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Internship report
on
“Money laundering and its prevention policy of
banking and financial institution”

Prepared for:
Dr. Mohammed Mehadi Masud Mazumder
Professor, Department of AIS
University of Dhaka

Prepared by:
Suman Chandra Howlader
ID: 11530066
Department of Accounting and Information System
University of Dhaka

Date of submission: 15 January 2018


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Table of Contents
Letter of transmittal………………………………………………………………………………………………………

Acknowledgement…………………………………………………………………………………………………………

Executive Summary………………………………………………………………………………………………………..

Origin of the report………………………………………………………………………………………………………..

Objectives of the report………………………………………………………………………………………………..

Methodology and data collection………………………………………………………………………………….

Introduction…………………………………………………………………………………………………………………

Definition of Money Laundering…………………………………………………………………………………...

Reasons of Money Laundering……………………………………………………………………………………..

Stages of Money Laundering………………………………………………………………………………………..

Consequences and why to combat money laundering and terrorist financing………………..

Money Laundering Prevention Act 2002 & 2009………………………………………………………….

Responsibility and power of Bangladesh Bank in preventing Money Laundering………….

Money Laundering Court……………………………………………………………………………………………..

Crime and Punishment…………………………………………………………………………………………………

Anti-Money Laundering Department of Bangladesh Bank…………………………………………..

Anti-money laundering process of our financial institutions…………………………………………

What our financial institution and government should do to combat money laundering..

Recommendations…………………………………………………………………………………………………………

Conclusion...........................................................................................................
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Date: 15 January 2018

Dr. Mohammed Mehadi Masud Mazumder


Professor, Department of AIS
University of Dhaka

Subject: Submission of Internship Report.

It is my great pleasure to submit my Internship report of 3 months Internship program in


Agroni Bank Limited. The title of the report is “Money laundering and its prevention
policy of banking and financial institution”. This report has been prepared to fulfill the
requirement of my internship program under MBA program of University of Dhaka.

I have tried my level best to make this report successful . Although there ware many
limitations to gather information and make report about money laundering, I have tried
to do it as thorough as possible. I would like to express my sincere cordial gratitude to you
for your kind guidance & suggestions in preparing the report.

It would be my great pleasure if you find this report useful & informative to have an
apparent perspective on the issue.

Suman Chandra Howlader


ID: 11530066
Department of Accounting and Information System
University of Dhaka
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Acknowledgement

First of all, I would like to express my sincere gratitude to my academic supervisor Dr.
Mohammed Mehadi Masud Mazumder, Professor, Department of AIS University of Dhaka. I
am deeply grateful to his cordial supervision to me during the Internship Period. His
guideline and time helped me so much to prepare the report in a well-organized manner.
Without his help and guidance I would not beable to make this report well.

I would like to thank to my branch senior officer Md. Abul Kalam Azad. Who helped me so
much during my internship period as well as making my internship report.

I would also like to thank my branch manager Md. Kazi Sah Jalal to assist me during my
internship program in the Agrani Bank.

I wish to convey my cordial gratitude to other officials and my friends who helped me by
suggestion and assistance which were very important to complete my report successfully.

Suman Chandra Howlader

Executive summary:
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Money laundering activities globally became an alarming issue in recent years especially in
the field of financial institutions. For inadequate anti-money laundering policy and
applications, financial institutions cannot prevent such kind of activities. The consequences
of money laundering on economic development are difficult to measure but it is true that
such activity damages the normal environment of economy of a country by encouraging the
criminal activities and corruption. Bank and other financial institution can play a vital role to
prevent money-laundering activities as well as discourage earning illegal money.

Mainly I have divided my report into two parts. The first part of the report is arranged with
the idea of money laundering, reasons behind money laundering, stages of money
laundering and its impact on the economy as well as on the society of any country. The
second part of the report is arranged with the limitations of anti-money laundering act and
the weakness of implementing the act to control it, and I have tried to find out a probable
solution to control money laundering.

Finally the report will end up with recommendations to anti-money laundering division of
the bank. I believe that this recommendations will work as a guideline and directions to
prevent money laundering in the banking sector.

