05

ANTI MONEY LAUNDERING

Policy

All banks must actively prevent money laundering and any activity that facilitates money
laundering or the funding of terrorist and criminal activities.

Introduction

Money Laundering is a process whereby terrorist, criminal and other illegal organizations,
through a series of large money transactions, use banks and financial institutions to fund
their subversive activities. They undertake these transactions by resorting to false identities/
documents and layering the transactions to hide the origins of the transactions.

Money laundering is the practice of engaging in financial transactions to conceal the identity,
source, and/or destination of illegally gained money. In the United Kingdom the common law
definition is wider: "taking any action with property of any form which is either wholly or in part
the proceeds of a crime that will disguise the fact that the property is the proceeds of a crime or
obscure the beneficial ownership of said property." It is common to refer to money legally obtained
as "clean", and money illegally obtained as "dirty".

In short money laundering is engaging in acts designed to conceal the true origins of criminally
derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or
constitute legitimate assets.

The first use of the term "money laundering" was during the Watergate scandal. U.S. President
Richard Nixon's "Committee to Re-elect the President" moved dirty campaign contributions to
Mexico, then brought the money back through a company in Miami. It was the Guardian
Newspaper (U.K.) that coined the term, referring to the process as "laundering."

In the past, the term money laundering was applied only to financial transactions related to
organized crime. Today its definition is often expanded by government and international regulators
to mean any financial transaction which generates an asset or a value as the result of an illegal act,
which may involve actions such as tax evasion or false accounting. In the UK, it does not even need
to involve money, but any economic good. Courts involve money laundering committed by private
individuals, drug dealers, businesses, corrupt officials, members of criminal organizations such as
the Mafia.

Criminals use banks as disguises for laundering money.

Money laundering is organised.

It is complex by nature:
• Money may be sent by wire, its provenance fading in a maze of electronic transfers which
are broken into manageable wads which can then be withdrawn and redeposited elsewhere,
obliterating the trail.
• Money laundering will use fake invoices or any document to legitimise the laundered
money to outside observers.
Examples of money laundering

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A business taking large amounts of small change each week (e.g. a convenience store)
needs to deposit that money in a bank. If its deposits vary greatly for no obvious reason this
can draw suspicion; but if the transactions are regular and roughly the same the suspicion is
easily discounted. This is the basis of all money laundering, a track record of depositing
clean money before slipping through dirty money
Another method is to start a business whose cash inflow cannot be monitored, and funnel
the small change into it and pay taxes on it. To avoid suspicion shell companies are formed
that could deal directly with the public, perform some service (not provide physical goods),
and have a business that reasonably would accept cash as a matter of course. Dealing
directly with the public in cash gives a plausible reason for not having a record of
customers. For example, a hairstylist is paid in cash, and even if she knows her customers'
names, she does not know their bank details. A record of a haircut must ostensibly be
accepted as prima facie evidence. Service businesses have the advantage of the anonymity
of resources—but the disadvantage that they must deal in cash. A business that sells
computers has to account for the computers, whereas the hairstylist does not have to
produce the cut hair, but the receipt for the computer, even if inflated, exists—that for the
haircut probably does not. It is of course also possible to invent customers, purely for the
purpose of accepting money from them.
In Structuring, (also known as "smurfing"), money is put into the licit economy in such a
way as to avoid legal record keeping and reporting requirements. For example: in the
United States deposits of less than $10,000 (anything over that amount would require a
report to be filed with the IRS ) are made into multiple bank accounts that are then
withdrawn after a sufficient amount of time has passed to avoid suspicion. It is believed
that 47% of the money used in the Twin Tower bombing (World Trade Center in New
York) came through cash deposits and the rest from miscellaneous sources. When the
process leading to the plane attacks commences, the terrorists began withdrawals to finance
the crime – 39% was withdrawn as cash, 11% in cheques and other miscellaneous
withdrawals.
Money laundering happens through the following financial products:
• Cash deposits
• Deposit accounts
• Client accounts
• Bank safety deposit boxes
• Wire transfers – the provenance of money fading in a maze of electronic transfers,
which are broken into manageable wads which can then be withdrawn and
redeposited elsehere, obliterating the trail.
• Correspondent bank accounts
• Omnibus accounts
• Bank bills
• Credit cards
• Back to back loans
• Letters of credit
• Bank accounts for legal entities
• Incorporating a bank
• Private Banking Services

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As financial crime has become more complex, and "Financial Intelligence" (FININT) has become
more recognized in combating international crime and terrorism, money laundering has become
more prominent in political, economic, and legal debate. Money laundering is ipso facto illegal; the
acts generating the money almost always are themselves criminal in some way (for if not, the
money would not need to be laundered).

