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POLICY

ON
ANTI-MONEY LAUNDERING AND
COMBATING THE FINANCING OF TERRORISM

1- INTRODUCTION
7
— Money Laundering is the conversion or transfer of property, knowing that such
property is the proceeds of offence, for the purpose of concealing or disguising the illicit
origin of the property or of helping any person who is involved in the commission of the
offence to evade the legal consequences of his or her action.
— Financing of Terrorism shall mean the willful provision of financial or other services
with the intention that such services be used or in the knowledge that they are or may be
used, in full or in part, for the purpose of supporting terrorism, terrorist acts or terrorist
organizations.
Generally, the process of money laundering comprises three stages, during which there
may be numerous transactions that could alert a bank to the money laundering activity:
i- Placement : the physical disposal of benefits of the offence or criminal conduct.
ii- Layering : the separation of benefits of the offence or criminal conduct from
their source by creating layers of financial transactions designed to
disguise the audit trail.
iii- Integration : the provision of apparent legitimacy to benefits of the offence or
criminal conduct. If the layering process succeeds, integration
schemes place the laundered funds back into the economy so that
they re-enter the financial system appearing as normal business
funds.

2- BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING AND FINANCING


OF TERRORISM

— The Law on Banking and Financial Institutions of 1999


— The Law on the Anti-Money Laundering and Combating the Financing of
Terrorism of March 24, 2007
— Prakas on Anti-Money Laundering and Combating the Financing of Terrorism
of May 30, 2008

To adhere to the Law on Anti-Money Laundering and Combating the Financing of


Terrorism and the Prakas on Anti-Money Laundering and Combating the Financing of
Terrorism, all management of ACLEDA Bank Plc shall develop, administer, and
maintain the following system and procedures:
a)- A system of internal control to ensure ongoing compliance with the law and
relevant regulations of National Bank of Cambodia (NBC).
b)- Independent testing of compliance.

POLICY AND PROCEDURE ON AML / CFT -1-


Terrorism, all management of ACLEDA Bank Plc shall develop, administer, and
maintain the following system and procedures:
a)- A system of internal control to ensure ongoing compliance with the law and
relevant regulations of National Bank of Cambodia (NBC).
b)- Independent testing of compliance.
c)- Daily coordinating and monitoring of compliance by a designated person and
relevant staffs.
d)- Training program shall be provided to all new recruits before they start to work
for the bank and refresher courses shall be conducted two times per annum for
front-line (Teller, Customer Service Officer, Credit Officer, Trade Finance
Officer, and Sale Officer) or relevant staffs.
2.1- All personnel of the bank shall pay attention to the official customers' identification and
other necessary relevant supporting documents.
2.2- Opening anonymous accounts and account in fictitious names shall be prohibited. Make
sure that no customer is allowed to open or operate an anonymous account or an account
in a fictitious, false or incorrect name.
2.3- Should not open account for or conduct business with a shell-company, which does not
conduct any commercial activities or have any form of commercial presence in the
country but are legal entities through which financial transactions may be conducted.
2.4- Report to the Financial Intelligence Unit for cash transactions exceeding USD 10,000.00
(or 40 million Riels or foreign currency equivalent), within 14 days of the date of
transaction, referred to article 28 of Prakas on Anti-Money Laundering and Combating
the Financing of Terrorism by National Bank of Cambodia of May 30, 2008.
2.5- To ensure an effective system of internal control, the management of the bank shall
establish a comprehensive procedure which is the process of internal control
implementation, including know your customer policy (KYC), checking and controlling
the new account opening and its transactions, and reporting the suspicious transaction.
2.6- The bank's internal or external auditors must:
ƒ Attest the overall integrity and effectiveness of management systems and control
fully comply with the Law and Parkas of NBC.
ƒ Test transactions in all areas of the bank with emphasis on high risk areas,
products, and services.
ƒ Access adequacy of the bank's process for identifying suspicious activity
2.7- The bank must maintain recorded documents and copies of documents involved in all
forms of transactions for at least 5 years after the date of transaction and the accounts
have been closed or the business relations with customer have ended.
2.8- The bank management shall ensure that appropriate personnel including senior
managements and all relevant staffs are trained in all aspect of the regulatory
requirements of the Prakas of NBC, internal policy and procedure on Anti-Money
Laundering and Combating the Financing of Terrorism.
2.9- All levels of the bank management and staffs are obligated to report all types of
suspicious transactions and shall be required to keep confidentiality of any information
obtained on suspected customers' transaction and record has been made.
3- DESIGNATION OF PERSONNEL TO BE RESPONSIBLE FOR IMPLEMENTING
THE POLICY AND PROCEDURE