Origin of the report:


All students of MBA (Evening) program of Faculty of Business Studies in University of Dhaka
needs to complete a three months internship in a particular organization as a part of
completing MBA program. After ending the internship, a report submission is mandatory,
under the supervision of the academic supervisor. I have got an opportunity to accomplish
my internship in the Agrani Bank Limited. I started my internship on 5th Nov 2017.

At the time of my internship period, by the my honorable supervisor Dr. Mohammed


Mehadi Masud Mazumder, Professor of Accounting & Information System, University Of
Dhaka, I was authorized to prepare report on Money laundering and its prevention policy of
banking and financial institution.

In the report I tried to provide a sound knowledge about The consequences of money
laundering on social and economic development in a country. I also tried to find out the
challenges for preventing this type of criminal activities and I tried to provide some
recommendation with my limited knowledge, which I believe will be helpful to the banks
and financial institutions in future.

Objectives of the report:


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The objectives of my report is finding out the reason of money laundering and the effect on
our economy, and how bank and other financial institutions are being used for money
laundering as well as I have tried to find out a probable path making some
recommendations that the commercial banks can apply to prevent it utilizing the money
laundering act and guidelines.

Methodology and data collection:


In order to generate this report both Primary data and secondary data is used. The sources
that is used to gather and collect data is given below-

Primary Source:

 Personal interview with branch manager Agrani Bank, Jatrabari Branch.


 Intranet Documents

Secondary Sources:
 Annual Report of reputed commercial banks of our country
 Different written document on banking and financial organizations
 Money laundering prevention act 2002, 2009
 Bangladesh bank’s guideline book on anti-money laundering
 Brochures of some banks and other financial organizations

Introduction:
Money Laundering is a common phenomenon in worldwide to conceal the origin of earned
from criminal activities. It includes illegal transfers, change the nature of assets, and
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concealment of properties, acquired or earned through illegal way. The launderer also
transfers his money in several countries in order to hide its origins. For that reason global
financial markets rise. It is a financial crime & punishable offense. Money laundering and
terrorist financing is very much co-related each other. They have a major influence on a
country’s social, economic, political, and overall development of a society. This type of
activities can weaken individual financial institution, and it is also a great threat to a
country’s overall reputation. Money laundering and terrorist financing are done in a
potential and innovative way. Using new technological idea the money launderers and
terrorist financers are designing more and more complicated and sophisticated procedures
to conceal the origin the earned black money. To face these emerging challenges, the global
community has taken various initiatives against this type of criminal activities. In accordance
with the international initiatives and standards, Bangladesh has also performed Money
Laundering Prevention Act (MLPA), 2012 (repealing the MLPA, 2009) and Anti-Terrorism Act
(ATA), 2009 (as amended in 2012).

Definition of Money Laundering:


Basically money laundering is the process of concealment or disguise the original nature,
source, location, disposition or ownership of illegally earned properties and ,converting
these properties into another form or transferring, bringing, remitting these properties into
several countries so that the money appeared to be earned from the legitimate source.
These illegal activity includes, earnings from drugs, smuggling, murder, bribes, theft or
robbery, blackmail, kidnapping, terrorism, tax evasion and any other crime committed that
results in financial gains.

Reasons of Money Laundering:

To show Legitimacy of Funds:


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Launderer earns money from illegal source. But normally they maintain a higher lifestyle
with uneconomical way so they need to expand more money showing that it was legally
earned. So the launderers legitimate their earnings by money laundering process.

Hide Sources of illicit proceeds:

By using the money laundering procedure after performing several transactions by the
financial institutions it becomes too much difficult to trace the original source of the money.
For that reason the launderers mainly use the commercial banks and other financial
institutions to conceal the origin of illegal money.

Shield against investigation and capture:

the launderer knows well, earnings from illegal sources is a punishable crime so they need
their money to be appeared legal so that the investigator cannot impose the law for
punishment. To shield illegal earnings from suspicion of authority and protect them from
being expropriated, criminals must try to make their legal.

