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I am just one among hundred other employees.

What role do I play in


preventing money laundering?
Firstly, by being sensitive to the seriousness and pervasiveness of money
laundering.
Secondly, Understand and adhere to the companys policy for AML.

What is AML? How is it different from KYC?


AML- Anti Money laundering, is a term generally used to imply
everything that is done to prevent money laundering. Hence, the due
diligence measures of KYC are in essence, measures adopted by a
company for AML.
Similarly, an AML measure that RBI has adopted for combating money
laundering in the country, is requiring every financial institution
to follow a well defined KYC policy.
RBI also requires every such institution to:
Obtain the PAN no. of any customer who makes a cash payment of
Rs.50000/-.
Report to them in case of any deposits of over Rs.10 lacs in cash by a
customer in a month. (The principal officer for HFFC is Kiran Agarwal Todi. If you come across
such deposits from one of your customers, you will report the same to her. She shall in turn, report to
RBI)

What are the KYC due diligence procedures our company follows ?
At the time of loan booking - CIP Customer Identification process is the
primary and the most important process where each employee who interacts with
the customer plays an important role .The process involves verifying the
customers documents for confirming his identity and permanent residence.
Whenever you follow a CIP, do it in the spirit of KYC.
By affixing an OSV (originals seen and verified) seal on the customer documents,
you are undertaking the responsibility of having complied with KYC.
During the loan tenure, if you find a customer making a lump sum payment- for eg.
margin money payment or payment for full repayment of loan, satisfy yourself as
to the source of that money and capture it in your records.
Is CIP is a standard process applicable for all customers?
CIP is applicable for ALL customers. However it is not necessarily standard for
all customers.
Customers are basically classified on the basis of risk as: Low Medium- High.
Low risk customers are individuals and entities whose identity and source of
wealth can be easily verified. They have structured incomes and their
transactions largely conform to their profile.
When this is not the case, they move into medium or high risk.
CIP should be more stringent for a customer who falls in the medium
risk category and even more for a customer who falls in the high
risk.

Should the customer be informed about KYC?


KYC is not only a responsibility, but also a regulatory requirement of RBI for
banks and financial institutions. Customers can be made aware so that they are
comfortable sharing information and documentary evidences required of them.
A write up on KYC should be displayed in your branch in local language for the
purpose.
So just by following the above due diligence processes, will I be complying
with KYC?
Criminal forces do not follow a fixed and predictable pattern. They are
constantly working every minute on finding new ways of exploiting the internal
controls of a financial institution to their advantage. Hence, it would be
sensible to not restrict oneself to the defined processes alone and always be
alert to the possibility of being targeted for money laundering.
As an employee, we play an extremely important role in breeding the
right culture in our organization.
Diligently following KYC is our individual responsibility. By ensuring a proper
KYC in each case, we play significant role in guarding our company against
money laundering.

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