch rating. Additionally, in addition to the regular weekly inspection/supervision schedule, independent testing procedures must be conducted for at least 10% (ten percent) of branches based on the checklist (Appendix- "G") determined in the Independent Testing Procedure, examining the compliance matters related to the money laundering and terrorist financing prevention activities of the concerned branch, and preparing a report after determining the branch rating; (3) The Internal Audit Department must send a copy of the report containing the ratings of the inspected/audited branches to the Money Laundering and Terrorist Financing Prevention Department of the bank; and (4) In the case of banks engaged in agent banking programs, the Internal Audit Department must conduct inspection/supervision activities on at least 5% (five percent) of agents on a weekly basis to verify the compliance status of the money laundering and terrorist financing prevention activities of their agents regarding the relevant matters, and send a copy of the report regarding this to the Money Laundering and Terrorist Financing Prevention Department.

8.3 Actions of the Money Laundering and Terrorist Financing Prevention Department: (1) The Money Laundering and Terrorist Financing Prevention Department must prepare a checklist-based evaluation report (similar to the report mentioned in Section 1.3(2) of this circular) of the inspected branches for the considered half-yearly period based on the self-assessment reports received from branches and the inspection/audit reports submitted by the bank's Internal Audit Department. The said report must necessarily include the following matters along with other matters: (a) The total number of branches and the total number of self-assessment reports received from branches; (b) The number of branches inspected/audited by the Internal Audit Department and the status of the branches (branch-wise score); (c) Measures taken by the Money Laundering and Terrorist Financing Prevention Department to prevent the irregularities mentioned in the received self-assessment reports that are common in a large number of branches; (d) General and specific irregularities mentioned in the reports submitted by the Internal Audit Department and measures taken by the Money Laundering and Terrorist Financing Prevention Department to prevent such irregularities; and (e) Measures taken to ensure compliance and improve the ratings of branches evaluated as "Unsatisfactory" and "Critical" in the received reports. (2) If any risky matter is observed in any branch while verifying the self-assessment reports received from branches, immediate inspection of that branch must be arranged through inspection or the Internal Audit Department, and the matter must be brought to the notice of the competent authority.

9. Wire Transfer: "Wire Transfer" refers to any monetary transaction in which a bank or financial institution, on behalf of a customer or entity, transfers funds to another bank or institution's branch using electronic means to a beneficiary person or entity.

9.1 Ensuring Collection of Information for All Types of Wire Transfers: (1) Domestic Wire Transfer: (a) In the case of domestic wire transfers of amount 1,000 (one thousand) US Dollars or more, or its equivalent in other domestic currencies, under general or special permission, the correct information of the applicant must be collected, preserved, and forwarded to the intermediary/beneficiary bank. The said information must include the account number of the applicant, or if there is no account number, the specific reference number of the transaction (Transaction Reference Number) so that the subsequent transaction can be easily found. Additionally, the said information must include the account number of the beneficiary, or if there is no account number, the specific reference number of the transaction (Transaction Reference Number) so that the subsequent transaction can be easily found.

4. Domestic Wire Transfer refers to any monetary transaction where the applicant and beneficiary are located in different countries. Furthermore, in the case of multiple interconnected transfers, if at least one transaction is executed outside the country, it shall also be considered a domestic wire transfer.
5. Applicant (Originator) refers to any person or entity (account holder or non-account holder) on whose request the concerned bank performs the said wire transfer activity.
6. Correct information of the applicant refers to information such as the name and address of the applicant or national ID card or date of birth, the accuracy of which has been verified.

17 (x) (1)(c) In the case of transactions below the limit specified in sub-paragraph (c) of clause (1), the application must include information regarding the applicant and beneficiary (which does not require verification), such as name, address, etc., and account number or, if no account number exists, the specific source number of the transaction (Transaction Reference Number), so that the subsequent transaction can be easily traced. (g) In the case of providing information regarding the beneficiary of domestic wire transfers to the beneficiary, the bank must preserve information regarding the beneficiary; and (h) In cases where a single applicant sends batch files (batch files) to multiple beneficiaries through multiple domestic wire transfers, the batch file must include the correct and complete information of the applicant and the beneficiary. Furthermore, the account number of the applicant and beneficiary, or if no account number exists, the specific source number of the transaction (Transaction Reference Number) must be included, so that the subsequent transaction can be easily traced. (2) Domestic Wire Transfer: (a) In the case of domestic wire transfers executed by the bank, the bank must comply with the instructions specified in Section 9.1(1) of this circular regarding the collection and verification of identity information of the applicant or beneficiary; (b) In the case of wire transfers using debit or credit cards (excluding payment for goods and services), the bank must preserve information similar to that in 2(c) above regarding the instruction/cancellation of payment; and (c) In the case of wire transfers in favor of government, semi-government, or autonomous institutions, compliance with the relevant instructions is not mandatory. In the case of intra-bank transactions, the instructions specified in clause 2(c) above are considered to continue to be applicable. 9.2 Other Instructions Regarding Wire Transfers: (1) During the operation of the relevant program, all concerned parties must follow the instructions issued by Bangladesh Bank, the instructions issued from time to time by this unit, and all relevant laws and regulations; (2) In the case of domestic and international wire transfers, the instructions specified in clauses (2) and (10) of this circular must be complied with.

7 Beneficiary (Beneficiary) means any person or institution (account holder or non-account holder) in whose favor the value is sent. 8 Domestic Wire Transfer (Domestic Wire Transfer) means a transaction where the applicant and beneficiary are located in the same country. In this regard, even if the process used in multiple interconnected transfers is completed in another country, it will be considered a domestic wire transfer. Source: Financial Action Task Force Recommendations Nos. 4-8.