Stages of Money Laundering:


In fact there is no certain method of laundering money. For example, usually most of the
criminal earnings are done in cash. This cash need to enter into a financial system by any
financial institutions so that this cash can be converted into another form which can easily
be transformed of concealed. Different methods are used by the launderer but the
laundering process are almost same to all. This process basically involves the following 3
basic stages.
These are:

 Placement
 layering
 Integration.

Placement: The first stage of the money laundering process is called placement. Placement
means depositing cash into Banks and Non-Bank financial Institutions for converting or
changing the form of cash into financial instruments such as buying money market
instruments (securities or fixed deposits, traveler’s checks, payment orders etc.) or buying
expensive and luxury items that has good resale value. Launderer also make small cash
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deposit into different account of different banks instead of large amount to an account of a
bank to avoid suspicion of the authority.

Layering: Layering is the movement of money by multiple transactions through and among
financial institutions so that the illegal origins could be disguised as far as possible. The
launderer moves and changes the form of the funds and their location in order to make it
harder for law enforcement authorities to identify black money. This process of layering is
very dormant so that the authorities can not take legal action with anti-Money Laundering
rules and regulations. Usually the stage involves the Channels by which the funds are being
used for purchasing or selling of investment instruments. The fund goes through a series of
accounts at various banks throughout a country and even crossing the border to purchase
and resale goods, services and assets.

Integration: The third and final stage of money laundering process is called integration.
After being processed successfully the first two stages of money laundering, In this stage the
laundered money are reinvested in the economy as it is legally earned without any
appearance of committed crimes. Popular method of this stage is, launderer use false
export-import invoices by overvaluing goods and services which allows the launderer to
transfer the money from one company or country to another one. Another simple method
to transfer money is using Electronic Fund Transfer (EFT) system to a legitimate bank
account from another account of the launderer.

These three steps can be illustrated in to the following figure-


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Figure: Money laundering process

Consequences and why to combat money laundering and terrorist


financing:
Money laundering and terrorist financing have a devastating effect on economy, security,
and society. By this process the criminals spread their illegal activities everywhere. With the
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help of money laundering process the offences such as illegal trade of drags, stolen goods,
kidnapping murder, back marketing trafficking of women and children, extortion, fraud,
forgery, counterfeiting currency, smuggling of domestic and foreign currency, bribery,
robbery, tax related offence any many other social problem increase which impact on
economy and society.

Impacts on Society:
Laundered money are normally acquired through criminal activity, such as terrorism,
evasion of tax, drug business, theft or robbery, smuggling, illegal gambling, prostitution,
piracy, black mailing, extortion, loan sharking, and any other unlawful activities. Directly or
indirectly these crimes has a deep effect in the society. For example, a drug dealer spreads
his drug business when he can earn more and use his earnings for his personal purpose. By
money laundering process he clean his dirty money and make any other investment. But the
drug addict increase rapidly for the availability of drugs which impacts on the society. Not
only the drug businessman are getting benefited by the money laundering process but also
the other criminal get huge benefitted for the process of money laundering. If the couldn’t
use their earnings they might have been demoralized to do such kind of criminal activities or
this type of activities could not grow like this.
Organized crimes can enter into bank and non banking financial institutions and acquire
control in the economy through investment. It can also encourage the tendency of offering
bribes to public servants, which is an alarming issue in Bangladesh. The impacts of criminal
activities on the politics and economy can weaken the social balance, ethical standards, and
ultimately the normal system of a country.

Threat to the Economy :


Money laundering has a great negative impact on the economy of a country as well as
worldwide. Day by day the growing economy of a developing country are being target of
money laundering due to the lack of regulatory control of the authorities. The launderers
are penetrating into the economy, so the commercial and financial sectors are getting under
the influence of organized crime. Because of money laundering the launderer directly or
indirectly impact on the inflation by devaluating the money of a country so the lower and
middle class people get the main sufferer of that situation.