Money laundering is the act of engaging in acts designed to conceal or disguise the true origins of
criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate
origins or constitute legitimate assets.

Money laundering also includes terrorist financing and may not involve the proceeds of criminal
conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be
used for criminal purposes.

Law

In 2009 The Proceeds of Crime and Money Laundering Act was passed and it came into effect in
2010. This Act emphasizes the importance placed by the Government.

The Act defines money- laundering and the steps banks must take.

Anti-Money Laundering (AML) Compliance Officer Designation and Duties

All Banks should have an Anti-Money Laundering Program Compliance Officer, with the
responsibility of overseeing the Bank’s AML program. The Officer shall be qualified by
experience, knowledge and training.

Banks should provide CBK with contact information for the AML Compliance Officer, including
name, title, mailing address, e-mail address, telephone number and facsimile number. CBK should
be informed of any change.

The duties of the AML Compliance Office shall include:

o Monitoring the Bank’s compliance with AML obligations, overseeing

communication and training for employees.

o Ensuring that proper AML records are kept.

o When warranted, ensure Suspicious Transaction Reports (STR), vide form

CBK/IF8, are filed.

Giving AML Information to Central Bank of Kenya (CBK)

o Under CBK Prudential guidelines (published on March 2006), Banks shall, through
the Compliance Officer; report to the CBK confirmed suspicious activities, which
indicate possible money laundering activities.
o The report shall provide sufficient details, regarding the activities or transactions so
that regulatory authorities can properly investigate and, if warranted, take appropriate
action.
o The Bank shall respond to requests from Banking Fraud Unit (or any other
legal/regulatory requests) about accounts or transactions by immediately searching
records, at its Head Office and the Branches operating in Kenya, to determine whether
it is maintaining or has maintained any account for, or have engaged in any transaction

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 with, individuals, entities, or organizations named in the request.
o Unless otherwise stated in the request, the Bank shall search accounts maintained
by a named suspect during the preceding 12 months, and transactions conducted by, or
on behalf of, or with a named subject, during the preceding 6 months.

Customer Risk Profiling

All accounts being opened will categorize in three risk categories and the same marked in the
system.
• Level 1 (lower risk)
• Level 2 (medium risk)
• Level 3 (high risk)

Checking the Office of Foreign Assets Control (“OFAC”) List

Before opening an account, and on an ongoing basis:

The Branch Manager, or designate shall check to ensure that the potential customer:
1. That the potential customer name is NOT on the UN and EU list given under the following
links:
• The United Nations List
http://www.un.org/sc/committees/1267/consolist.shtml & http://www.un.org/Docs/
sc/committees/INTRO.htm
The European Union List
http://ec.europa.eu/external_relations/cfsp/sanctions/list/consol-list.htm

2. Internal Cautionary list

3. Is not from or engaging in transactions with people or entities from, embargoed

countries and regions listed on the OFAC Web Site.

Does not appear on any other government issued list, or internal cautionary lists.

The Compliance Officer shall consult the list on the OFAC Web Site on a regular basis for
updates and/or subscribe to receive updates when they occur in order to review existing
customer accounts against these lists. In addition the customer database shall be checked
against the United Nations, and European Union Lists.

On determining that a prospective customer, or someone with or for who the customer is
transacting, is on the SDN List or is from or engaging in transactions with a person or entity
located in an embargoed country or region, the Branch Manager shall report to the
Compliance Officer in order to be advised of the appropriate action.

Customer Identification and Verification

The Bank should establish a written Customer Identification Program (CIP) that gives
guidelines on minimum customer identification information to collect for specified customer
account type. The verification of the information received should be performed within a
reasonable time before or after the account is opened and all records for customer identification
information and the verification methods and results maintained.

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The bank should not open or keep anonymous accounts or accounts in fictitious names.

Required Customer Information Deadlines & Control

The Branch Manager or his designate shall ensure that:

The required account opening details are furnished within a month from the account opening
date.