18 9.3 Obligations of Ordering, Intermediary, and Beneficiary Banks: (1) Ordering Bank: The ordering bank must ensure the correct and complete information of the applicant in the case of wire transfer transactions. Additionally, the ordering bank must collect the value information of the beneficiary. All such information must be preserved for a minimum of 05 (five) years and must be provided immediately upon request by the appropriate authority. Furthermore, the ordering bank must not execute any domestic or international wire transfer program without fulfilling the instructions specified in clauses 9(1) and (2) of this circular. (2) Intermediary Bank: (a) In the case of both domestic and international wire transfers, if any bank acts as an intermediary between the ordering bank and the beneficiary bank, that bank must ensure the preservation of information regarding the applicant and beneficiary. Appropriate measures must be taken to identify missing information regarding the applicant and beneficiary. Additionally, information received from the ordering bank (or any other intermediary bank, if applicable) must be preserved by the intermediary bank/institution for a minimum of 05 (five) years; and (b) In the case of executing wire transfers by each intermediary bank, the concerned bank must have a risk-based policy and procedure for executing, suspending, or canceling the said transfer and for necessary follow-up actions in the absence of information regarding the applicant or beneficiary. (3) Beneficiary Bank: (a) The beneficiary bank involved in the wire transfer transaction program must undergo a risk-based procedure to check whether there is any deficiency in the complete information of the applicant or beneficiary. If there is any deficiency in the complete information of the beneficiary or if identity verification has not been done, [in the case of transactions of amount not less than 1,000 (one thousand) or more in US Dollars or equivalent amount in foreign currency], the concerned parties must collect information or verify identity through mutual communication or other means if necessary. At the time of paying the value to the recipient/beneficiary, the beneficiary bank must collect the complete and correct information of the recipient/beneficiary and preserve the relevant information for a minimum of 05 (five) years; and (b) In the case of executing wire transfers by each beneficiary bank, the concerned bank must have a risk-based policy and procedure for executing, suspending, or canceling the said transfer and for necessary follow-up actions in the absence of information regarding the applicant or beneficiary. 10. Prevention of Terrorist Financing and Proliferation Financing (Prevention of Terrorist Financing and Prevention of Proliferation Financing of Weapons of Mass Destruction): To implement Resolution 1267 of the United Nations Security Council and its subsequent resolutions, Resolution No. 1373 of the United Nations Security Council, and resolutions regarding the prevention, suppression, and obstruction of the proliferation of weapons of mass destruction and the financing thereof, banks must take the following steps:

19 (1) Each bank must establish a procedure to prevent and detect transactions related to terrorist financing and the proliferation of weapons of mass destruction through the approval of the bank's management committee, issue instructions regarding the responsibilities of the bank's employees, monitor them from time to time, and ensure that the instructions issued by BFIU are properly complied with; (2) As soon as news regarding terrorist financing and the proliferation of weapons of mass destruction is published in the media, if any person or entity involved in the said crime is operating any bank account, the concerned bank must immediately send detailed information regarding this to BFIU; (3) Each bank must preserve the updated information electronically of any person or entity listed under suspicion of terrorism, terrorist financing, and proliferation of weapons of mass destruction under various resolutions of the United Nations Security Council, and any person or entity declared listed or prohibited by the Government of Bangladesh, and ensure their proper use; (4) Each bank must take regular programs to identify whether any bank account exists or any transaction has occurred in the name of any person or entity listed under any resolution of the United Nations Security Council or by the Government of Bangladesh, or in the name of any person or entity directly or indirectly controlled by them or any associate. Additionally, the bank must monitor transactions if necessary. Information regarding findings9 obtained in this process must be preserved. As soon as any bank account or transaction of any person or entity listed or declared prohibited by the Government of Bangladesh, or any person or entity directly or indirectly controlled by them or any associate, is identified, the concerned bank must suspend the transaction of the said account or the transaction and send detailed information regarding this to BFIU within the next working day; and (5) In the implementation of the resolutions of the United Nations Security Council regarding terrorist financing and the proliferation of weapons of mass destruction, the instructions of the "Guidelines for Reporting Entities on Prevention of Terrorist Financing and Prevention of Proliferation Financing of Weapons of Mass Destruction" issued by BFIU must be followed. 11. Employment and Training: 11.1 Employment: To mitigate the risk of money laundering, terrorist financing, and proliferation of weapons of mass destruction, banks must consider the following matters in the recruitment of employees/officials: (1) Follow appropriate verification procedures (background checks) in the recruitment process; and (2) Assign a sufficient number of qualified employees to the Anti-Money Laundering and Terrorist Financing Department.

9 Findings mean information obtained through monitoring of transactions, accounts, and customers, including information on suspicious transactions, suspicious accounts, and suspicious customers, and information on compliance with the Anti-Money Laundering, Terrorist Financing, and Prevention of Proliferation Financing of Weapons of Mass Destruction Act, 2012. 10 In identifying bank accounts or transactions, all types of services provided by the bank shall be considered.

20 11.2 Training - Bank Employees: To ensure proper compliance with the program to prevent money laundering, terrorist financing, and proliferation of weapons of mass destruction, banks must take the following steps: (1) Make arrangements to provide appropriate training11 to all employees of the bank regarding money laundering, terrorist financing, and the prevention of proliferation of weapons of mass destruction. In this regard, appropriate training means training of various types (formal and informal) for employees of various levels and departments regarding money laundering and terrorist financing prevention, and the relevant money laundering and terrorist financing risks associated with their programs, and periodic training at fixed intervals; (2) Provide appropriate training and/or professional certification to increase the competence of the Chief and Deputy Chief Anti-Money Laundering Compliance Officers and other concerned employees; and (3) Preserve information and documents regarding bank training. 11.3 Training - Bank Customers: To increase customer awareness regarding the prevention of money laundering, terrorist financing, and proliferation of weapons of mass destruction, banks must take the following steps: (1) The bank must inform customers about the accuracy of various verified information collected and documents submitted at the time of opening their accounts, and distribute leaflets from time to time and arrange to install posters on this matter in visible places in each bank branch to increase customer awareness regarding the prevention of money laundering, terrorist financing, and proliferation of weapons of mass destruction; and (2) Additionally, make arrangements to propagate awareness-raising advertisements, information graphics, etc., on this matter through various media including mass media. 12. Preservation of Records and Necessary Information/Documents: (1) The bank must preserve the following necessary information/documents regarding any customer for a minimum of 05 (five) years after the closure of the account: (a) Information/documents regarding domestic and foreign transactions, all information and documents collected during the execution/updation of the CDD process, and all information/documents regarding any report on any customer or any type of account or transaction monitoring or any report on the bank's compliance status; and (b) Information/documents regarding transactions conducted by DD-RA (DD-RA). (2) Preserve information and documents regarding training, meetings, inspections/surveys, and special surveys related to money laundering and terrorist financing; and (3) In applicable cases, present preserved information/documents as documentary evidence in judicial proceedings of criminal cases, and provide all preserved information and documents to BFIU as per its demand or instructions.

11 Appropriate training means various types (formal and informal) of training for employees of various levels and departments and periodic training at fixed intervals.

21 13. Others: (1) The instructions of all previous circulars and circular letters issued by BFIU applicable to scheduled banks, except the circulars and circular letters listed below, are considered to be replaced by this circular; (2) During the operation of the relevant program, all concerned parties must compulsorily follow the instructions issued by Bangladesh Bank, the instructions issued from time to time by this unit, and all relevant laws or regulations; and (3) The instructions of this circular will come into force immediately.

Yours faithfully,

Attachment: As per list.