Money laundering devaluate asset and commodity prices which causes misallocation of
resources. It can lead to an instability for financial institutions and unsound asset structures
which can create risks of monetary instability and even systemic crises. The loss of
credibility and investor confidence as well as the customers cause devastate the financial
system of the smaller economies.
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One of the most dangerous micro-economic impacts of money laundering is seen in the
private business sector. Launderers often use front companies to offer products at prices
below its manufacturing costs. For that reason front companies get a competitive
advantage over legitimate firms who borrow capital from financial markets. Most of the
time it becomes more difficult to the legitimate firms to compete against front companies
with subsidized funding which creates a negative impact on the legitimate business and
that can make them terminated from the business industry. The management policy and
principles of these criminal business enterprise are not consistent with the principles of
legitimate business, which results in further negative macro-economic effects of a country.
Money launderers are not interested to generate profit from their investments but rather in
protecting their earnings illegal activities by the musk of legitimate investment. For that
reason they invest such kind of activities that are not actually economically beneficial to the
country. Moreover, it is a financial crime that redirect funds from profitable investments to
barren investments that conceal their proceeds so, economic growth can suffer. For
example, construction and hotels business, where it has not actual demand, but because of
concealing their origin they use this way. When these this type of businesses no longer suit
to the money launderers, they abandon them, so these businesses get collapsed and which
causes a huge economical damage to that industry.

Effects on Financial Sector:

Financial sector includes banks and non-banks other financial institutions, such as private
lenders, and equity markets. These institutions are important to the economy because they
are an important source of capital resources for the country and their investments generate
a self-sustainable economic development.

Indirectly money laundering impacts in financial sector. When money laundering occurs in a
financial institution, it means an employee is involved with it directly or indirectly,
unknowingly or knowingly, which indicates that financial institution is being used for
terrorist financing, which damages the institution itself. Sometimes money is laundered
through a specific financial institution by bribing the officers who are the inspectors to
detect the laundering activities of an institution. The employees or the management
turning a blind eye having a healthy amount as a bribe. In that kind of cases the institutions
are involving in the criminal activities which is unethical and punishable offence. Once
money laundering happens in a financial institution, and if it becomes known to its
customers, customer trust get damaged as the perceived risk grows up and also considered
to be a corrupted financial organization.

Financial institutions that depend on the proceeds of crime have an additional challenges in
adequately managing their assets, liabilities and operations. For example, large sums of
laundered money may get in a financial institution but without any notice it can disappear
suddenly through wire transfers in response to any non-market factors which can result in
liquidity and operational problem of a bank. Such incidents can damage the financial
intermediaries, regulatory authorities and overall financial sectors.
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Money Laundering also affects adversely in the interest rates and currencies of a country. At
the third and final stage laundered money flows into global financial systems, where it can
undermine national currencies and economies. Money Laundering is not only a law
enforcement problem; it also indicates a serious national and international security threat
as well.

Increase of Reputation risk:

Money Laundering can erode the integrity of a nation's financial institutions. Due to the high
integration of capital markets, Money Laundering can also adversely affect currencies and
interest rates. Ultimately, laundered money flows into global financial systems, where it can
undermine national economies and currencies. Money Laundering is thus not only a law
enforcement problem; it poses a serious national and international security threat as well.

The negative reputation that results from the illegal activities such as money laundering,
terrorist financing, widespread financial fraud, insider trading of securities, and
embezzlement diminishes legitimate global opportunities and sustainable growth. This also
diminishes the infrastructural development of a country. Again, once a country’s financial
reputation is damaged, it becomes very difficult to retrieve. In that situation.

Impacts on Real Sector:

Money laundering has an impact on the Real sector which includes real estate, goods such
as automobiles, arts and anything else that can be called “goods” fall into this sector of the
economy. In most of the cases in real sectors, real state channel is used for laundering
money. When real estate is purchased with laundered money, it causes artificial demand,
which can falsely trigger supply and thus fulfill the real estate market. Because of money
laundering real estate value suffers, because its prices are usually artificially determined
higher the fair market value.

Impacts on Export Import Business:

Imports and exports sectors become affected when proceeds from an illegal activity are
used to import luxury goods by the process of money laundering. When these funds are
used to imports goods, economy suffers because no legal economic transaction is
generated, no employment is created and competition is not supported because of
artificial price set for the purpose of laundering money. Such activities suppress domestic
value of the product, damage natural competition between domestic and global firms, and
decrease the profitability of domestic companies.

