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No Title Page No
1 Introductioon 3
2 History 5
3 RBI follow-up 6
4 Guidelines 12
5 kyc policy 13
6 Monitoring of transaction 19
7 Global effect 22
8 Wire tranfer 23
9 Principle officer 25
11 Research methodogy 41
12 Case study 50
13 Limitation 54
14 Conclusion 53
15 Questionnaire 55
INTRODUCTION
Know your customer (KYC) is the due diligence and bank regulation that
financial institutions and other regulateds companies must perform to
identify their clients and ascertain relavant information pertinent to doing
financial business with them. Know your customer policies have becoming
increasingly important globally to prevent identity theft fraud, money
laundering and terrorist financing. In a simple form these ruyles may equate
to answering twelve questions,but this is the tip of the iceberg and regulators
now expect much more.KYC should noot be thought of as a form to be
filled- it is a process to be undergone froom the start of a customer
relationship to the end.
One aspect of KYC checking is to verify that the customer is not on any list
of known fraudsters, terrorists or money launderers,such as the Office of
ForeignAssets Control'sSpecially Designated Nationals list.Beyond name
matching, a key aspect of KYC controls is tooo monitor transactions oof a
customer against their recorded profile, history on the customer's account(s)
and with peers.
With effect from 1st feb 2008, KYC is mandatory. till the time, one gets the
KYC refrence number; one cannot invest 50k or more in the Indian mutual
funds.
Meaning of Customer
For the purpose of Policy , a Customer' is defied as:
0 A person or enttity that maintains an account and/or has a business
relationship with the Bank;
HISTORY
2 Worldwide Impact:
3 Thw main purpose of KYC norms was to restricing the
United money laundering torrorist financing when it was
introced in late the 1990s States. The US govt. turned very
strict after 9/11 and all regulations were finalized before
2002 for KYC.
9 The Auditors were advised to select all types of accounts over a period
and submit their findings.
10 It means that the Branches are not complying with the KYC
guidelines extremely careful and the requirement of KYC compliance
is not being taken seriously by some branches.
Following are measure for achieving full KYC compliance in all the
existing accounts as per the RBI directives:
15 In order to ensure that all the territoties are covered , RBI also
arranged to publish the notice in local news papers of different States.
Branches should display this Notice prominently in the Branch premises and
confirm to their respectives Zonal Offices of having done so .
Identification of KYC Non- compliant Accounts:
16 The task of identifying accounts requiring KYC compliance at each
-branch shall be carried out by the zones oon priority. In order to
ensure that the exercise is done diligently, the scrutiny of accounts to
identify the KYC non-compliant accounts at a branch shall be done by
officer/deputed from a diffrent Branch.
20 Once the accounts are identified for KYC non-compliance and the
nature of the deficiency is established,Branch shall address a suitable
communication to each such identified account holder requesting for
submission of the neccesary documents for compliance of the KYC
requirements. The branch should ensure that any change of address
communited by the customer is properly recorded and the notice is
sent to the correct address. The customers may be given SEVEN
DAYS time for complying with the Bank's required. In caes the KYC
norms are not complied within the period stipulated therein the
accounts shall be frozen.
After the expiry of the notice period, the Branches shall submit thier reports
to the Zonal Offices within seven days. The zonal Offoices will consolidate
the reports of all the Branches in their zones and submit their report to RBI
within SEVEN Days in the same format.
24 Second and Final Notice in the news papers, Drawing the customers'
attention to the earlier newspapersnotice as well as the individual
noticesent by the Branches and their failure to comply with the KYC
guidelines spite the said notices. The Notices. shall give a deadline of
seven days to the customers for fulfilling the KYC documentation and
notify to them the transacations in their accounts shall be ceased and
accounts frozen after expiry of the deadline, if KYC compliance is not
fulfilled by that date.
29 The RBI had also directed all banks to make a policy for
implementing 'Know Your Customer' and anti-money laundering
measures and remain fully compliant with given guidelines before
December31,2005. But there have been instances of lapses in the
implementation of KYC guidelines by several banks.That resulted
into the infamous IPO scam. since January 2006, the RBI has slapped
penalties on several leading banks. Till date we have not come across
any case of money laundering, terrorist financing or transfer of funds
for anti-national activities, but in case of any more lapses in the 'Know
Your Customer' guidelines, the threat of the misuse of the banking
channels for anti-natinal activities always lurks around the corner.