(Md. Zakir Hossain, Chief Manager) Phone: 9530118 Copy No.- BFIU(Policy)-3/2020- 131 Date: Unlisted Copies are sent to the following for information and necessary action: (Not in order of seniority)

1. Senior Secretary, Ministry of Finance, Public Institutions Division, Bangladesh Secretariat, Dhaka.
2. Chairman, Bangladesh Securities and Exchange Commission, Agargaon, Sher-e-Bangla Nagar, Dhaka.
3. All Divisional Chief, Bangladesh Bank, Head Office, Dhaka.
4. Executive Director/Chief Manager, Bangladesh Bank, Motijheel, Dhaka/Chittagong/Rajshahi/Khulna/Bogura/Sylhet/Barishal/Rangpur/Mymensingh/Sadarghat, Dhaka.
5. Executive Director, Bangladesh Bank Training Academy, Mirpur, Dhaka.
6. Chairman, Bangladesh Association of Banks, Jabbar Tower, 42 Gulshan Avenue, Dhaka.
7. Chairman, Association of Bankers Bangladesh, 73 Eastern Commercial Complex, Kakrail, Dhaka.
8. Director General, Bangladesh Institute of Bank Management, Mirpur, Dhaka.
9. Secretary General, The Institute of Bankers Bangladesh, D.R. Tower (13th Floor), Ghazi Golum Dastagir Road, Paltan, Dhaka.
10. Chief Manager, Secretariat of His Excellency the Governor, Bangladesh Bank, Head Office, Dhaka.
11. Personal Staff of His Excellency the Governor, Bangladesh Bank, Head Office, Dhaka.
12. Deputy Director/Assistant Director attached with the Deputy Governors, Bangladesh Bank, Head Office, Dhaka.
13. Personal Assistants of Chief Economist/Chief Economic Advisor/Executive Directors, Bangladesh Bank, Head Office, Dhaka.

(Md. Masud Rana) Deputy Director

Circular/Circular Letter No. Date of Issue Subject AML Circular No.-22 21/04/2009 In the context of the issuance of the Anti-Terrorism Act, 2009. BFIU Circular No.-02 15/03/2012 In the context of the issuance of the Money Laundering Prevention Act, 2012. BFIU Circular Letter-01 30/01/2012 In the context of the naming of BFIU. BFIU Circular No.-07 14/07/2013 In the context of the issuance of the Anti-Terrorism (Amendment) Act, 2013. BFIU Circular Letter No.- 01 08/01/2015 In the context of Money Laundering and Terrorist Financing Risk Management Guidelines. BFIU Circular Letter No.- 03 09/04/2015 In the context of the issuance of the Anti-Terrorism Rules, 2013. BFIU Circular Letter No.- 06 08/12/2015 In the context of the issuance of the amendment to the Money Laundering Prevention Act, 2012. BFIU Circular Letter No.- 01 11/02/2016 In the context of the implementation of United Nations Security Council Resolutions. BFIU Circular Letter No.- 01 22/04/2018 In the context of protection of information confidentiality. BFIU Circular No.-22 31/01/2019 In the context of information exchange among Reporting Institutions. BFIU Circular No.-23 31/01/2019 In the context of internal control of financial groups and overseas branches and subsidiaries. BFIU Circular Letter No.- 01 24/02/2019 In the context of the issuance of Money Laundering Prevention Rules, 2019. BFIU Circular No.-24 10/12/2019 In the context of Trade-Based Money Laundering Guidelines. BFIU Circular No.-25 08/01/2020 In the context of e-KYC Guidelines.

Appendix-K Confidential and to be filled by the Bank 22 ............Bank/Bank Ltd. .............Branch Customer Identification Form (CDD Form) (To be used for individual accounts)

1. Name of the Account:
2. Nature of the Account:
3. Purpose of Opening the Account:
4. Occupation of the Customer (Detailed):
5. Monthly Expected Income of the Customer:
6. Source of Funds/Sources (Detailed):
7. How was the source of funds of the account holder verified (Detailed with documents):......................
8. How was the address(es) of the account holder verified (Detailed):........................................ ...............................................................................................................................
9. Is there a Beneficial Owner (BO) of the account: Yes No (If the answer is Yes, KYC must be conducted for each actual beneficial owner as per Annex-1)
10. Identity Document (Any one): Copy Received Verified [Tick (√)] a) National ID Number: ............................ (If applicable) b) Passport Number: ............................. (If applicable) c) Birth Registration Certificate Number: ............................ (If applicable) d) Others: .................................
11. In the case of Non-Resident (NRI) and Foreigners: (a) Nature of Visa: ............................. Expiry Date: ............................. (b) In the case of opening accounts for holders of Certificate of Registration (COR), has the Certificate of Registration (COR) document been collected and approval obtained from the appropriate authority for opening the bank account: Yes No (In the case of Non-Resident Bangladeshis, a copy of the passport and in the case of foreigners, a copy of the passport along with the visa must compulsorily be collected.)
12. Is the Customer a Politically Exposed Person (PEP)/Influential Person (IP)/Principal or Senior Official of a Domestic Organization and their family members or close associates: Yes No If the answer is Yes: a. Has approval been obtained from Senior Management: Yes No b. Has a face-to-face interview with the customer been conducted: Yes No Account Number: ............................. Unique ID Code: ..................

Appendix-K Confidential and to be filled by the Bank 23 13. In light of the relevant laws, rules, and circulars, has any match been found after checking the customer's name against the list of names of any person or entity listed under suspicion of terrorist activities, terrorist financing, and proliferation of weapons of mass destruction under various resolutions of the United Nations Security Council, or any person or entity listed or declared prohibited by the Government of Bangladesh: Yes No a) If the answer is Yes, description of measures taken in this regard: 14. Risk Rating (According to Annex-2): Sum of Risk Scores Overall Risk Rating

=15 High <15 Low Remarks: (* Even if the Risk Rating is less than 15, the customer may be determined as high risk considering other risks such as BO - High Risk, by mentioning the reason in the remarks.)* Prepared by: (Account Opening Officer/Relationship Manager) Signature (with Seal): Name: Date: Reviewing and Verifying Officer: (Branch Manager/Branch Anti-Money Laundering Compliance Officer) Signature (with Seal): Name: Date:

................................................................. (In the case of PEP/IP/Domestic Organization, Approving Senior Management) Signature and Date with Named Seal 15. Date of Last Review and Updation of Account and Customer Information: Reviewing and Updation Officer: Signature (with Seal): Name: Date:

Appendix-K Confidential and to be filled by the Bank 24 ............Bank/Bank Ltd. .............Branch Customer Identification Form (CDD Form) (To be used for institutional accounts)

1. Name of the Account:
2. Nature of the Account:
3. Nature of the Institution (Detailed):
4. Net Assets of the Institution:
5. Source of Funds/Sources (Detailed):
6. Which documents were collected to verify the source of funds:
7. .................
8. ..................
9. .................. Have the collected documents been verified: Yes No
10. How was the address(es) of the institution verified (Detailed): ............................................. ...............................................................................................................................
11. Has the Beneficial Owner (BO) of the account been determined: Yes No If the answer is Yes, KYC must be conducted for each actual beneficial owner as per Annex-1: (In the case of a company, KYC must be conducted for each single shareholder holding 20% or more shares as per Annex-1. Additionally, KYC must be conducted for the controlling shareholder of the company.) Copy Received Verified [Tick (√)]
12. Electronic-Tax ID (E-TIN) Number: .......... (If applicable)
13. VAT Reg. Number: ...................................... (If applicable)
14. Registration Number of the Institution: .............................. (If applicable)
15. Other documents: ---------------------------------- (If applicable)
16. Purpose of opening account for foreign company/institution: (If applicable) ............................................................................................................................... (a) Name of the relevant controlling authority: ............................................................................ (b) Information regarding approval: .......................................................................................... Account Number: ............................. Unique ID Code: .................. ............