A monthly exception report for all accounts opened with deficient documents is be prepared for
review by Senior Management or their designate, with a copy to the Compliance Officer.

Depending on the nature of the account and requested transactions, the following cautionary
measures are taken for such accounts:

Pending the obtaining and verification restrict the types, and amounts of transactions in the
account.

If suspicious information is found that indicates possible money laundering or terrorist

financing activity, inform the Compliance Officer immediately, for appropriate action.

When a reasonable belief cannot be formed of the true identity of a customer, either because a
potential or existing customer refuses to provide the required information when requested, or
appears to have intentionally provided misleading information, inform the Head of Operations
and Compliance Officer immediately, for appropriate action.

Verifying Information

• Based on the risk, and to the extent reasonable and practicable, person authorizing the
opening of the account shall:

• Ensure that the Bank has a reasonable belief that it knows the true identity of its customers
by verifying and documenting the accuracy of the information obtained about the
customers.

• In analyzing the verification information, consider whether there is a logical inconsistency

among the identifying information provided, such as the customer’s name, street address,
postal code, telephone number, date of birth, and PIN number etc.

• Ensure that information is verified within a reasonable time before or after the account is
opened.

• Appropriate documents for verifying the identity of customers include, but are not limited
to, the following:

• For an individual, valid government-issued identification evidencing nationality, residence,

and bearing a photograph or similar safeguard, such as a driver’s license or passport; and

• For a person other than an individual, documents showing the existence of the entity, a
business search at the registry, such as certified articles of incorporation, a government-
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 issued business license, a partnership agreement, or a trust instrument.

Banks are not required to take steps to determine whether the document that the customer has
provided for identity verification has been validly issued. Banks may rely on a government-
issued identification as verification of a customer’s identity. If, however, it is noted that the
document shows some obvious form of fraud, the bank must consider that factor in determining
whether the bank can form a reasonable belief that it knows the customer’s true identity.

Non-documentary identity verification

In light of the increased instances of identity fraud, the Bank shall supplement the use of
documentary evidence by using the non-documentary means by using the non-documentary
means described below:

 Contacting a customer; or

 Independently verifying the customer’s identity through the comparison of

information provided by the customer with information obtained from references or
other source; or

 Checking references with other financial institutions; or

 Obtaining a financial statement.

o Such non-documentary methods of verification will be used in the following

situations:

 If still uncertain about whether the true identity of the customer.

 When the customer is unable to present a valid (unexpired) government-issued

identification document with a photograph or other similar safeguard;

 When the Bank is unfamiliar with the documents the customer presents for identification
verification;

 When the customer and Bank do not have face-to-face contact; and

 When there are other circumstances that increase the risk that the Bank will be unable to
verify the true identity of the customer through documentary means.

Record keeping

All account identification information will be kept in accordance with the Bank’s retention
policy. Such documents shall include:

• Verification documents, including all identifying information provided by a customer, the

methods used and results of verification, and the resolution of any discrepancy in the
identifying information.

• With respect to non-documentary verification retain documents that describe the methods
and the results of any measures we took to verify the identity of a customer.

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Notice to Customers

The Bank’s Management should send a notice to customers (to be displayed at all branches)
that the Bank will be requesting information from them to verify their identities, and support
transactions.

Reliance on Other Financial Institution for Identity Verification

Under the following circumstances, the Bank may rely on the performance by another Financial
Institution of some or all of the elements of the customer identification program with respect to any
customer that is opening an account or has established an account or similar business relationship
with the other Financial Institution to provide or engage in services, dealings, or other financial
transactions:

o When such reliance is reasonable under the circumstances;

o When the other financial institution is subject to a rule implementing the anti-
money laundering compliance program requirements and is regulated by CBK; or
o When the other financial institution has entered into a contract with the Bank
requiring it to certify annually to us that it has implemented its anti-money
laundering program, and that it will perform (or its agent will perform) specified
requirements of the customer identification program.

Foreign Correspondent Accounts and Foreign Shell Banks

Detecting and Closing Correspondent Accounts of Unregulated Foreign Shell Banks

Banks should not establish, maintain, administer, or manage correspondent accounts for
unregulated foreign shell banks.