POLICY AND PROCEDURE ON AML / CFT -2-


3.1- The bank management shall designate a bank's Compliance Officer as senior
management (referred to article 36 of Prakas on Anti-Money Laundering and
Combating the Financing of Terrorism) to be responsible for implementing the policy
and procedure including the following duties:
ƒ Updating policy and procedure
ƒ Providing training to staffs
ƒ Independent carrying out daily checking, coordinating, and monitoring
throughout the bank network
ƒ Receiving all suspicious transactions report (SRTs) from the entire network of
ACLEDA Bank Plc within 24 hours and independently submitting the report to
Financial Intelligence Unit of Cambodia if there is reasonable ground of
suspicion
3.2- Compliance Officer is responsible for developing a system of internal control to ensure
ongoing compliance while Internal Audit Division and Human Resource Division are
respectively for testing the compliance with the policy and procedure, and training
personnel referred to point "d" of point 2 above.

4- MONITORING AND UPDATING THE ACLEDA'S BLACK LIST

Compliance Officer shall be responsible for recording and updating the


ACLEDA's Black List for the bank's use as a whole. The sources of the black list shall
derive from NBC and independent research into the US Treasury (OFAC) and/or other
necessary sources. The updated list must be disseminated in the timely manner to the
entire bank network and the action must be taken to prevent money laundering and
financing of terrorism.

(2)

POLICY AND PROCEDURE ON AML / CFT -3-


OPERATING MANUAL AND PROCEDURE
ON
ANTI-MONEY LAUNDERING AND
COMBATING THE FINANCING OF TERRORISM

1- INTRODUCTION
7
This operating manual is solely aimed at enhancing the full adherence and
ensuring all domestic and international financial transactions of ACLEDA Bank Plc.
are not involved in money laundering or financing of terrorism. More importantly, we
can evade the regulatory sanctions, and maintain good reputation of the bank on a
timely and due basis in a full compliance with the existing policies, and other related
regulations.
— The Law on Banking and Financial Institutions of 1999
— The Law on the Anti-Money Laundering and Combating the Financing of
Terrorism of March 24, 2007
— Prakas on Anti-Money Laundering and Combating the Financing of
Terrorism of May 30, 2008
— ACLEDA Bank's policy on Anti-Money Laundering and Combating the
Financing of Terrorism approved by the Board of Directors on October 02,
2009.

To fully comply with the policies and relevant regulations, all personnel of ACLEDA
Bank must follow and implement the following procedures on Anti-Money
Laundering and Combating the Financing of Terrorism.

2- THE DEFINITION OF MONEY LAUNDERING AND TERRORIST


FINANCING
— Money Laundering is the conversion or transfer of property, knowing that such
property is the proceeds of offence, for the purpose of concealing or disguising the
illicit origin of the property or of helping any person who is involved in the
commission of the offence to evade the legal consequences of his or her action.
— Financing of Terrorism shall mean the willful provision of financing or other
services with the intention that such services be used or in the knowledge that they are
or may be used, in full or in part, for the purpose of supporting terrorism, terrorist acts
or terrorist organizations.
Generally, the process of money laundering comprises three stages, during which
there may be numerous transactions that could alert a bank to the money laundering
activity:
i- Placement : the physical disposal of benefits of the offence or criminal conduct;
ii- Layering : the separation of benefits of the offence or criminal conduct from
their source by creating layers of financial transactions designed to
disguise the audit trail;

OPERATING MANUAL ON AML / CFT -1- 1


iii- Integration : the provision of apparent legitimacy to benefits of the offence or
criminal conduct. If the layering process succeeds, integration
schemes place the laundered funds back into the economy so that
they re-enter the financial system appearing to be legitimate
business funds.

3- IMPLEMENTATION OF ANTI-MONEY LAUNDERING AND COMBATING


THE FINANCING OF TERRORISM
3.1- CUSTOMER DUE DILIGENCE MEASURE
Sound KYC policies are essential for protecting the safety and the soundness
of bank integrity and as a critical element in the effective management of bank risks.
Prior to establishing business relations, such as opening accounts, taking stocks, bonds
or other securities into safe custody, granting safe-deposit facilities, wire transfer or
engaging in any other business dealings, designated and/or relevant staffs shall require
customers to furnish the official original photo identification, passport and/or other
necessary documents. Those official identification documents can supply the general
information pertaining to applicants as follows:
y Full Name
y Permanent and mailing address, telephone number, fax or mail
y Date of birth
y Nature of the business / Occupation
y Nationality
3.1.1- INDIVIDUAL CUSTOMERS
In establishing a business relationship with an individual customer designated
and/or relevant staffs shall require the individual to furnish the original and make
copies of one or more of the following documents:
y National identification card
y Passport; or
y Identity document preferably bearing a photograph of the customer, issued
by an official competent authority.
Prior to opening a new account for non-residential customer who doesn't have
the permanent address in Cambodia, designated / relevant staffs shall require the
following documents:
y Passport
y Confirmation letter from the local competent authorities / rental contract to
prove his/her address / confirmation letter from their competent management
if s/he works in Cambodia.
3.1.2- CORPORATE CUSTOMERS
In establishing a business relationship with a corporate customer registered in
Cambodia, designated and/or relevant staffs shall require the company / business to
furnish the original and make copies of at least the following documents:
y Memorandum / Article of Corporation / Partnership
y Business Registration Certificate / Certificate of Authority
y Identification of account holders