Money Laundering Prevention Act 2002 & 2009


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On 7th April 2002 the national parliament of Bangladesh passed “Money laundering
prevention act 2002” understanding the necessity of preventing this financial crime. Before
this act there was no legal procedure to control and prevent money laundering. And on 25 th
February 2009 the second act was passed by the enactment of this law and Bangladesh
Bank was entrusted with all legal power and responsibility to control and prevent money
laundering through all scheduled banks and financial organizations in the country.

Responsibility and power of Bangladesh Bank in preventing Money


Laundering:
 Conducting investigation about money laundering
 Observing and supervising any activities of bank and non-banking financial
institutions.
 Training the staff and officer of the bank and financial organizations to detect
launderer and making consciousness of their transactions.
 Analyzing the financial statement of these institutions to detect the engagement
with money laundering.
 Taking legal action if there is any involvement with money laundering.
 Collecting money laundering report from all scheduled banks.

Source: Guidance Notes on Prevention Of Money Laundering, Bangladesh Bank

Money Laundering Court:

 To fulfill the objectives of laundering act 2002 all courts of sessions will be regarded
as money laundering courts.
 Money Laundering court will accept written agreement of Bangladesh Bank.
 Any kind of offences under this act shall be non-bail able.
 Court can apply the code of criminal procedure.
 Court will be able to make restriction for selling and any other transfer of the asset.
 To freeze the property.
 All receivable of bank account will be deposited to the frozen account.
 Publish on the Gazette and Dailies.
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Crime and Punishment:


 If anyone is engaged in money laundering then the guilty person may be sentenced
to minimum six month and maximum seven years imprisonment and the penalty can
be double of his laundered money. (Section 13 of the Act)

 If anyone violates seizure order the convicted person will be imprisoned for
minimum one year or fined tk. ten thousands or he can be punished with both.
(Section 14 of the Act)

 If anyone violates the freezing order the convicted person will be imprisoned for
minimum one year or fined tk. five thousands or he can be punished with both.
(Section 15 of the Act)
 If anyone get involved in disclosing information or making obstruction to enquiry
hiding relevant information the convicted person will be imprisoned for minimum
one year or fined tk. ten thousands or he can be punished with both. (Section 14 of
the Act)

 If anyone obstructs the investigation the convicted person will be imprisoned for
minimum one year or fined tk. ten thousands or he can be punished with both.
(Section 17 of the Act)

 If the violator of the provision of the act is any bank or any financial organizations
then it will be considered that, each proprietor, director, manager, secretary or any
other officer or employee or representative of the company has violated the
provision of the act. Bangladesh Bank will report this negligence and failure to the
licensing authority of the convicted institution so that the authority can take proper
action (Section 19(3) of the Act).

 Bangladesh Bank is empowered to impose fines to bank or financial institution of


not less than Taka ten thousand and not more than Taka one lakh for the violation of
the provision of act. (Section 19(4) of the Act)

Source: Anti-money laundering act 2002

Anti-Money Laundering Department of Bangladesh Bank:

Bangladesh bank established a specialized department known as Anti Money Laundering


Department to determine the laundering activities occurred by bank and financial
institutions and prevent it.
The prime responsibilities of this department are to provide comprehensive training to all
scheduled banks and financial organizations in the country. They conduct nationwide a
comprehensive training program getting assistance from some of the foreign multinational
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banks. This anti money laundering department is also responsible to conduct investigations
in all scheduled banks. All scheduled banks and financial institutions are to submit a Bi-
monthly and Quarterly money laundering report to this department compulsorily. In this
report any type of suspicious transaction can be found that should be mentioned clearly.
This report is sent by the 15th of the month due. If this report is not submitted on time
Bangladesh bank can take legal action against the institution.

Anti-money laundering process of our financial institutions:

Know Your Customer Procedures:

By opening account a relationship established between financial institutions and clients.


