Politicaly exposed persons Slides show.pptx

invaluable information about PEPs catagories

1. PEPs Compliance Department Training for Compliance officers

2. Contents PEPs introduction PEPs types How we should know a PEPs PEPs importance PEPs guidelines regarding the policy PEPs Checklist PEPs Approval PEPs EDD Measures

3. PEPs Political Exposed Persons اشخاص متبارز سیاسی

4. Introduction: Politically exposed persons are individuals who are or have been entrusted with famous public functions like : Head of State or of Government Ministers Deputy Minster or equivalent rank senior politicians senior government / judicial / military officers, Presidents / Heads of important political parties Parliament / Provincial Assembly members Ambassadors Governors/sub Governors Close Family members & business partner of above persons

5. POLITICALLY EXPOSED PERSONS According to FATF’s International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation , there are two types of Politically Exposed Persons (PEPs ): • Foreign PEPs: Individuals who are or have been entrusted with prominent public functions by a foreign country, for example heads of state or of government, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, important political party officials . • Domestic PEPs: Individuals who are or have been entrusted domestically with prominent public functions , for example heads of state or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials .

6. How we should know a PEPs While a famous person comes to your branches. During Account Opening Interview Asking about positions in government Services. Asking about their ID cards & checking their ID cards. From their family members name, like father, Mother Brothers, sisters etc. Getting some extra information's.

7. Responsibilities of Compliance Officers Collecting Complete KYC documents, from CSRs, CSOs Preparing Approval letter Filling EDD forms Reporting to Compliance Department Recordkeeping

8. PEPs Importance PEPs is having an essential consideration due to its risk is high, and the persons who are involved are those who are having a key position in government sector so the possibility of conducting any type of fraud is there, by misusing the position and the authority that they have, so for avoiding this kind of issues we give more consideration on our PEPs customers, hence Branches gather sufficient information on any person / customer of this category intending to establish a relationship and check all the information available on the person in the public domain.

9. Bank also verify the identity of the person and seek information about the sources of funds before accepting the PEP as a customer by sending confirmation letter to their employer address for confirming their position and monthly income. The decision to open an account for PEP is taken after getting approval from senior management. Bank also subject such accounts to enhanced monitoring on an ongoing process .

10. About Policy As per policy and procedure of Azizi Bank under inspection of Central Bank, we should undertake enhanced due diligence when dealing with this category of customers and legal persons, family member of those persons, persons dealing on their behalf and their close associates, hence we are monitoring all PEPs accounts on quarterly basis to ensure all policy and procedure are complied, To comply with the proceeds of crime (Money Laundering), Terrorist Financing. Hence on article 13 of the DAB Law it said that: Article 13 − Due diligence measures for politically exposed persons . Reporting entities should, in relation to politically exposed persons , in addition to performing normal due diligence measures :

11. a. have appropriate risk management systems to determine whether the customer is a politically exposed person; b. obtain senior management approval for establishing business relationships with such customers; c. take reasonable measures to establish the source of wealth and source of funds; and d. Conduct enhanced ongoing monitoring of the business relationship. For this purpose we have a responsible person who monitor the accounts quarterly basis, investigate about the documents and make them complete, beside this sent thanks letter for address verification and income letter for clarification of exact income . File STR if any suspect is found, also make sure that for each of them there is approval letter available

12. For the purpose of conducting an effective and efficient process enhanced due diligence , we use to follow the following steps:    1- Account monitoring and having comment on each account after monitoring is done/completed. 2- Filling STR if any suspect found while monitoring. 3- Updating the PEPs database and sending it to FINTRACA. 4- Making sure that there is availability of documents of each. 5- Having the printed documents as hard copy for future needs. 6- Sending mails to the related branch if any incomplete document is found. 7- Sending thanks letters on the address related, for the confirmation of correct address. 8- Sending confirmation letters for the purpose of income information and its source. 9- Having approval for each PEPs customer from the senior authority.  

13. Which points should be observed in KYC forms of PEPs Customer Full Name Complete address Monthly income and currency PEPs category Risk category Stamp in photo of customers Customers signature CSR,CSO,AML\Officer, branch manager (these signatures are compulsory) ID cards For salary accounts letter of introducer Approval letter Joint holders CIF Tazkira / passport with full details PEPs site information (Afghan Bios ……..) Income letter Thanks letter Etc….