OPERATING MANUAL ON AML / CFT -2- 2


y Board of Directors' / Directors' Resolution
y Identification document of Directors / Shareholders / Partners
y Authorization letter for any person to represent the company / institution
ƒ Designated and / or relevant staffs shall conduct a basic research or enquiry on the
background of such company / business to ensure that it has not been, or is not in the
process of being dissolved or wound-up and be aware of the purpose of the account
opening.
ƒ Designated and/or relevant staffs shall verify the identity of all signatures according
to customer due diligence (CDD) for individual customers. When signatories
change, attention should be taken to ensure that the identity of all current signatories
has been verified.
ƒ Before entering business relationship and opening a new account for companies,
businesses or partnerships registered outside Cambodia, designated and/or relevant
staffs shall:
y Require customers to provide the above comparable documents of customer
registered in Cambodia. However, as different countries have varying
standards of control, the originals or certified copies authenticated by notary
public outside the country shall be used for verification. Attention should be
paid to the origin of the documents and the background against which they
are produced.
y Designated and / or relevant staffs that are responsible for opening new
accounts for customers shall make enquiry about or be aware of the purpose
of the account opening with ACLEDA Bank Plc located in Cambodia.
y Designated and/ or relevant staffs shall forward all relevant documents for
account opening to Anti-Money Laundering (AML) Unit to clarify with
Legal & Corporate Affair Division on the legality and appropriateness of the
documentations. The AML Unit shall return the documents after they have
been confirmed they are legitimate and complete by Compliance Officer and
Legal & Corporate Affair Division, at Head Office.
ƒ Where the customer or the owner of the controlling interest is a public company that
is subject to regulate disclosure requirements i.e. a public company listed in a
recognized stock exchange, it is not necessary to seek to identify and verify the
identity of the shareholders of that public company.
ƒ Bank competent management, designated and/or relevant staffs shall also understand
the ownership and control structure of the corporate customers and determine the
source of fund of the customer. This will assist bank in ascertaining any suspicion
concerning the changes to the ownership or control structure and in developing the
customer profile and expected activity through the company/business account.
3.1.3- BENEFICIAL OWNER
Designated or relevant staffs should conduct customer due diligence as
stringent as the one imposed on individual customer when they suspect a transaction is
conducted on behalf of a beneficial owner and not the customer who is conducting
such transaction. Beneficial owner is the natural person (s) who ultimately owns or
controls a customer and/or the person whose behalf a transaction is being conducted. It
also incorporates those persons who exercise ultimate effective control over a legal
person or arrangement.
3.1.4- NON-GOVERNMENT ORGANIZATION (NGO) AND FOUNDATION

OPERATING MANUAL ON AML / CFT -3- 3


In establishing a business relationship with a NGO or Foundation customer,
designated and/or relevant staffs shall require the customers to furnish the original and
make copies of at least the following documents:
y Memorandum / Article of NGO or Foundation
y Authorized Letter of Functioning of organization
y Identification of account holders
y Board of Directors' / Directors' Resolution
y Identification document of Directors
y Authorization for any person to represent the institution / organization
ƒ Designated / relevant staffs should require Non-government Organization or
Foundation establishing business relationship to furnish the constitution document
or other similar documents to ensure that it is properly constituted and registered.
ƒ For non-government organization and foundation registered and based outside
Cambodia, designated / relevant staffs shall require the customer to provide the
authorization letter issued by Ministry of Foreign Affair and International
Cooperation or competent authority in Cambodia.
ƒ Designated and/or relevant staffs shall verify the identity of all signatures according
to customer due diligence (CDD) for individual customers. When signatories
change, attention should be taken to ensure that the identity of all current signatories
has been verified.
ƒ Designated/relevant staff should take steps to understand who control and makes
decisions regarding the Non-Government Organization / Foundation, and the use of
the funds.
3.1.5- TRUST AND NOMINEE ACCOUNTS
ƒ Designated / relevant staffs need to establish whether the customer is acting on
behalf of another person as trustee, nominee or agent.
ƒ Designated / relevant staffs should ensure that customer due diligence requirements
is completed for beneficial owner, when the trust or nominee account is established.
ƒ Designated / relevant staffs should take reasonable measure to understand the
ownership, control structures, the relationship among the relevant parties in handling
a trust or nominee account, and obtain evidence of the identity of the settler, trustee,
nominee, authorized signatories, persons exercising effective control and the
beneficiary.
ƒ Designated / relevant staffs require a written assurance from the trust or nominee
that evidences of the identity of the beneficiaries has been obtained, recorded and
retained, and that the trust or nominee is satisfied regarding the source of funds. In
addition, identification information must be immediately available to bank upon
request.
3.1.6- RELIANCE ON INTERMEDIARIES OR OTHER THIRD PARTIES FOR
CUSTOMER DUE DILIGENCE OR INTRODUCED BUSINESS
ƒ Designated / relevant staffs should be wary and ensure that they do not fall
complacently and completely rely on the customer due diligence conducted by the
intermediary or other third party because ultimate responsibility of customer due
diligence always remains with the bank not the intermediary or third party.
ƒ Designated / relevant staffs must be satisfied that the introducing intermediary / third
party:

OPERATING MANUAL ON AML / CFT -4- 4


y Has carried out customer due diligence by identifying the customer and
verify that identity using reliable, independent source of documents, data or
information
y Has identified the beneficial owner and in respect of corporate customers
understands the ownership and control structure of the customer
y Understands the purpose and nature of the business relationship
y Has put in place a system to provide the bank with access to the
identification documents, data or other necessary documents upon request
and without delay
3.1.7- NON-FACE TO FACE CUSTOMERS
For non-face to face customer, designated / relevant staffs shall require
customers to provide identification / passport and other necessary documents pursuant
to the customer due diligence measure for individual customers, cooperated entities,
non-government organizations, and foundations. Authentication from the original
copy should be made by notary public for the customer outside the country and local
attorney at law or competent authority for the customer having originated in
Cambodia.
3.1.8- CORRESPONDENT BANK AND RESPONDENT BANK
— Correspondent Bank: is a bank that regularly performs services for another
financial institution usually located in another city or marketing area. For instance,
ACLEDA Bank Plc opened a new nostro USD account with ABC Bank located in
New York, U.S.A. Hence ABC Bank is the Correspondent Bank and ACLEDA Bank
Plc is Respondent Bank.
Before establishing to open Nostro or Vostro Account and requesting /
accepting the SWIFT Relationship Management Application (RMA) with
Correspondent or Respondent bank outside Cambodia designated / or relevant staffs
shall conduct the study research and satisfy the information gathered and ensure the
threats of money laundering and financing of terrorism is not imposed on ACLEDA
Bank Plc. through the opened account or correspondent/ respondent relationships.
For the Nostro account opening and requesting to establish or accepting RMA
with correspondent / respondent bank, Financial Institution Department or designated
/ or relevant staffs shall conduct the customer due diligence and collect reliable
information about the correspondent bank as the following:
y Background of counterpart (if possible)
y Structure of board of director and management
y Information of shareholder of the bank (if possible)
y Products and business activities
y Annual reports (if possible)
For the Vostro account opening for correspondent inside or outside the
country, the Financial Institution Department or designated / or relevant staffs shall
require the additional documents and information as stipulated in the above Nostro
Account as the following:
y Commercial License
y Banking License
y Memorandum and articles of association