GUIDELINE
General:
1) Banks should keep in mind that the information collected from the
customer for the purpose of opening of account is to be treated as
confidential and details thereof are not to make known for cross selling or
any other like purpose. Banks should, therefore, ensure that information
sought from the customer is relevant to the perceived risk,is not intrusive,
and is in conformity with the guidelines issued in this regard. Any other
information from the customer should be sought separately with his /her
consent and after the opening the account .
KYC Policy:
Banks should frame their KYC policies incorporating the following four key
elements:
Monitoring of Transaction:and
Risk management
B) Banks should prepare a profile for each new customer based on risk
categorization. The customer profile may contain information relating to
Customer"identity, social/financial status, nature of business activity,
information about his client" business and their location etc.
5. Verify the legal status of the legal person/entity through proper and
relevant document.
Indicative Guidelines
When the bank has knowledge or reason to believe that the clent
account opened by a professional intermediary is on behalf of a single
client,that client must be identified. Banks may hold'pooled' accounts
managed by professional intermediaries on behalf of entities like mutual
funds, pension funds or oother types of funds.where funds held by the
inteermediaries ther are 'sub-accounts',each of them attributable to a
beneficial owner, all the beneficial owners must be identified. Where such
funds are co-mingled at the bank, the bank should still look through to b the
beneficial owners. Where the banks rely on the 'customer due
diligence'(CDD) done by an intermediary, they should satify themselves
that the intermediary is regulated and superised and has adequate systems in
place to comply with the KYC requirements It should be understood that
the ultimate responsibility for knowing the customer lies with the bank.
Monitorning of transactions
30 on going monitoring is am essential element of effective KYC
procedures. Banks can effectively control and reduce their risk only if
they have an understanding of the normal and reasonable activity of
the customers so that they have the means of identifying transactions
that fall outside the regular pattern of the activity. However, the extent
of monitorning will depend on the risk sensitivity of the accounts.
Banks should pay special attention to all complex, unusually large
transacvtions and all unusual patterns which have no apparant
econmic or visible lawful purpose. Banks may prescribe threshold
limits for a particular category of accounts and pay particular attention
to the transactions which exceeds these limits. Every bank should set
key indicators for such as the country of origin, sources of funds, the
type of transactions involved and other risk factors. Banks should put
in place a system of periodical review of risk categorization of
accounts and the need for applying enhanced due diligence measures.
There are five types of risks that an effective KYC policy can help to
mitigate:
31 Reputational
32 Operational
33 Legal
34 Financial
35 Concerntration
Reputational risk:
Operational risk:
THis is the risk of direct or indirect loss from, faaulty or faiuled internal
processes, management and systems. It ,today's competitive
environment,Operational excellence is critical for competitive advantage. If
a KYC policy is faulty or poorly implemented, then operational resources
are wasted, there is an increased chance of being used by criminals for
illegal purposes, time and money is then spent on legal and investigative
actions and the businbess will be viewed as operationally unsound.
Legal risk:
if a busiess is used as a vehicle for illegal activity by customers, it faces the
risk of fines, penalties, aninjunction an even forced discontinuance of
operations. Apart from regulatory risk, involvement in illegal activities cuold
lead to third party judgement and enforceable contracts. Due to the nature of
business, these risks can never entirely be eliminated. However, if a business
does nott have an effective KYC policy, it will be inviting legal risk. By
stirictly implementing and following a kYC policy, a business can mitigate
legal risk to itself and its staff.
Financial risk :
If a business does not adequately identify and verify customers,it may run
the risk off unwittingly allowing a customer to pose as someone they are
not. THe consequences of this may be far reaching . IF a business does not
know the true identity of its customers, it will also be difficult retrieve any
money that the customer owes.
Concertration risk:
This types of risk occurs on the assets side of a business if there is too much
exposure to one customer or a group of related customers. it also occurs on
the liabilities side if the business holda large concentrations of funds from
one customer or group (in which case it faces liquidity risk if these funds are
suddenly withdrawn)
GLOBAL EFFECT
WIRE TRANFER
Domestic wire transfer means any wire transfer where the originator and
beneficiary are located within the same country. A transaction
involving a chain of wire transfers that take place within the borders of a
single country is domestic wire transfer even though the system used for
effectin the transaction is located outside the country.