This account opening procedure includes all the necessary information stated clearly by the
customer such as Identification, Bank References, Source of funds and wealth, expected
transaction activity and so on. This is called know your customer KYC profile. This profile
gives the basic status of customer like, Name, Address, contact numbers, income source,
type of business, Annual sales. Financial institutions need to monitor how the accounts are
being conducted to ensure the consistency of the nature of business stated with the
deposited amount or transactions. Institutions need to report the suspicious transactions
undertaken by the clients and need to update the KYC profile for any significant changes in
their lifestyle periodically. KYC procedure also includes the investigation and observation by
the institution’s agent or stuff to the customers business place, type of his clients,
transaction types, payment of method (cash of cheque) etc.

Risk categorization – Based on Activity/KYC Profile:

While opening an account the concerned staff of officer must assess the risk measuring the
possibility that the accountholder can use the account to launder money. He must classify
the accounts as either High Risk or Low Risk. The following risk categories are used to assess
the risk level.

 Nature of customer’s occupation and business.

 Net worth of sales turnover of the customer


 Mode of opening account
 Estimated value of periodic transactions
 Estimated number of periodic transactions
 Estimated value of periodic cash transactions
 Estimated number of periodic cash transaction
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Every categories are scored using the range of scale 1-5. Scale 1-2 indicates low risk, 3
indicates medium risk, 4-5 denotes high risk. If anyone’s KYC profile scores less than 14,
indicates low risk and more than 14 indicates high risk. This assessment of risk are
documented with every KYC profile. The assessed risk of KYC must be updated in a periodic
basis and to be reported to anti-money laundering (AML) Compliance Officer.

Monitoring Transaction Profile:

Financial organizations are to control and monitor the relevant activities of their clients in
the course of the business relationship continuously. The monitoring process depends on
the nature of business. The purpose of this monitoring process is to be cautious about the
significant changes or inconsistencies in the type of transactions.
Possible areas to monitor are:

 Transaction type
 Frequency of transactions
 Unusual large amounts
 Geographical destination
 Changes in account signatories
 Deposit and withdrawal of cash and cheque per month with estimated volume.
 Expected Remitted money per month
 Demand Draft, Telegraphic Transfers and Payment Order per month.

Most effective method of monitoring of accounts is achieved through a combination of


human manual and computerized system. A well trained and conscious officer can utilize
the monitoring method by day to day dealing with customers. Computerized system can be
used to monitor the amount or frequency of transactions setting different categories of
customer automatically.
When inconsistency in this type of categories crops up in the transaction profile is subject
revision and subsequent upgrading.
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Cash Transaction Report (CTR):

Every month all financial organizations has to sent a report to the central compliance unit,
Head office which is known as Cash Transfer Report. Every cash transaction of the branch
must be reported to the Central Compliance Unit, Head office using Financial Intelligence
Unit (FIU) reporting system software provided by Bangladesh Bank. And finally head office
send the report to the Anti-Money Laundering Department of the Bangladesh Bank.

Reporting Suspicious Activity of the clients:

Financial organizations should establish written internal procedures so that the suspicious
activity would discover with the reporting process by the staff. The responsible officer
should report about the suspicious activity of the clients to the Anti-Money Laundering
Compliance Officer (AMLCO). If the staff find further suspicious activities by the same clients
which has been reported to (AMLCO) the stuff should continue to report to the (AMLCO).
The AMLCO should determine whether a exposure in accordance with the act is
appropriate.

Self-Assessment Process:

Every financial organizations should establish an annual self-assessment process that will
evaluate how the anti-money laundering department identify the areas of risk in an efficient
and effective manner. The process should include report documenting the work performed,
who performed it, how it was controlled and supervised and resulting findings, conclusions
and recommendations. This assessment process should advice management whether the
internal procedures and statutory obligations of the financial organizations have been
discharged properly.

With the self assessment process the report should provide conclusions to three key
questions:

 Are AML procedures in place?


 Are this procedures being adhered to?
 Do this procedures comply with all policies, controls and statutory requirements?