OPERATING MANUAL ON AML / CFT -5- 5


y Photo identification of account holders
y Letter of Attorney or Board Resolution
y Account opening requested letter of Director or Authorized person
y AML / CFT Policy and Procedure or Certificate of Registration for Money
Laundering Regulation (comparable document) or completion the AML/CFT
questionnaire (Appendix 1)
y Purpose of Vostro account opening with ACLEDA Bank Plc located in
Cambodia
ƒ Financial Institution Department or designed / relevant staffs shall pay close
attention to the account opened for Financial Institutions which have insufficiently
implemented the internationally accepted AML / CFT measures. It is strictly
prohibited to open account or request / accept the RMA with the bank or financial
institutions which have not implemented AML/ CFT measures because there may be
heightened risks exposed to ACLEDA Bank Plc.
ƒ Financial Institution Department or designed / relevant staffs shall ensure that such
correspondent bank / respondent bank relationship do not include correspondent
bank / respondent bank relationship or financial institutions that have no physical
presence (Shell Bank).
ƒ In case of ACLEDA Bank Plc. has not received the completed documents and
relevant information as stipulated above for requesting or accepting RMA, but in
urgent need of requesting or accepting RMA relationship, VP & Head of Financial
Institution Department, Compliance Officer and Legal & Corporate Affair Division
shall have a joint consultation and a decision match before reguesting or accepting
RMA.
ƒ For Vostro account opening or accepting the RMA relationships, Financial
Institution Department, Compliance Officer and Legal & Corporate Affair Division
shall jiontly examine and verify the accuracy and legality of the relevant documents.
ƒ All Nostro / Vostro account opening or requesting/accepting RMA with
correspondent bank / respondent bank, Financial Institution Department or
designated / relevant staffs shall present the relevant documents to Anti-Money
Laundering Unit to check and verify AML seal against the ACLEDA's Black List
before being submitted to competent management for approval.
ƒ President & CEO or Authorized person is a final authorizer for the Nostro account
opening with correspondent bank.
ƒ Financial Institution Department or designated / relevant staff shall file and retain
the relevant copied documents of correspondent bank/ respondent bank.
3.1.9- MICRO FINANCE INTISTUTION LOCATED IN CAMBODIA
Before establishing a business relationship with Micro Finance Institution
(MFI) located in Cambodia, designated / relevant staffs shall understand, and satisfy
the information gathered and ensure that they are not exposed to the threat of money
laundering and financing of terrorism.
3.1.9.1 Entering a business relationship with MFIs, designated / relevant staffs shall at least
collect and assess the following information as below:
ƒ Business license or Authorized letter of entity functioning
ƒ Article and Memorandum
ƒ Photo Identification of account holder

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ƒ Board resolution or account opening requested letter of Director
ƒ Brief background and shareholders of MFI (if available)
ƒ Structure of Board of directors and management (if available)
ƒ Product and business activities
ƒ Policy and procedure of Anti-Money Laundering or completion the AML/CFT
questionnaire (Appendix 2)
ƒ Annual report (if available)
ƒ The purpose of account opening
3.1.9.2 Designated / relevant staffs should not establish relationship with MFIs which have
insufficiently implemented the internationally accepted AML / CFT measures.
3.1.9.3 Designated / relevant staff shall check against ACLEDA's Black List before
submitting to competent management for approval of account opening for MFIs. Prior
consultation of Complaince Officer should be caried out in case the MFIs do not have
the Policy and Procedure in place or having insufficiently implemented the AML/CFT
measure.
3.1.10- MONEYCHANGERS
ƒ Designated / relevant staffs must pay special attention to and should conduct
customer due diligence as stringent as the one imposed on individual customer, and
ensure that the moneychangers who maintain account with ACLEDA Bank Plc are
licensed by National Bank of Cambodia and only conduct legitimate currency
exchange transactions, and ensure that the nature and volume of transaction in the
moneychangers account reflect the nature of their business.
ƒ Designated / relevant staffs shall promptly report to Compliance Officer if identify
any discrepancies in the activities of the moneychangers account.
3.1.11- POLITICALLY EXPOSED PERSONS (PEPs)
— Politically Expose Persons shall mean any individual who is or has been entrusted
with prominent public function is being conducted, including those persons who
exercise ultimate effective control over a legal person or arrangement.
ƒ Designated / relevant staffs should conduct customer due diligence the existing and
new customers to identify whether they are Politically Exposed Persons for
determining the level of AML/CFT risk.
ƒ Once PEP is identified, designated / relevant staffs should take reasonable measures
to establish the source of wealth and funds of such persons.
ƒ The decisions to enter into business relationships with PEPs should be made by
SVP&Head, Branch Manager, and/or staff who acting on behalf of the SVP&Head
or Branch Manager.
ƒ Designated / relevant staffs should be on-going monitoring and record the
information collected from the customer and obtained through independent research,
and fully understands the nature of business relationship and transaction activity.
3.1.12- CUSTOMER WHO USE PRIVATE BANKING
ƒ Designated / relevant staffs should conduct customer due diligence to establish the
customer requesting the private banking service does not engage in the money
laundering or financing of terrorism.
ƒ Designated / relevant staffs should conduct customer due diligence and require
customer to provide the identification and other necessary documents according to

