Use Case
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Key Challenges
▪ Transaction related risk rating to be submitted but Banks were submitting Customer risk rating
▪ Complete information from Swift was not being captured in the report
▪ Ultimate Beneficiary details Not captured
▪ Related authorised signatories, Multiple Joint holders were not captured by many institutions
▪ Treasury Transactions not captured
▪ Transactions which are supposed to be reported were not reported and Transactions which are
not supposed to be reported were reported.
▪ Indian State Codes captured against Foreign country Code.
▪ Majority of data massaging activity in capturing data of Telephone/Mobile/Fax etc.
▪ No validation from BIC Code master for BIC Codes or institution Ref No. used leading to no data
uniformity or inconsistent data
▪ Incorrect PAN No, Aadhar No reported as FIU utility is not highlighting any error for PAN No.or
Aadhar No less than 10 or 12 characters respectively.
▪ No audit system available for verifying the data changes from multiple source system and
massaged data.
▪ Multiple applications being used for data collection. Bank was spending 80% of time in data
preparation.
▪ Maintaining & managing the desired granularity of data to the level of transaction, customer,
product, transaction related processes, etc. was highly cumbersome & was hampering the banks’
attempt to consolidate, report timely and accurately.
▪ Lack of Audit & System trail of past submissions resulting in failure and notices.
▪ Manual functioning hindered the Audit of resubmission of corrected reports. Slippages on
automated internal controls & compliances.
▪ Manual case updates and missing customer data.
▪ Bank’s compliance team faced multiple challenges in handling customer transaction and
accounting data and providing complete information to FIU on their reportings.
▪ High penalties imposed by FIU in case of non-reporting or incorrect reporting.