Should the Bank detect correspondent accounts for unregulated foreign shell banks the
following steps shall be taken:

o . Upon finding or suspecting such accounts, Bank employees will notify the
Compliance Officer, who will initiate the process of terminating any verified
correspondent account for an unregulated foreign shell Bank.

o The Bank shall terminate any correspondent account that has been determined as
not maintained by an unregulated foreign shell Bank but is being used to provide
services to such a shell bank.

o The Bank shall exercise cautions regarding liquidating positions in such accounts
and take reasonable steps to ensure that no new positions are established in these
accounts during the termination period.

Certifications

The Bank shall require foreign bank account holders to complete certifications:

• The Compliance Office shall send the certification forms to the foreign bank account
holders for completion, and which will require them to certify that they are not shell banks
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 and to provide ownership and agent information.
• The Compliance officer will request for fresh certification upon belief that the information
is no longer accurate and at least once every three years.
• The Bank shall terminate any correspondent account for which it has not obtained the
required AML control information of the regulations regarding shell banks within the time
periods specified in those regulations.
• The certifications will also be obtained from local financial institutions, designated non-
financial businesses (Casinos, dealers in precious metals, automobile dealers) and
Professionals (law and accountancy firms, sole practitioners, and partners), that seek to
establish a relationship with us.

Monitoring Accounts for Suspicious Activity

• The Bank will monitor accounts for suspicious activity using manual methods, through its
line staff, and automated monitoring done at the Compliance Office.
• All suspicious transactions shall be reported directly to the Compliance Officer by all staff.
No staff, other than the Compliance Officer shall report suspicious transactions to CBK.

Account Monitoring

o Among the information to be used to determine whether a transaction is suspicious

are exception reports that include transaction size, location, type, number, and nature of
the activity. Banks should:

o Manually monitor a sufficient amount of account activity to permit identification of

patterns of unusual size, volume, pattern or type of transactions, geographic factors
such as whether jurisdictions designated as “non-cooperative” are involved, or any of
the “red flags” identified.

o Look at transactions, including trading and wire transfers, in the context of other
account activity to determine if a transaction lacks financial sense or is suspicious
because it is an unusual transaction or strategy for that customer.

o The Compliance Officer shall create employee guidelines with examples of

suspicious money laundering activity and lists of high-risk clients whose accounts may
warrant further scrutiny.

o The Compliance Officer, or designate will conduct an appropriate investigation to

establish whether to file a Suspicious Transaction Report (STR) vide form CBK/IF8.

Red Flags

Red flags that signal possible money laundering or terrorist financing include, but are not
limited to:

Nature of business and account activity

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 • The customer has difficulty describing the nature of his or her business or lacks general
knowledge of his or her industry.

• Customer transactions or account activity (e.g. large, frequent or unusual deposits,

withdrawals, payments or exchanges of cash, foreign currency, transfers or negotiable
instruments) which is not consistent with or reasonably related to the customer’s normal
business activities or financial standing;

• The customer's account has inflows of funds or other assets well beyond the known income
or resources.

• The customer's account has a large number of wire transfers to unrelated third parties
inconsistent with the customer's legitimate business purpose.

• Unusual transfer of funds among related accounts, or accounts that involve the same or
related principals.

• A retail business has dramatically different patterns of cash deposits from similar
businesses in the same general location.

• The currency transaction patterns of a business show a sudden change inconsistent with
normal activities.

• A large volume of banker’s cheques, drafts, and/or wire transfers deposited into, or
purchased through, an account when the nature of the account holder’s business would not
appear to justify such activity.

• The owner of a retail business does not ask for cash when depositing cheques, possibly
indicating the availability of another source of cash.

• The customer makes a funds deposit for the purpose of purchasing a long-term investment
followed shortly thereafter by a request to liquidate the position and transfer of the
proceeds out of the account.

Multiple or nominee accounts

• Customers who wish to maintain or use of multiple or nominee accounts, trustee account,
or similar or related accounts which are not consistent with the customer’s normal business
activities, financial standing, or indicated reasons thereof;

• Customers who open numerous accounts and pay in amounts of cash to each of them in
circumstances in which the total of credit would be a large amount; or which are under a
single name or multiple names, with a large number of inter-account or third party transfers
or in the names of family members or corporate entities, for no apparent purpose.

Transfers

The customer makes a funds deposit followed by:

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 o An immediate request that the money be wired out or transferred to a third party, or
to another Bank, without any apparent business purpose.

o An immediately withdrawal by check or debit card without any apparent business

purpose.