OPERATING MANUAL ON AML / CFT -7- 7


customer due diligence (CDD) for individual customers, incorporated entities, non-
government, and foundation.
ƒ The decisions to enter business relationships with or set account for the private
banking customer should be made by SVP&Head, Branch Manager, and/or staff
acting on behalf of the SVP&Head or Branch Manager.
3.2- CUSTOMER ACCEPTANCE POLICY AND DESIGNED RISK BASED
APPROACH
Designated / relevant staffs shall be clear on measure of customer due
diligence (CDD) to identify the customers who pose a higher than average risk to the
bank. In creating the risk profile of a customer type or an individual customer,
designated / relevant staffs should at least take into consideration the following
factors:
˜ The origin of the customer and location of the business
˜ Background and personal particulars of the customer
˜ Nature of the customer's business
˜ Structure of ownership for a corporate customer, and
˜ Any other information indicating the customer is of higher risk
Following the initial acceptance of the customer, designated/relevant staffs
should continuously monitor the customer's account activity pattern to ensure it is in
line with the customer profile. In case of unjustified and unreasonable differences,
designated/relevant staffs shall reassess below listed characteristics of customer who
have been identified with potentially higher money laundering and/or financing of
terrorism risks:
˜ Money service business (remittance house, exchange house, money transfer
agents and bank note traders)
˜ Casino and/or betting and other gambling related activities
˜ Unregulated charities and other unregulated "not for profit" organizations
especially those operating on a cross-border basis.
˜ Real estate agents
˜ Dealers in precious metals and stones
˜ Lawyers, notaries, other independent legal professional and accountants who
represents their client to prepare for or carry out transactions in relation to
the following activities:
y Buying and selling of real estate
y Managing of client's money, securities or other assets
y Management of bank, savings or securities accounts
y Creating, operating or managing of legal persons or arrangements,
and buying and selling of business entities
˜ Customers that are Politically Exposed Person or "PEPs"
3.3- UPDATING AND DISSEMINATING THE ACLEDA'S BLACK LIST
— ACLEDA's Black List: is the consolidated list which derived from National Bank
of Cambodia (NBC) and U.S Treasury's website (OFAC list) or other nescessary
sources, designed by ACLEDA Bank Plc to be used for the whole network before
establishing a business relationship or providing any services to customers.

OPERATING MANUAL ON AML / CFT -8- 8


3.3.1- HEAD OFFICE
ƒ After receiving the black list from NBC and independent research in U.S Treasury's
website (OFAC list), Compliance Officer shall be responsible for updating and
disseminating the ACLEDA's Black List to all relevant divisions, departments,
centers, and branches.
ƒ Compliance Officer shall send the soft copy of the list through e-mail to all related
divisions, departments, center and branches on the notice-issued day.
ƒ After receiving the letter, SVP & Head of Divisions, VP & Head of Departments /
Centers involved shall urgently circulate the list to all the relevant staffs on the
receiving date or not latter than one day within the working day.
ƒ In case of receiving the letter but failing to obtain the ACLEDA's Black List in soft
copy through E-mail, AVP & Manager of Teller Unit, AVP&Manager of Marketing
Unit, AVP&Manager of Remittance Unit and/or other relevant AVP & Managers
Unit shall promptly contact to Compliance Officer to find the appropriate remedy to
resend on time.
3.3.2- BRANCHES LEVEL
ƒ After receiving the letter, all branch managers shall urgently keep all relevant staffs
informed about the new updated black List on the notice-issued day or not latter than
one day within the working day.
ƒ After getting informed by Branch Managers, all related AVP & Managers in each
branch shall urgently make all relevant staffs known about the new updated black
list on the notice-issued day or not later than one day within the working day.
ƒ After receiving the soft copy of the list through E-mail, AVP & Manager of Teller
Unit, AVP&Manager of Marketing Unit, AVP&Manager of Trade Finance Officer
or other related AVP&Manager shall promptly circulate the list to all relevant staffs
on the receiving date.
ƒ In case of receiving the letter but failing to obtain the black list in soft copy through
E-mail, AVP & Manager of Branch Teller, Branch Marketing officer, Branch Trade
Finance officer and other relevant AVP & Managers of Branch shall promptly
contact to Compliance Officer at Head Office to find the appropriate remedy to
resend on time.

3.4- ACCOUNT OPENING


3.4.1- REQUIREMENT OF IDENTIFICATION AND OTHER NECESSARY DOCUMENTS
ƒ Prior to opening a new account for customers, designated / relevant staffs shall
require customer to provide the official identification and/or other necessary
documents as stringent as the one imposed on point 3.1 above.
ƒ All account opening, designated / relevant staffs shall be fully aware of the purpose
of the new account opening and nature of the customer business.
ƒ Passport, Photo Identification, and other necessary documents shall have at least
three months of validity.
ƒ Opening anonymous accounts and account in fictitious names shall be prohibited.
Make sure that no customer is allowed to open or operate an anonymous account or
an account in a fictitious, false or incorrect name.
ƒ Should not open account for or conduct business with a shell-company, which do
not conduct any commercial activities or have any form of commercial presence in