Appendix-K Confidential and to be filled by the Bank 25 14. Is there any Politically Exposed Person (PEP)/Influential Person (IP)/Principal or Senior Official of a Domestic Organization and their family members or close associates associated with the customer institution (If applicable): Yes No If the answer is Yes- a. Has approval been obtained from Senior Management: Yes No b. Has a face-to-face interview with the customer been conducted: Yes No 15. In light of the relevant laws, rules, and circulars, has any match been found after checking the customer's name against the list of names of any person or entity listed under suspicion of terrorist activities, terrorist financing, and proliferation of weapons of mass destruction under various resolutions of the United Nations Security Council, or any person or entity listed or declared prohibited by the Government of Bangladesh: Yes No a) If the answer is Yes, description of measures taken in this regard: 16. Risk Rating (According to Annex-2): Sum of Risk Scores Overall Risk Rating

=15 High <15 Low Remarks: (Even if the Risk Rating is less than 15, the customer may be determined as high risk considering other risks such as BO - High Risk, by mentioning the reason in the remarks.) Prepared by: (Account Opening Officer/Relationship Manager) Signature (with Seal): Name: Date: Reviewing and Verifying Officer: (Branch Manager/Branch Anti-Money Laundering Compliance Officer) Signature (with Seal): Name: Date:

................................................................. (In the case of PEP/IP/Domestic Organization, Approving Senior Management) Signature and Date with Named Seal 17. Date of Last Review and Updation of Account and Customer Information: Reviewing and Updation Officer: Signature (with Seal): Name: Date:

Appendix-A Confidential and to be filled by the Bank 26 ............Bank/Bank Ltd. .............Branch Customer Identification Form (KYC) (To be used for Special Schemes/Fixed Deposit Accounts)

1. Name of the Account:

2. Nature of the Account:

3. Occupation of the Customer (Detailed):

4. Customer's Monthly Expected Income:

5. Source of Funds/Sources (Detailed):

6. Documents collected to verify the source of funds:

7. .................

8. ..................

9. .................. Have the collected documents been verified: Yes No

10. How has the account holder's address been verified (Detailed): ....................................................

11. Has the Ultimate Beneficial Owner (UBO) been determined: Yes No If the answer is Yes, KYC must be conducted for each Ultimate Beneficial Owner according to Annex-1. (In the case of a company, KYC must be conducted for any single shareholder holding 20% or more shares according to Annex-1. Additionally, KYC must be conducted for the controlling shareholder of the company.)

12. Identification Documents: Copy Taken Verified [Tick (√) mark] a) Passport Number: ........................................ (If applicable) b) National ID Number: ............................. (If applicable) c) Birth Registration Certificate Number: ............................ (If applicable) d) Electronic-Tax ID (E-TIN) Number: ....... (If applicable) e) VAT Reg. Number: ...................................... (If applicable) f) Establishment Registration Number: ................................ (If applicable) g) Others: ...............................................................................................

13. Purpose of opening the account for Non-Resident (NRI) and Foreigners: ................................................................................................................... a) Nature of Visa.......................................... Expiry Date:............................. b) In the case of opening an account for a Commercial Certificate holder, is the Commercial Certificate and the approval of the competent authority for opening a bank account available: Yes / No (If applicable) .................................................................................................................................. (In the case of Non-Resident Bangladeshis, a copy of the passport must be collected compulsorily, and in the case of foreigners, a copy of the passport along with the visa must be collected compulsorily)

Account Number: ............................. Unique ID Code: ..................

Appendix-A Confidential and to be filled by the Bank 27

11. Is the customer a Principal or Senior Official of a Politically Exposed Person (PEP) / Politically Exposed Person (PEP) / International Organization, or a family member or close associate: Yes No If the answer is Yes: a. Has approval been obtained from Senior Management: Yes No b. Has a face-to-face interview with the customer been conducted: Yes No

12. Based on relevant laws, rules, and regulations, has any match been found with the names of any person or entity suspected of involvement in terrorist activities, terrorist organizations, or weapons of mass destruction proliferation under various UN Security Council resolutions, or with the names of any person or entity listed by the Government of Bangladesh or declared prohibited:

Yes No a) If the answer is Yes, description of measures taken:

13. Risk Grading (According to Annex-2): Sum of Risk Scores Overall Risk Rating

=15 High <15 Low

Note: (* Even if the Risk Rating is less than 15, considering UBO and other risk factors, the customer may be determined as high risk by mentioning reasons)

Prepared by: (Account Opening Officer/Relationship Manager) Signature (With Seal): Name: Date:

Reviewing and Verifying Officer: (Branch Manager/Branch Money Laundering Prevention Compliance Officer) Signature (With Seal): Name: Date: ................................................................. (In the case of Senior Officials of PEPs/PEPs/International Organizations, approval by the competent Senior Official) Signature, Name with Seal, and Date

14. Date of last review and update of account and customer information (Review & Update): ...................................................................................................................... Reviewing and Updating Officer: Name (With Seal) Signature and Date

Appendix-A Confidential and to be filled by the Bank 28 ............Bank/Bank Ltd: .............Branch Customer Identification Form (KYC) (To be used for Government/Semi-Government/Autonomous Institution Accounts)

1. Name of the Account:

2. Nature of the Account:

3. Nature of the Institution (Detailed):

4. Source of Funds/Sources (Detailed):

5. Documents collected to verify the source of funds:

6. .................

7. ..................

8. .................. Have the collected documents been verified: Yes No

9. How has the institution's address(es) been verified (Detailed): ........................... ...............................................................................................................................

10. Institution Documents: Copy Taken Verified [Tick (√) mark] a) Electronic-Tax ID (E-TIN) Number: ....... (If applicable) b) VAT Reg. Number: .................................. (If applicable) c) Decision regarding operation of bank account:........ (If applicable) d) Other documents: ...................................... (If applicable)

11. Risk Grading: High Risk/ Low Risk (* Customer's risk may change due to risk factors)

Prepared by: (Account Opening Officer/Relationship Manager) Signature (With Seal): Name: Date:

Reviewing and Verifying Officer: (Branch Manager/Branch Money Laundering Prevention Compliance Officer) Signature (With Seal): Name: Date:

9. Date of last review and update of account information (Review & Update): Reviewing and Updating Officer: Signature (With Seal): Name: Date: Account Number: ............................. Unique ID Code: ..................