Consolidation of funds before transfer:

• Consolidation of multiple smaller accounts at several institutions within same
locality prior to request for onward transmission of funds elsewhere;

• Many small, incoming wire transfers of funds received, or deposits made using
checks and money orders. Almost immediately, all or most are wired to another city
or country in a manner inconsistent with the customer’s business or history.
Activity: The customer's account has unexplained or sudden extensive wire activity, especially
in accounts that had little or no previous activity.

Wire Transfer activity that is unexplained, repetitive, or shows unusual patterns.

Payments or receipts with no apparent links to legitimate contracts, goods, or services.

Suspicious movements of funds from one bank into another, then back into the first bank:
• Purchasing bankers checks from bank A;
• Opening up a checking account at bank B;
• Depositing the cashier’s checks into a checking account at bank B; and,
• Wire transferring the funds from the checking account at bank B
into an account at bank A.
Information

• The customer exhibits unusual concern about the Bank's compliance with government
reporting requirements and the Bank's AML policies (particularly concerning his or her
identity, type of business and assets), or is reluctant or refuses to reveal any information
concerning business activities, or furnishes unusual or suspicious identification or
business documents.

• A Customer is reluctant, when establishing a new account,

• To provide complete information about the nature and purpose of its business,
• Anticipated account activity,
• Prior banking relationships,
• Names of its officers and directors,
• Information on its business location.

• A customer is reluctant to provide information needed to file a mandatory report, to

have the report filed, or to proceed with a transaction after being informed that the
report must be filed.

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 • A customer provides unusual or suspicious identification documents that cannot be
readily verified.

• The customer requests that a transaction be processed to avoid the Bank's normal
documentation requirements.

• A customer or group tries to persuade a bank employee to not file required reports or to
not maintain required records.

• A business or new customer asks to be exempted from reporting or record-keeping

requirements.

• A customer’s home/business telephone is disconnected.

• The customer’s background differs from that which would be expected based on his or
her business activities.

• Walk in: A customer is reluctant to furnish identification when purchasing instruments,

such as banker’s cheques, TC’s in significant amounts.

Credit

• Sudden repayment of scheduled loans where the source of funding is unclear.

• Requests by a customer to provide/arrange/participate in credit facilities where the source

of the customer’s contribution is unclear, not consistent with normal business activities or
financial standing, or involves real property.

• Request to borrow against assets held by the bank or a third party, where the origin of the
assets is not known or is inconsistent with the customer’s standing.

Cash

• Matching of cash deposits/withdrawals with payments or transfers out/in;

• Deposit of cash by means of numbered credit slips so that the total of each deposit is
unremarkable but the total of all the credits is large;

• Company accounts whose transactions, both deposits and withdrawals are dominated by
cash rather than the forms of transactions normally associated with commercial operations
(e.g. cheques, letters of credit, bills of exchange, etc);

• Customers who seek to exchange large quantities or low denomination notes for those of
higher denomination;

• The customer attempts to make frequent or large deposits of currency, insists on dealing
only in cash, or asks for exemptions from the Bank's policies relating to the deposit of cash.
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 • A rapid increase in the size and frequency of cash deposits with no corresponding increase
in non-cash deposits.

• Frequent deposits of currency wrapped in currency straps or currency wrapped in rubber

bands that are disorganized and do not balance when counted.

Thresholds

• The customer engages in transactions involving cash or cash equivalents or other monetary
instruments that appear to be structured to avoid the $10,000 government reporting
requirements, especially if the cash or monetary instruments are in an amount just below
reporting or recording thresholds.

• A customer who purchases a number of Bankers cheques, money orders, or traveller’s

cheques for large amounts under a specified threshold.

• A customer uses the automated teller machine to make several bank deposits below a
specified threshold.

Third party

• Deposits of large third-party cheques endorsed in favor of customer;

• The customer appears to be acting as an agent for an undisclosed principal, but declines or
is reluctant, without legitimate commercial reasons, to provide information or is otherwise
evasive regarding that person or entity.

Blacklists

• The customer is from, or has accounts in, a country identified as a non-cooperative country
or territory by the FATF(Financial Action Task Force).

• Wire transfer activity no apparent business purpose to/from a financial secrecy haven, or
high-risk geographic location without an apparent business reason, or when it is
inconsistent with the customer’s business or history.