OPERATING MANUAL ON AML / CFT -9- 9


the country but are legal entities through which financial transactions may be
conducted.
3.4.2- CHECKING PROCESS OF ACCOUNT OPENING
ƒ Before opening an account for customers, designated / relevant staffs carefully
examine the adequacy of the documents and the information provided by the
customers.
ƒ Prior to opening all account types for customers and requesting to add new members
from the account hoder, one relevant staff who first directly meets customer or fills
in the form of account opening application for the customer or the officer who is
responsible for inputting CIF of account opening in to T24 has to check and stamp
AML on the "Specimen Signature for Personal Account" for individual's account or
"Specimen Signature for all Customer Other than Personal Customer" for entity's
account and sign initial adjacent on the top part of the AML seal after duly checking
against ACLEDA's Black List to prove that applicant is not in the black list.
(Appendix 3)
ƒ For semi-online/off-line branches or district offices where ClickSaving Multi User
program is used to open account, checking shall be done by one relevant officer who
first directly meets customer or fills in the form of account opening application for
customer has to stamp AML on the "Specimen Signature for Personal Account" for
individual's account or "Specimen Signature for all Customer Other than Personal
Customer" for entity's account and sign initial adjacent on the top part of the AML
seal after duly checking against ACLEDA's Black List to make sure that applicant is
not in the ACLEDA's Black List. (Appendix 3)
ƒ The authorizer should not sign and approve of the Account Opening Application
Form in case there is no AML stamped and signed initial of the first officer, in
contrast, the authorizer shall be liable for the authorized transactions without having
been checked and stamped AML.
ƒ In case of finding the name of applicant looking similar or match to the ACLEDA's
Black List, designated / relevant staffs must promptly contact to Anti-Money
Laundering Unit, Head Office, for further checking and appropriate action in a
timely manner.
ƒ Designated / relevant staffs shall monitor the transactions in the customer account,
and must promptly report to competent management or Compliance Officer if there
is an inconsistency with the gathered information or expectation.
3.5- REMITTANCE AND WIRE TRANSFER
3.5.1- REQUIREMENT OF IDENTIFICATION AND OTHER NECESSARY DOCUMENTS
ƒ Prior to providing all service of remittance / wire transfer to customer, designated /
relevant staffs shall require customer to provide the official identification and/or
other necessary documents as stringent as the one imposed on point 3.1 above.
ƒ All remittance / wire transfer, designated / relevant staffs shall be aware of or require
customers to clarify the purpose of transfer, which seems to be reliable and
reasonable, and fully understand the nature of customer business.
ƒ Designated / relevant staffs shall require customer to provide relevant documents to
support the remittance / wire transfer such as commercial contract, purchasing order,
commercial invoice, or other relevant document based on the nature of the
transactions.

OPERATING MANUAL ON AML / CFT -10- 10


ƒ In case of finding the name of applicant or beneficiary looking similar or matching
to the Terrorist List, designated / relevant staffs must promptly contact to Anti-
Money Laundering Unit, Head Office, for further checking and appropriate action
on a timely basis.
3.5.2- DOMESTIC TRANSFER
ƒ For all kinds of remittance / wire transfer equal to or in excess of USD 1,000.00
(KHR 4 millions) and other equivalent currencies, designated / relevant staffs shall
require customers to furnish the identification or other necessary documents as
stipulated in 3.5.1 above of the customer due diligence measure.
ƒ Competent management shall resolve whether to conduct the transaction or not
should be based on the compliance with customer due diligence measure, where the
customer doesn't possess photo identification and other necessary document or never
used to have the document kept at the bank either.
ƒ Where the customer has held account or provided the photo identification or other
necessary documents to the bank, there is no need to require again from the
customer, but make sure they can be found when needed. Designated / relevant
staffs shall write down "KYC" or customer account below "Prepared by" on
TRANSFER APPLICATION-Form 07.
ƒ Designated / relevant staffs shall be aware of or ask customers about the purpose of
the transfer conducted, and the nature of customer business.
3.5.2.1 CHECKING PROCESS OF DOMESTIC TRANSFER
ƒ For local transfer transactions equal to or in excess of USD1, 000 (4 millions Riels
or foreign currency equivalent) shall be checked seriously by one relevant officer or
teller who meets and receives Transfer Application Form from customer must check
and stamp AML and sign initial adjacent on the top part of the AML seal on the
Transfer Application-Form 07 in order to prove that the transaction is thoroughly
checked against the ACLEDA's Black List, and applicant or beneficiary is not in the
black list. (Appendix 4)
ƒ Stamping AML shall be undertaken on the first and second page of Transfer
Application (Form 07), and the third page for the customer's copy is not required.
ƒ Exception of stamping AML:
y Inter-Account transfer
y Transfer to personal account
y Transfer to repay loan to the bank
y Transfer to current account for revenue and expense of the government
ƒ The authorizer should not sign and approve of the Transfer Application Form in case
there is no AML stamped and signed initial of the first officer, in contrast, the
authorizer shall be liable for the authorized transactions without having been
checked and stamped AML.
3.5.3- OVERSEA TRANSFER
3.5.3.1 OUTBOUND TRANSFER VIA SWIFT
ƒ All transactions, designated / relevant staffs shall require customer to provide such
photo identification and/or other necessary documents, and relevant information in
point 3.5.1 above.
ƒ For transfer transaction below USD 500 (Riel 2 millions) or other equivalent
currencies, competent management shall be at his or her discretion to provide