Annex-1 29 (To be filled for the Ultimate Beneficial Owner of the account.) Date:............................... Account Number: .................................. Unique ID Code: ..........................

1. Title of the Account (In Bengali): ..................................................................................................... (In English) .................................................................................................

2. Name of the Ultimate Beneficial Owner (In Bengali):............................................................................................ (In English): ...............................................................................................

3. Date of Birth:.....................................................................................................................

4. Father's Name:....................................................................................................................

5. Mother's Name:.....................................................................................................................

6. Husband/Wife's Name:.....................................................................................................................

7. Nationality:.................................................................... 8. Gender: ...................................

8. Occupation (Detailed):...................................................................................................................

9. Monthly Income:.....................................................................................................................

10. Source of Funds (Detailed): ..........................................................................................................

11. Tax ID Number (TIN) (If any): .........................................................................................

12. (a) Current Address: Road/Village:....................... PO:................................ Thana:.......................... District:.......................... Phone/Mobile Number:................................Email:...................................... (b) Permanent Address: Road/Village:..............................PO:................................Thana:............................ District:........................... Phone/Mobile Number:................................Email:.....................................

13. Identification Document: (a) National ID Number:................................................................................. Or, (b) Passport Number/ Birth Registration Number/ Others (Must be specified): ...................

[Photo of the Ultimate Beneficial Owner of the Account]

30 Customer Risk Assessment Form: Product/Service & Channel Risk Score Type of Product/Service Savings Account 1 Current Account 4 FDR 3 Deposit Scheme (Up to 12 Lakhs) 1 Deposit Scheme (Above 12 Lakhs) 3 FC Account 5 SND 3 RFC 5 Type of Onboarding Through Branch Manager/Relationship Manager 2 Through Sales Representative 3 Internet/Non-Face-to-Face 5 Walk-in 3 Related Risk Score According to BFIU Circular, is the customer a Principal or Senior Official of a PEP/PEP/International Organization: No 0 Yes 5 According to BFIU Circular, is the customer a family member or close associate of a Principal or Senior Official of a PEP/PEP/International Organization: No 0 Yes 5 Transaction Risk Score Customer's Annual Turnover: Individual Institution Below 10 Lakh Taka 1 0 10 Lakh to 50 Lakh Taka 2 1 50 Lakh to 5 Crore Taka 3 2 Above 5 Crore Taka 5 4 Geographic Risk Score Non-Resident Risk Customer: Resident Bangladeshi 1 Non-Resident Bangladeshi 2 Foreign National 3 For Foreign Nationals: Risk classification based on country of birth/residence Is the citizen of the country the customer is a citizen of, classified as a High-Risk Jurisdiction by FATF or a Country with Strategic AML/CFT Deficiencies, or is the customer listed in the UN or any other Sanctions List: Yes 5 No 1 Transparency Risk Score Does the customer provide reliable information about the source of funds: Yes 1 No 5 Business and Occupation Risk Score Business Included in Annex-1 List..... Operations Included in Annex-1 List.....

Annex-2

31 Follow the list below for risk assessment related to business and occupation: Business (Advertising) 3 Service Provider 3 Tobacco and Cigarette Business 3 Entertainment Park/Entertainment Business 3 Motor Parts Trader/Workshop 3 Poultry/Dairy/Fishing Farm 2 Agro Business/Rice Mill/Beverage 2 Small Business (Investment less than 50 Lakh Taka) 2 Computer/Mobile Phone Dealer 2 Manufacturer (Excluding Weapons) 2 Others (Specifically) 1-5 Customer's Business Type Score Jewelry/Gold/Precious Metals Business 5 Money Changer/Courier Service/Mobile Banking Agent 5 Real Estate Developer/Agent 5 Construction Project Promoter/Contractor 5 Industrial and Antiquities Dealer 5 Restaurant/Bar/Night Club/Pool/Residential Hotel Business 5 Import/Export and Import/Export Agent 5 Manpower Export Business 5 Arms Business 5 Garments Business/Garments Accessories/Packaging/Buying House 5 Share/Stock Dealer, Broker, Portfolio Manager, Merchant Banker 5 Software/IT Business 5 Offshore/Non-Resident Corporation 5 NGO/NPO 5 Film Production/Distribution Organization 5 Mobile Phone Operator/Internet or Cable TV Operator 5 Land/House Broker 5 Insurance/Brokerage Agency 5 Religious Institution/Organization and Educational Institution 5 Trust 5 Business (Petrol Pump/CNG Station) 5 Software Business 5 Ship Breaking Business 5 Bank/Leasing/Finance Company 4 Business (Indenting) 4 Business (Outsourcing) 4 Farm/Engineering Firm/Consultancy Firm 4 Fuel and Electricity Generation Company 4 Print and Electronic Media 4 Travel Agent/Tourism Company 4 Merchant with Investment above 10 Million Taka 4 Chain Store/Shopping Mall 4 Freight/Shipping/Cargo Agent/C&F Agent 4 Motor Car Business (New/Reconditioned) 4 Leather/Leather Goods Business 4 Construction Materials Business 4 Business Agent 3 Yarn/Rag Trader 3 Transport Operator 3 Business (Pharmaceutical Production and Marketing) 3 Cold Storage Business 3 Customer's Occupation Score Pilot/Flight Attendant 5 Trustee 5 Professionals (Journalist, Lawyer, Doctor, Engineer, Chartered Accountant etc.) 4 Director (Private/Public Limited Company) 4 Senior Official of Multinational Corporation (MNC) 4 Housewife 4 Information Technology (IT) Sector Employee 4 Sports Person/Media Celebrity/Producer/Director 4 Freelance Software Developer 4 Government Employee 3 Landlord/House Owner 3 Private Sector Employee: Management Related 3 Teacher (Government/Private/Autonomous Educational Institution) 2 Private Sector Employee 2 Self-Employed Professional 2 Student 2 Retired 1 Agriculturist/Fisherman/Laborer 1 Others (Specifically) 1-5 List-1

32 Appendix-B Questionnaire for Self-Assessment of Branches on AML/CTF A. General Information

1. Name of the Bank: ................................................
2. Branch Name: ................................................
3. Branch Address: ................................................
4. Branch Manager's Name: ................................................
5. Branch Manager's Phone: ................................................
6. Date of Establishment of the Branch: A. When was the branch established? Year / Month B. AML/CTF
7. Is the branch's AML/CTF Compliance Officer senior and experienced? Yes, when was the AML/CTF Compliance Officer appointed? Year / Month
8. Does the branch's AML/CTF Compliance Officer regularly conduct monitoring and review of the branch's AML/CTF activities at specified and acceptable intervals and in the work process? Yes, when was the last review conducted? Year / Month C. AML/CTF Compliance Officer's Qualifications and Experience The branch's AML/CTF Compliance Officer should have sufficient knowledge, experience, and authority to perform AML/CTF duties. D. Customer Due Diligence, Record Keeping, and Reporting:
9. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No
10. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No
11. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No
12. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? (If not, what are the reasons? - Mention reasons if not performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy, and if not performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy, and if not performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy) Yes / No
13. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No
14. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No
15. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy?