14. PEPs Approval letter   To: Respected CEO From: Compliance Department Branch Code: Subject: PEPs Approval Letter Date: / / Dear Sir,   As per policy and procedure of our bank under inspection of Central Bank, we should undertake enhanced due diligence when dealing with this category of customers and legal persons, family member of those persons, persons dealing on their behalf and their close associates, hence we should obtain senior management approval while establishing business relationship with politically Exposed Persons (PEPs). To comply with the proceeds of crime (Money Laundering), Terrorist Financing Act and risk management purposes the identity of client must be verified. As a result this form must be completed. PEPs Information: Name: ------------------------------------------------------------------------ Position: ---------------------------------------------------------------------- Organization: --------------------------------------------------------------- ID Number: ------------------------------------------------------------------ Telephone Number: ----------------------------------------------------------------     Interviewed By CSO/Branch Compliance Officer Reviewed by Branch Manager Name/AZB No: Name/AZB No: Signature: ------------------------------ Signature: --------------------------------- Account Opening for political exposed person must be approved by the Chief Executive Officer CEO. Approved By: Mohammad Salem “ Omaid ” CEO & President Azizi Bank Signature: ----------------------------------------

15. PEPs Information: Name: ------------------------------------------------------------------------ Position: ---------------------------------------------------------------------- Organization: --------------------------------------------------------------- ID Number: ------------------------------------------------------------------ Telephone Number: ----------------------------------------------------------------     Interviewed By CSO/Branch Compliance Officer Reviewed by Branch Manager Name/AZB No: Name/AZB No: Signature: ------------------------------ Signature: --------------------------------- Account Opening for political exposed person must be approved by the Chief Executive Officer CEO. Approved By: Mohammad Salem “Omid” CEO & President Azizi Bank Signature: ----------------------------------------

16. EDD Form For PEPs Account No: Branch Name: Title of Account: Account Open Date:

17. No   Yes No/NA 1-   Account holder himself/herself is PEP ? Please Specify -director of external relations of independent election commission       If No in the above, what is the relationship of customer with the PEP? Family member Close Associate Other Relationship Please Specify______________________________________         2- Category of PEP: Politician Civil Bureaucrat Military Official Judiciary Personnel Others Please Specify:________________________________________      

18. 3- In case of politician, what is the current official position of the PEP /or ever held in the past? Senior Executive of State-Owned Entities Federal/ Provincial Minister Senior Government Judicial or Military Officials. Member National/ Provincial Assembly Senior Politicians Senator All family members of such persons above Close Associate who have business or financial relationship with PEP Others --------------------------------------       4- Mention the name of the political party customer is associated with:_______________________     5- Beneficial Owner of the account is other than the customer himself/herself ?     6- If Yes in the above, provide the below mentioned information regarding beneficial owner of account and please obtain his/her identification documents. Name :__________________________ Tazkira / PassportNumber :_______________ Relationship with the Customer: _________________________________________________  

19. 7- Account is operated by other than the customer.     8- If Yes in the above, provide the below mentioned information regarding third party authorized person / operator / authorized signatory of the account: Name: _____________________________ Tazkira/Passport:______________________________ Relationship with the Customer: ____________________________________________________   9- What is the source of income of the customer? Salary ________________________________ Business_______________________________ Others_________________________________     10- Business details: In case, if PEP other business, please obtain information below. Name of the Business -------------------------------- Nature of the business ------------------------------- Address of the business -----------------------------------------------------------    

20. 11- Is the customer referred by Azizi Bank Staff, If yes, mention the name of the bank staff? Name:__________________________ Designation: ___________________________       12- Has the name of customer/ Third party authorized person been filtered out through UNSC lists and OFAC lists please affix OFAC/UNSC Stamp or acknowledgement     13- Prior Approval for opening of account is obtained from the Senior Management     14- Mention the details of other accounts /financing facilities availed by the customer from Azizi Bank: a)____ ______________________________b)__________________________________ c)___________________________________d)__________________________________   16- Estimated Monthly Account Turnover______________________________ Estimated Annual Account Turnover _______________________________    

21. 17 Document Obtain: S/N Document Name Document Obtain YES or NO Remark 1 Tazkira / Passport of the Customer Tazkira / Passport of the Beneficial Owner (if any)     2 Source of fund proof     3 Proof of PEP     4 Source of Wealth proof in case of corporate accounts (If Any)     6     18 Branch Comments: ____________________________________________________________________________ ___________________________________________________________________________________________________________________________________________________  

22. Prepared by branch Officer Recommended by BM Name   Name   Date:   Date     Signature   Signature       Approved By Chief Compliance Officer Name Date     Signature     Note : Hard copy of this EDD Form (duly filled & signed) should invariably be retained at the Branch along with Account Opening Form for Audit Trail purpose. Additional information (If Any) can be provided on a separate paper which should be attached with this EDD form for future reference.

23. T hanking Y ou  Any Question!