Cross-border transfer means any wire transfer where the originator and
the beneficiary bank or financial institution are located in different
countries. It may include any chain of wire transfers that has at least one
cross-border element.
(c) Where several individual transfers from a single originator are bundled in
a batch file for transmission to beneficiaries in another country, they may be
exempted from including full originator information, provided they include
the originator's account number or unique reference number as at (b) above.
An ordering bank is the one that originates a wire transfer as per the
order placed by its customer. The ordering bank must ensure that
qualifying wire transfers contain complete originator information. The
bank must also verify and preserve the information at least for a
period of ten years.
While the information as required above will enable banks to furnish the
details to authorities in an expeditious manner for investigation or
prosecution of money laundering or terrorist financing cases, the beneficiary
banks also should analyse the data to find out any unusual/ suspicious
activities which they may consider reporting to the FIU-IND India.
PRINCIPAL OFFICER
No, KYC requirements have always been in place and Banks have been
taking KYC documents in accordance with the guidelines issued by RBI
from time to time.RBI has revisited the KYC guidelines in the context of
recommentatins made by the Financial Action Task Force (FATF) on Anti
Money Laundering Standards and on Combating Financing of Terrorism and
enhanced the KYC standards in line with internatiuonal benhmarks.
Legal:
The Prevention of Money LaunderingAct,2002(PMLA) which came
into force from July 1, 2005 (after "rules" under the Act were formulated and
published in the OfficalGaztte) also requires Banks,Financial Institutions
and Intermediarries to ensure that they follow certain minimum standards of
KYC and AML as laid down in the Act and the "Rules" framed there under.
APPLICATION OF KYC
The first step in the laundering process for criminals is to get their money
into an account with a Bank, often using a false identity and address. The
funds so deposited will be transferred to other accounts locally or abroad
or used for buying goods or services.
These trasactions would appear to be like any legally earned money and
beecomes difficult to trace it back to its criminal past. Banks under law
should not only prevent this, but should stop criminals who wish to use
the banking channel to launder the ill-gotten money from illegal/ criminal
activities.
The best identification documents are those which are issued by a Govt.
authority, which should have a photograph, address and signature. You
may provide one single document which can establish your identify and
address or two or more documents. For individual documents like copy
of the passport,Election Identity Card,Driving License, Permanent
Account Number(PAN) card, etc. would be sufficient for the purpose of
establishing the identity, addess and signature.Similarly, for other entities
like firms, companies,trusts,etc. documents like Partnership Deed,Trust
Deed,Memorandum &Articles of Association,Certificate of
Incorporation, Registration and Service Tax,License under Shops and
Establishment Act, etc. would be applicable and the branch/ sales staff/
call center would be able to help you in providing the details of the list of
approved documents.
While the internal procedures of the Bank and the guidelines of RBI
require that satisfactory proof of customer identity and addess,RBI has
simplified the KYC procedure with the objective of greater financial
inclusion,i.e. making available the basic banking facilities to those
persons who intend to keep balances not exceeding Rupees Fifty
Thousand (rs.50000) in all their accounts taken together and the total
credit in all the accounts taken together is not expected to exceed Rupees
One Lakh(Rs.100000/-) in a year.
Bank can also help prevent crime against yourself and others by
maintaining the confidentiality of your account details and documents.
"we are losing outr many investors due to delay in completing the
KYC norms. Usually, this is the time, retail investors start investing
into equity linked saving scheme (ELSS)funds for gaining tax
advantages," said a leading distributor on condition of anonymity.
WaqarNaqvi,CEO of Taurus MF said, Due to compulsory KYC, the
appolication volumes have gone up in the last few days". He however
added that the suddenrush might have led to some technical
glitches,which could be ironed outover a period of time.
2.Where and how does one get to be KYC Compliant ?Does the
investor have to repeat the KYC process with every Mutual
Fund?
Answer- The Association of Mutual Funds of India (AMFI) has
facilitated a centralised platform through CDSL Ventures Limited
(CDSL), a wholly owned subsidiary of Central Depository
Services(India) Limited , to carry out the KYC procedure on behalf
of all Mutual Funds. Once the KYC is duly completed in all regards,
the investor needs to produce a copy of the acknowledgement when
investing for the firsttime with a Mutual Fund. There is no need to
repeat the KYC process individually for each mutual fund.