Appendix-B 33 Customer Due Diligence (PEP), Family Members, and Close Associates: Yes / No 16. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes, when was the last review conducted? Yes / No E. Record Keeping 17. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 18. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No F. Customer Due Diligence, Record Keeping, and Reporting 19. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 20. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 21. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 22. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 23. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No G. Reporting Suspicious Transactions and Freezing Assets 24. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 25. Are the branch's AML/CTF Compliance Officer's duties regarding reporting suspicious transactions and freezing assets clearly defined and assigned to specific individuals? Yes / No 26. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 27. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No

Appendix-B 34 H. Training 28. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No I. Customer Due Diligence 29. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 30. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No 31. Does the branch's AML/CTF Compliance Officer regularly monitor and review the branch's AML/CTF activities to ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy? Yes / No J. Other AML/CTF Activities: (Customer's AML/CTF Activities) .......................................................................................................................................................................... .......................................................................................................................................................................... K. Conclusion 32. Based on the above answers, the branch's AML/CTF status is: ● Compliant with laws and rules ● Non-Compliant ● Partially Compliant ● Non-Compliant Yes / No If the answer is 'No', the branch must take necessary steps to become compliant with laws, rules, BFIU circulars, and the bank's own AML/CTF policy. If the answer is 'Yes', the branch must ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy. If the answer is 'Yes', the branch must ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy. If the answer is 'Yes', the branch must ensure that the branch's AML/CTF Compliance Officer is performing duties according to laws, rules, BFIU circulars, and the bank's own AML/CTF policy. Name: ................................................ Designation: ................................................ Branch Manager: ................................................ Date: ................................................ Seal of the Branch Manager: ................................................ Signature: ................................................

Appendix-B 35

----- Bank Ltd: ---- Branch. Self-Assessment of Branches through the AML/CTF System Every bank branch must determine its own status in the AML/CTF system by providing detailed answers to the following questionnaire based on existing laws, rules, BFIU circulars, and the bank's own AML/CTF policy:

Questionnaire Verification Criteria Branch's Current Status / Actions Taken / Recommendations

1. What is the total number of staff in the branch? (Designation-wise)? How many staff have received formal training on AML/CTF? (Percentage) Training records must be verified.

2. a) Is the branch's AML/CTF Compliance Officer (AMLCO) senior and experienced? Has the AMLCO received any AML/CTF training in the last two years? b) To ensure that the branch's AML/CTF program is being implemented regularly, does the AMLCO conduct monitoring and review at specified and acceptable intervals and in the work process? AMLCO must: ● Verify the accuracy of KYC activities? ● Verify if transactions are monitored and Suspicious Transaction Reports (including internal reports) are filed? ● Verify if records are preserved properly? ● Verify if EDD and CDD measures are taken? ● Verify if foreign currency inward and outward transactions are monitored?

3. Are the AMLCO and branch staff informed about existing laws, rules, BFIU circulars, and the bank's own AML/CTF policy? What is the method of verification? (Write in detail)

Appendix-G 36 Criteria for Questionnaire Verification | Current Status of Branch | Action Taken/Recommendation

4. Does the branch hold a quarterly meeting on the prevention of money laundering and terrorist financing? • Is the agenda of the meeting distributed for everyone's information? • What important decisions were taken in the meeting? • How are the decisions taken in the meeting implemented?

5. Is customer identification satisfactorily obtained in accordance with the Money Laundering Prevention Act, Anti-Terrorism Act, and instructions issued by BFIU from time to time, in all cases of account opening and transaction management? • How is the authenticity of customer identification verified? How is it being preserved at the branch? • Is the source of funds of the customer verified during the period of operation? • Is the beneficial owner (BO) of the account identified and is the verification process satisfactory? • Are additional due diligence measures (EDD) taken for high-risk customers?

6. a) Does the branch classify/categorize customers based on risk? b) Are transactions of high-risk accounts examined? • How many high-risk accounts have been opened at the branch so far? • What steps has the branch taken in opening and managing such accounts? • By what method are transactions of high-risk accounts examined?

7. Have appropriate measures been taken to prevent money laundering and terrorist financing in accordance with the instructions issued by BFIU and the bank's own policies? • Has a policy on this matter been formulated? • How is the aforementioned policy being implemented at the branch?

8. Does the branch periodically update the customer's KYC information based on the instructions issued by BFIU? By what method is such evaluation conducted?

Appendix-G 37 Criteria for Questionnaire Verification | Current Status of Branch | Action Taken/Recommendation

9. What process does the branch follow for Non-Resident Bangladeshi (NRB) accounts? How is the aforementioned process completed?

10. If any person other than the account holder deposits money in the case of Non-Resident Banking, what process is followed in that case? If followed, what process is being carried out?

11. By what method does the branch examine customer transactions? • Based on the threshold limit set by the bank branch or by any other method; • Is it verified whether the expected amount of transactions (EVT) is consistent with the customer's profession and income? • Is the actual transaction amount verified against the declared expected amount by the customer subsequently? • Does the branch examine daily transactions based on a defined threshold? • Does the branch periodically verify the consistency of transactions with the information provided by the customer in the KYC on a sample basis?

12. What steps has the branch taken to prevent terrorist financing under the Anti-Terrorism Act, 2009? • Does the branch preserve a list of persons or entities suspected of involvement in terrorism, terrorist acts, and proliferation of weapons of mass destruction under various resolutions of the UN Security Council, and any person or entity listed or declared prohibited by the Government of Bangladesh, and verify accounts and transactions accordingly?

Appendix-G 38 Criteria for Questionnaire Verification | Current Status of Branch | Action Taken/Recommendation

• Does the branch follow any specific procedure on this matter? • Does the branch maintain a Watch List? • Is BFIU informed about accounts (if any) operated in the name of such persons or entities?

13. How many Suspicious Transactions (STR) have been identified by the branch so far? • Does the branch follow any procedure for identifying suspicious transactions? • Is an internal reporting mechanism for Suspicious Transaction Reporting operational at the branch? • Are internal reports of suspicious transactions preserved by the branch? • How many STRs have been identified so far? How many CTR/STR reports have been sent to the Central Unit?