Source of funds

• The information provided by the customer that identifies a legitimate source for funds is
false, misleading, or substantially incorrect.

• Upon request, the customer refuses to identify or fails to indicate any legitimate source for
his or her funds and other assets.

Bank Employees

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 • Lavish lifestyle that cannot be supported by an employee’s salary.

• Failure to conform with recognized systems and controls, particularly in private banking.

• Reluctance to take a vacation.

Negative publicity

• The customer (or a person publicly associated with the customer) has a questionable
background or is the subject of news reports indicating possible criminal, civil, or
regulatory violations.

Charges

• The customer exhibits a lack of concern regarding commissions, or other transaction costs.

Dormant accounts

• Large or unusual activity in dormant/inactive accounts

Suspense

• The customer engages in excessive use of suspense accounts without any apparent
reason

Responding to Red Flags and Suspicious Activity

• When a member of the Bank detects any red flag he or she will investigate further under the
direction of the AML Compliance Officer. This may include gathering additional information
internally or from third-party sources, contacting a government authority, freezing the account,
or filing a Form CBK/IF8.

Suspicious Transactions Reporting

Filing a Form CBK/IF8

The Bank will through the Compliance Officer:

• File Form CBK/IF8 for any account activity (including deposits and transfers) conducted or
attempted through our Bank involving KES400,000 ($5,000) or more of funds or assets
where we know, suspect, or have reason to suspect that:

• The transaction involves funds derived from illegal activity or is intended or conducted in
order to hide or disguise funds or assets derived from illegal activity as part of a plan to
violate or evade the law or regulation or to avoid any transaction reporting requirement
under the law or regulation,
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• The transaction is designed, whether through structuring or otherwise, to evade the any
requirements of the applicable regulations,

• The transaction has no business or apparent lawful purpose or is not the sort in which the
customer would normally be expected to engage, and we know, after examining the
background, possible purpose of the transaction and other facts, of no reasonable
explanation for the transaction, or

• The transaction involves the use of the Bank to facilitate criminal activity.

• Not base its decision on whether to file a CBK/IF8 solely on whether the transaction falls
above a set threshold. CBK/IF8 will be filed of all transactions that raise an identifiable
suspicion of criminal, terrorist, or corrupt activities.

• Periodically report all CBK/IF8s to the Board of Directors and Top Management, with a
clear reminder of the need to maintain the confidentiality of the CBK/IF8.

• Report suspicious transactions by completing a CBK/IF8 and collecting and maintaining

supporting documentation as required by the applicable regulations. The CBK/IF8 shall be
filed not later than 30 calendar days after the date of the initial detection of the facts that
constitute a basis for filing a CBK/IF8. If no suspect is identified on the date of initial
detection, the Bank may delay filing the CBK/IF8 for an additional 30 calendar days
pending identification of a suspect, but in no case, will the reporting be delayed more than
60 calendar days after the date of initial detection.

• Retain copies of any CBK/IF8 filed and the original or business record equivalent of any
supporting documentation for 7 years from the date of filing the CBK/IF8. Supporting
documentation will be identified and maintained and such information made available to
CBK, or any appropriate law enforcement agencies, state securities regulators, upon
request.

• Not notify any person involved in the transaction that the transaction has been
reported, except as permitted by the applicable regulations. Disclosure of any of the
information contained in the CBK/IF8 shall be only as required by law.

Transfers of KES240,000 ($3,000) or More

For transfer funds of KES 240,000 or more record on the transmittal order at least the following
information:

• The name and address of the transmitter and recipient

• The amount of the transmittal order

• The identity of the recipient’s financial institution, and the account number of the recipient

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 • Verify the identity of transmitters and recipients who are not established customers of the
Bank (i.e., customers of the Bank who have not previously maintained an account with us
or for whom we have not obtained and maintained a file with the customer's name, address,
taxpayer identification number, or, if none, alien identification number or passport number
and country of issuance).

AML Record Keeping

Banks must establish procedures to maintain AML program records and reviews. This requirement
includes the records required to be kept as part of the Bank’s CIP.

Training Programs

The bank should develop ongoing employee training under the leadership of the AML Compliance
Officer and Top Management. The training will occur on at least once in a year. It will be based on
Bank’s size, its customer base, and its resources.

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