Source: Guidance Notes on Prevention Of Money Laundering, Bangladesh Bank

What our financial institution and government should do to combat


money laundering:

The effective and continuous administrative and legislative environment in the financial
sector must be ensured to combat and control money laundering. Government and judicial
body must ensure a contemporary legal action against this type of financial crime. Though it
is not possible to fight against money laundering by Bangladesh Bank and its scheduled
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banks but law enforcing authorities must stop the related crime and the punishment must
be further exemplary.

 Authority must stop HUNDI system. This system is a major tool of laundering money
and terrorist financing in our country.
 Bank authorities must be careful and honest in dealing with export-import business
so that the probability of suffering for under and over invoicing will be decreased.
 Bank staff should encourage rural people to use banks for their transactions. Though
bank staff need to be well trained to make them cultured and well trained.
 In accordance with the feedback from the financial institutions and Bangladesh
Bank money-Laundering prevention act must be updated time to time with the
change of global phenomenon.

 Money laundering department of Bangladesh Bank must be well equipped in


terms of resources, training system to its scheduled financial institutions,
segregation of work and adequate authority. Bangladesh Bank AML department
must be sent to overseas for standard and contemporary training so that they
would be able to train the other bank staff well.

 All scheduled banks and financial institutions must take appropriate measures
immediately by setting separate Anti-Money Laundering Compliance Unit by
setting AML Policy for their banks, they must establish appropriate KYC
principals and train their staff well to recognize suspicious transaction. The
accounts keeping system must be special computerized system so that if can
measure the frequency and amount of transactions as well as notify these
transactions.

 Government must take a consistent policy in relation to Finance, Trade and


Commerce, Taxation with law enforcing sectors so any kind of crime,
embezzlement or misappropriation occurred in these sector the effective action
can be taken promptly.

 In some cases it is seen that some corrupt bankers are involved to help the
launderer to launder money in that case bank authorities should take proper
action against the officer.

 When the launderer is a public figure or powerful person the bank government
and media should work together and publish this to publicly.

 Since the origin of laundering money is crime so without uprooting the criminal
offences it is quite impossible to combat money laundering by making money
laundering law. So the government must stop the crime first and punish them
within shortest possible time. Government pay scale must be made at par with
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the Cost of Living index and at the same time Government agencies to be made
accountable to people.

 Making law against money laundering or criminal activities cannot assure 100%
implementation to combat money laundering. Since laundering money is also a
social problem so general awareness among all class and all level people is
necessary through advertisement.

Despite of having difficulty in preventing money laundering Bangladesh Bank especially the
Governor and Deputy Governor have formed central and regional Task Forces immediately of
enactment of the law and they formed a individual department. To prevent money laundering the
Governor has formed four focus group to establish a guideline for its scheduled banks.

Recommendations for Bangladesh Bank:


 Political influence is a great problem in combating money laundering so legal system
should be strengthen to control political issue.
 Communication and controlling system of Bangladesh Bank should be computerized
and automated system so that they get update information about suspicious
transactions.
 Bangladesh bank should have certain budget to anti money laundering department
to train the scheduled banks and financial organizations.
 Effective and efficient supervision of the banking activities must be established in a
frequent manner.
 Penalties and time of imprisonment to the convicted person should be increased.

Recommendations for commercial banks and other financial


organizations:
 Automated working process should be ensured for effectiveness of detecting
suspicious account.
 Commercial banks and other financial organizations should maintain a close
connection with Bangladesh Bank.
 Regular training to make the officer efficient with the new techniques that launderer
can apply
 The efficient officer who would detect the launderer should be awarded.
 Suspected transaction area should be widen.

Conclusion:
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Money laundering has a devastating effect on economy, security, and society. By this
process the criminals spread their illegal activities worldwide. It hinders the economic
growth as well as the overall development of the nation as a whole. Only by making law
against laundering, this type of crime cannot be prevented. Awareness and tactfulness of
the staff/officer is very important to combat it. Proper communication between banks and
the authority must be ensured. Banks KYC profile is a very important component to measure
the probability of involvement with money laundering. If this type of crime cannot control,
the illegal offence will increase rapidly so the government Bangladesh Bank and Law
Enforcement Authority should combat it at anyhow.