14. Has the branch developed any method to identify Structured Transactions (below reporting threshold) through repeated cash transactions by customers? Is any report being generated to identify Structured Transactions in daily transactions, or is there any method? (Write in detail)

15. Are CTRs being regularly and correctly sent to the Central Reporting Unit by the branch? • How is the accuracy of the sent information being verified? • Does the branch continue its own CTR verification program even when CTRs are reported centrally?

16. What separate records does the branch maintain regarding the Money Laundering Prevention Act, Anti-Terrorism Act, related rules, circulars, training records, descriptions, and other AML/CFT related matters? (Write in detail).

Appendix-G 39 Criteria for Questionnaire Verification | Current Status of Branch | Action Taken/Recommendation

Are they being preserved? Are copies of laws, circulars, etc., provided to all officers/employees of the branch?

17. Does the branch maintain any accounts of Politically Exposed Persons (PEPs), influential persons, or senior officials of international organizations in accordance with the BFIU Master Circular? If yes, what types of precautions are taken in opening and managing these accounts?

18. Are the instructions of BFIU regarding Offshore Banking transactions properly followed in the branch?

19. Have the deficiencies/non-compliances regarding AML and CFT compliance mentioned in the inspection reports of the Head Office, Bangladesh Bank, and the Bangladesh Financial Intelligence Unit (BFIU) been regularly rectified? If not, what are the obstacles?

20. Are inward and outward foreign currency transactions, including domestic remittances, examined by the branch? If so, how? In inward remittance transactions, is the list of terrorist organizations/persons provided by BFIU from time to time verified, where applicable?

21. Are transactions related to domestic trade (LC, Guarantee, etc.) properly examined at the branch?

22. Are loan accounts and other related transactions properly examined at the branch?

Signature and Date with Seal of the Branch AML Compliance Officer Signature and Date with Seal of the Branch Manager

Appendix-G 40 Name of the Bank: Base Date: Name of the Branch:

