By FAISAL KAMRAN
KNOW YOUR CUSTOMER (CUSTOMER OR ENHANCED DUE DILIGENCE)
KYC REQUIREMENTS • Account Holder ID • NTN • Funds Transfers • Investment / Security Purchase • Compliance Program
KYC OBJECTIVES • • • • • •
Facilitate Compliance Facilitate Safe & Sound Practices Decrease the Likelihood of Abuse Protect the Reputation of the Bank Timely Detection of Suspicious Activity Reduce Risk of Seizure or Forfeiture
CONTENTS OF KYC PROGRAM • Vary Based on Institution's Size and Complexity • Nature and Extent of Activities • Levels of Risk • Delineate Appropriate Documentation Requirements
CONTENTS OF KYC PROGRAM [continued]
• Understand Intended Relationship • True Identity of Customers • • •
Source of Funds Monitoring Activity Suspicious Activity Reporting
CUSTOMER IDENTIFICATION PROCESS • Satisfactorily Establish Identity • Extent of Identification Process • Best Documents for Verifying Identity • Introductions or Referrals • Necessary Information – Minimum Threshold
NATURAL PERSON Examine and Record Primary Identification • • • • •
CNIC Drivers License Passport Any other ID Registration Card
NATURAL PERSON
[continued]
Record Primary Information • • • • • •
Name and Address National Tax Number Foreign ID Number Date of Birth Phone Numbers Bank References
NATURAL PERSON
[continued]
Examine and Record Secondary Identification • • • • •
Credit Card Employer Card Union Card Voter Registration School ID
NATURAL PERSON
[continued]
Verifying Information • • • •
Physical Observation • Telephone Book • Contacts Call Backs Third Party Checks • Credit Reports Verification Services
BUSINESS ENTITY Establish True Identity • Verify and Record Evidence of Legal Status • Verify Information About Business • Verify and Record ID of Principals • Verify Information on Principals
REVIEW-EXAMINATION CONSIDERATIONS • Internal Controls • Account Opening Procedures • Management Information and Monitoring Systems • Compliance With Laws and Regulations.
INTERNAL AUDIT CATEGORIES OF CUSTOMER RISK • Type of Customer • Products and Services • Geographical Locations
TYPE OF CUSTOMER • Cash Intensive • NBFC Activities • Financial Services – Money Transmitters – Currency Exchangers – Cash Cheques
• Non-Resident Accounts • Professional Service Providers
PRODUCTS & SERVICES • • • •
Private Banking Offshore Activity Money Transfers Monetary Instrument Sales
KYC FACILITATES SUSPICIOUS ACTIVITY REPORTING • • •
Detection Timely Reporting Controlling Risk – – – –
Reputation Compliance Civil & Criminal Liability Penalties
Thanks