Compliance Risk:
"But it is for the general good. There is a law and there is need to
follow a certain process.World over compliance risk is the biggest
risk,"he said. Bank officials point out that all application forms are
divided into two parts mandatory information and optional
information. The mandatoryinclues the ISA verification-Identity,
Signature and Address, said Mr. Ghotgalkar,Corporate Head, Retail
Banking , IDBI LtD. Other information, such as previous credit
history and details about the customer's assets are usually part of
optional information, which the customer need not reveal.
Customer Education:
Implementation of KYC procedures requires banks to demand certain
information from customers which may be of personal nature or
which have never been called fore. This can sometimes lead to a lot
Questioning by the customer as to the motive and purpose of
collecting such information. There is, therefore,a need for banks to
prepare specific literature/pamphletsetc. so as to educate the customer
of the objectives of the KYC programmed.The front desk staff needs
to be specially trined to handle such situations while dealing with
customers.
Employee's Training :
Banks must have an on-going employee training programme so that
the members of the staff are adequately trained in KYC
procedures.Training requirements should have different focuses for
frontline staff,compliance staff and staff dealing with new customers.
It is crucial that all those concerned fully undewrstand the rationale
behind the KYC policies and implement them consistently.
Hiring of Employees:
It may be appreciated that KYC norms/AML standards?CFT measures
have been prescribed to ensure that criminals are not allowed to
misuse the banking channels. |It would, therefore, be necessary that
adequate screening mechanism is put in place by banks as an integral
part of their rewcruitment/ hiring process of personnel.
Purpose
1.Main purpose for doing so is to prevent future mal practice and
financial frauds.
3.To aware customer time to time there must be need for training of
employee.
No prize for the right answer.But penalty is huge if you don't know
your customer',especially in the world of finance.
Keys
List checking
*Internal lists
*Other lists
Keys
*Where to stop
* Strong penetration
.
*Can be leveraged for other risks to the organization.
Keys
*Shelf-ware
CIP solutions
# Integration issues
Keys
OBJECTIVES OF STUDY
RESEARCH METHODOLGY
TYPE OF DATA:-There are two type of data i.e. Primary data and
secondary data. For carrying out this research study I need Primary Data.
For carrying out this study I will use questionnaire as a method of data
collection.
56 ATM Services:
64 Shri.O.P.Bhatt-Chairman
65 Shri. Sk.Bhattacharyya-MD &CC&RO
66 Shri.R. Sridharan-MD & GE(A&S)
67 Shri.D.Sundram.
68 Shri Dileep .C.Choksi.
69 The only Indian Bank to find a place in the Fortune Global 500 list-
Improved Ranking from 495 last year to 380 this year.
70 Reputation Institute, USA has ranked SBI 29th .
71 Awarded the "Bank of the Year- 2008 India " by the Banker Magazine,
London.
72 Ranked #1 in survey of Top 5 Companies in India in terms of
Financial Reputation by Wall Street Journal Asia.
AXIS BANK
HISTORY- Axis Bank was the first of the new private banks to have
begun operations in 1994, after the Govt. of India allowed new private
banks to be established. The Bank was promoted jointly by the
Administrator of the specified undertaking of the Unit Trust of India
(UTI-I), Life Insurance Corporation of India(LIC) and General Insurance
Cororation of India (GIC) and other four PSU insurance companies, i.e.
National Insurance Company Ltd., The New India Assurance Company
Ltd., The Oriental Insurance Company Ltd. and United India Insurance
Company Ltd.
83 MISSION:
84 Customer Service And Product Innovation tuned
todiverse needs of
85 individual and corporate clientele.
86 Continuous technology upgradation while maintaining
human values.
87 Progressive globalization and achieving internalional
standards.
89 CORE VALUES:
90 Customer Satisfaction through
# providing quality service effiectively and
efficiently
Karnataka bank has expanded its reach to various parts of India, over
the85 years of its existence.Today, the bank has a total of 447 branches,
spread across 19 statesand 2 Union Territories, with a total business of
about Rs. 31,248 crore. The bank presently employees over 4,900
employees and is answerabl,es to about 71,822 shareholders and over 3.7
million customers. The bvank hes specialized branches like Agricultural
Development Branch, Overseas, Foirsign Excharge Branches,
Specialized SSI Branches, Asset Recovery Management Branches,
currency Chests,Central Processing Centre spread across the length and
breadth of the country.
KARNATAKA BANK:-