Sr. No. | Inspection Area | Subject of Verification | Method of Verification | Remarks | Total Marks | Obtained Marks 1 | 2 | 3 | 4 | 5 | 6 | 7 1 | Branch Compliance Officer Evaluation | 1) Is there a Compliance Officer (CO) in the branch? | See the General Office Order and check if the designation of CO is included in the office order. | 1 | | | | 2) Is the CO experienced and senior? | Verify in light of BFIU Circular instructions. | 2 | | | 2) Are the responsibilities delegated to the CO properly fulfilled? | Examine the CO's sub-program. | 3 | 2 | Customer Due Diligence (CDD) | 1) Has all necessary information been obtained for filling out the account opening form? | To ensure that all types of accounts have completed the necessary procedures for account opening properly, check at least 3 forms of each type of account. Examine how the collected information has been verified. | 2 | | | | 2) Has the customer's personal information been verified properly? | Examine the documents preserved in favor of verification, the method of verification, and the inspection trail. Check KYC forms and related documents of at least 10 accounts on a sample basis. | 2 | | | | b) Has the source of funds of the customer been verified? | Verify the accuracy of the source of funds of at least 10 accounts based on Source of Funds (SOF) documents. | 4 | | | | c) Is the beneficial owner (BO) of the account identified and what is the verification process? | Check attached documents/information of KYC forms of 10 accounts based on BFIU Circular and Guidelines. | 4 | | | 3) a) Are the instructions mentioned in the Risk Management Guidelines formulated by the Head Office for customer selection/account opening/service provision being complied with at the branch? | Examine what arrangements the branch has made according to the Risk Register. | 2 | | | | b) Is risk-based customer division/classification/categorization done at the branch and is it appropriate? | Examine if the risk-based customer division/classification/categorization method at the branch is consistent with the instructions mentioned in the Risk Grading section of the account opening form. | 1 | | | | c) Is additional information and related documents preserved and verified (EDD) for high-risk customers? | Collect the list of high-risk customers preserved at the branch and examine what type of information is collected and if it is sufficient while inspecting the related accounts. | 1 | | | 4) a) Is KYC updated periodically/as needed? | Check documents/information according to BFIU Circular instructions. | 1 | | | | b) Is any process followed for dormant/inactive (Dormant/Inactive) customers (DD, TT, Pay Order, Online Deposit, Online Withdrawal, etc.) by the branch? | Check if it is implemented according to BFIU Circular instructions by checking related documents/information. | 2 | | | | c) Is any process followed for Offshore Banking by the branch? | Check if it is implemented according to BFIU Circular instructions by checking related documents/information. | 1 | | | 5) Are any accounts of Politically Exposed Persons (PEPs), influential persons, or senior officials of international organizations preserved at the branch? | Verify on a sample basis according to BFIU Circular instructions. | 3 | | | 6) a) Are BFIU instructions followed in providing Inward Remittance services? | Check if customer identification is correctly obtained and verified in the issuance of Inward Remittance. Check if the credit limit of Inward Remittance is consistent with the customer's income. Check if the branch updates KYC. | 1 | | | | b) Are BFIU instructions followed in providing Outward Remittance services? | Check what precautionary measures the branch has taken in providing Outward Remittance services and if any additional information has been taken considering the customer's risk. | 1 | | | 7) Are BFIU instructions followed regarding Trade Finance services? | Check if customer identification is correctly obtained in account opening and what/what type of additional information has been taken considering the customer's risk. | 1 | 3 | Transaction Monitoring | 1) Is any operational procedure for transaction monitoring operational at the branch? | Mention the monitoring procedure (collect evidence if applicable). If manual transaction monitoring is done, verify in detail how it is done. | 4 | | | | | If automated, collect and inspect system-generated reports. Collect and verify documents of past transaction monitoring. | | | | 2) a) Is the expected amount of transactions (EVT) obtained consistently with the customer's profession and income? | Examine at least 10 sample cases if applicable. | 2 | | | | b) Is all necessary information included in the expected amount of transactions (EVT)? | Verify Circular instructions. | 1 | | | | c) Is the actual transaction verified against the expected amount? | Examine the transaction monitoring procedure of at least 10 accounts and check if there is a match between the transactions and the EVT mentioned in the bank's automated system if necessary. | 2 | | | | d) Is the EVT determined before examining the customer's transactions within 6 months of account opening? | Verify EVT of at least 10 accounts according to BFIU Circular. | 1 | | | | e) Is EVT updated from time to time if any specific need is felt or under the regular examination program of the branch? | Verify EVT of at least 10 accounts. | 1 | | | 3) Is a list of high-risk accounts operated at the branch preserved and are the transactions of the said accounts examined properly? | Collect the list of high-risk accounts and verify if the transactions of the said accounts are examined properly by collecting related documents according to BFIU Circular instructions. | 3 | | | 4) a) Is the local terrorist list mentioned in the Annexure of the Anti-Terrorism Act 2013 under the Anti-Terrorism Act preserved at the branch to prevent terrorist financing, and are account opening and transaction activities verified accordingly? | Verify if both lists are verified in account opening, transaction monitoring, and domestic/international trade. Check if the branch follows any independent (automated) procedure on this matter. Examine at least 10 sample cases. | 2 | | | | b) Is the Watch List preserved at the branch? | Examine if any Watch List has been made by the branch for verifying the Anti-Terrorism Act and local terrorist list. | 1 | | | 5) What arrangements has the branch made to prevent money laundering and terrorist financing in the financing of foreign and domestic trade?** | Collect documents of LC and other related accounts of 4/5 customers on a sample basis and verify the following matters: • Check if the value of goods mentioned in the Bill of Lading is verified against international standards. • Check if the Branch has inspected the Inward Remittance of Beneficiary/Consignee. • Check if EDD is done if the Beneficiary/Consignee is identified as a high-risk person by the Financial Action Task Force (FATF) or other international organizations. • Check if the Branch preserves the documents of the Inward Remittance of the Exporter. • Check if the value of goods/shipment is consistent with the Commercial Invoice/Shipping Bill. | 5 | | | 12 Note: Subsection 3(5) is applicable only to AD branches. For non-AD branches, convert the obtained number out of 95 into a percentage to determine the sub-rating. | | 6) Does the branch examine inward and outward remittances including domestic remittances? | Verify customer KYC information related to inward and outward remittance transactions on a sample basis. | 1 | 4 | Cash Transaction Reporting (CTR) and Suspicious Transaction Reporting (STR) | 1) a) Is CTR done monthly and reliably? | Check records/documents/registers. In cases where the Head Office centrally makes CITR, check if CITR is preserved at the branch on a monthly basis. | 3 | | | | b) Is a copy of the CITR sent every month preserved at the branch and regularly inspected? | Examine the reporting list/file. Verify if it is inspected according to BFIU Circular by checking related documents. Even if CITR is done centrally, check if CITR is inspected by the branch. | 4 | | | | c) Has any method been developed at the branch to identify Structured Transactions by customers making repeated transactions below the reporting threshold? | Identify possible accounts by inspecting the branch's cash register and inspect them. Check if any report is generated by the branch on this matter. | 5 | | | 2) a) Is any procedure operational at the branch for identifying Suspicious Transactions (STR)/SAR? | Verify if any procedure is operational for identifying Suspicious Transactions (STR) based on various indicators of Suspicious Transactions (STR). | 5 | | | | b) Are all concerned officers informed about STR/SAR? | Examine if branch officers have a proper understanding of identifying and reporting suspicious transactions. | 3 | 5 | Submission of Reports to AML Division | 1) Are the required number of reports submitted to the Money Laundering Prevention Division by the branch? Does the branch submit reports on time? | Examine if CITR (and STR reports if applicable) are sent monthly and Self-Assessment reports are sent semi-annually to the Money Laundering Prevention Division. Delayed submission or non-submission of reports will be considered unsatisfactory. | 2 | | | 2) Is the information provided in the report accurate and complete? | Examine related documents. If information is not accurate and complete, it will be considered unsatisfactory. | 1 | 6 | Self-Assessment Method | 1) Is the branch evaluation system operational using the self-assessment method? | Check if an evaluation report has been prepared using the checklist attached with BFIU Circular. | 1 | | | 2) Has a meeting been held at the branch under the chairmanship of the Branch Manager with concerned officers before finalizing the aforementioned evaluation report? | Check documents. | 1 | | | 3) a) Have deficiencies been identified in the evaluation report? | | b) What steps has the branch taken to implement the decisions taken, and have the progress of the previous meeting's related matters been discussed in subsequent quarterly meetings? | Check documents. | 2 | | | 4) Is the branch's own assessment appropriate? | Check documents and evaluate each point of the checklist after inspection. | 1 | 7 | Officer Knowledge and Awareness on CTR/STR | 1) How many officers at the branch have undergone formal training on money laundering? | See related records at the branch. Formal training on money laundering lasting at least 1 day covering international standards, national policies, laws, BFIU guidance notes and circulars, risk management, and reporting methods will be considered. | 1 | | | 2) Has a copy of the annual declaration of commitment on AML/CFT matters by the Principal Executive been notified to all officers and preserved in the records, and have branch officers complied with it properly? | Check documents. | 1 | | | 3) Are branch officers aware of AML/CFT policies, procedures, programs, national policies, and BFIU guidelines? | Evaluate based on interviews with branch officers. | 1 | | | 4) Is information and documents related to training preserved properly? | Check documents. | 1 | 8 | Record Preservation/Delivery | 1) Are records related to customer transactions properly preserved according to the Money Laundering Prevention Act-2012 and the bank's own policies? | Examine account transaction information (e.g., account opening forms, transaction details, checks/vouchers, etc.) according to the Money Laundering Prevention Act-2012 and BFIU Circular. | 2 | | | 2) Is information and documents collected during the CDD process and transaction-related information and documents provided on time as per BFIU's demand? | Examine related documents. Failure to provide information on time and correctly will be considered unsatisfactory. | 3 | 9 | Audit, Inspection and Others | 1) Does the Branch Manager play an appropriate role in implementing the CTR/STR program if not the CO? | Evaluate based on the agenda of meetings held at the branch and interviews with the Branch Manager. | 1 | | | 2) Have the irregularities/recommendations mentioned in previous audit/inspection reports conducted at the branch been properly complied with? | Examine the latest audit report and verify what arrangements the branch has made to correct the irregularities mentioned in the report. • Check the latest audit report prepared by the Bank's Internal Audit Department and verify the status of compliance. • If Bangladesh Bank's Bank Inspection Department conducts an inspection program, inspect its report (especially the AML part) and verify the status of compliance. • If Bangladesh Bank's Foreign Currency Inspection Department conducts an inspection (if any), inspect its report and verify the status of compliance. • If BFIU conducts an inspection (if any), inspect its report and verify the status of compliance. | 4 | | | 3) What arrangements have been made to increase customer awareness? | Verify what programs the branch has taken to increase customer awareness. Check if leaflets are distributed to customers and if posters on this matter are present in visible places at the branch. | 3 |

Total: 100 100

Appendix-G 44 Sr. No. | Inspection Area | Allotted Total Marks | Obtained Marks 1 | Branch Compliance Officer Evaluation | 6 | 2 | Customer Due Diligence (CDD) | 26 | 3 | Transaction Monitoring | 23 | 4 | Suspicious Transactions and Cash Transaction Reporting | 20 | 5 | Submission of Reports to AML Division | 3 | 6 | Self-Assessment Method | 5 | 7 | Officer Knowledge and Awareness on AML/CFT | 4 | 8 | Record Preservation | 5 | 9 | Audit, Inspection and Others | 8 | Total: 100

Score Rating 90+ - 100: Strong 70+ - 90: Satisfactory 55+ - 70: Fairly Good 40+ - 55: Marginal 40 and below: Unsatisfactory