OPERATING MANUAL ON AML / CFT -11- 11


service or not to customer having no the identity documents or necessary documents
kept at the bank, which is supposed to fully rely on the customer due diligence
measure.
3.5.3.1.1 CHECKING PROCESS OF SWIFT
ƒ All overseas transactions shall be checked by one relevant officer or teller who
directly meets and receives SWIFT WIRE TRANSFER APPLICATION from
customer need to thoroughly check and stamp AML and sign initial adjacent on the
top part of the AML seal on SWIFT WIRE TRANSFER APPLICARION to prove
that the transaction is rigorously checked against ACLEDA's Black List before the
service has been delivered to customers. (Appendix 4)
ƒ AML shall be stamped on the first and second page of SWIFT WIRE TRANSFER
APPLICATION and the third page for the customer copy is not required.
ƒ The authorizer should not sign and approve of the SWIFT WIRE TRANSFER
APPLICATION in case there is no stamped AML and initial signature of the first
officer but, on the contrary, the authorizer shall be liable for the authorized the
transactions without having been checked and stamped AML.
ƒ For the Head office, Anti-Money Laundering Unit shall check and stamp AML on all
oversea wire transfer the Remittance Unit has published from the oversea short term
account in the system T24. The Remittance Unit or relevant staff must not process
the data into the SWIFT system if there is no AML stamped by Anti-Money
Laundering Unit, on the other hand, the authorizer shall be liable for the authorized
the transactions without having been checked and stamped AML.
3.5.3.2 OUTBOUND TRANSFER VIA WESTERN UNION (W.U)
ƒ All transaction, designated / relevant staffs shall require customer to provide such
photo identification and/or other necessary documents, and relevant information in
point 3.5.1 above.
ƒ For transfer transaction below USD 500 (Riel 2 millions) or other equivalent
currencies, competent management shall be at his or her discretion to provide
service or not to the customer having no the identity documents or necessary
documents kept at the bank, which is expected to be fully compliant with the
customer due diligence measure.
3.5.3.2.1 CHECKING PROCESS OF WESTERN UNION
ƒ All W.U outbound transaction shall be checked by one relevant officer or teller who
directly meets and receives the W.U application (To send Money) from customer
need to thoroughly check and stamp AML and sign initial adjacent on the top part of
the AML seal to prove that the transaction has been rigorously checked against
ACLEDA's Black List before the service has been delivered to customers.
(Appendix 4)
ƒ To stamp AML is required on the first page of To Send Money form, the second
page that is customer's copy is not required to stamp AML.
ƒ The authorizer should not sign and approve of the W.U application (To Send
Money) if discover there is no AML and sign initial of the first officer on the W.U
application (To Send Money). On the other hand, the authorizer shall be liable for
the approved transactions without having been checked and stamped AML.
3.6- BANK DRAFT
— Bank Draft: is a settlement tool designed by ACLEDA Bank Plc. for individual or
business customers to withdraw certain amount of money from ACLEDA's Nostro

OPERATING MANUAL ON AML / CFT -12- 12


Account maintained with correspondent banks abroad. Additionally, this kind of
service is also a possible means of money laundering or financing of terrorism by
some criminals who intend to move money from one place to another in a foreign
country if we have not paid close attention to their identities, supporting documents
and other necessary documents of the applicant and the beneficiary.
ƒ Designated / relevant staffs shall pay close attention to the customer due diligence
measure to establish that the applicant requesting the bank draft of ACLEDA Bank
Plc. is consistent with his or her nature of business.
ƒ Designated / relevant staffs shall require applicants to furnish the identity and
supporting documents and other pertinent information as imposed on the individual
customer, incorporated entities, and NGOs and foundations.
3.6.1- IDENTIFICATION REQUIREMENT AND OTHER NECESSARY DOCUMENTS
ƒ For all Bank Draft transactions conducted for customers, designated / relevant staffs
shall require them to furnish the identification and supporting documents and other
pertinent information as stipulated in the customer due diligence mechanism for
individual customer, incorporated entities, NGO, and foundations.
ƒ For customers having account or documents kept at the bank, there is no need to
make request from the customers again, but make sure it can be found when needed.
3.6.2- CHECKING PROCESS OF BANK DRAFT
ƒ Prior to providing Bank Draft service for customers, designated/relevant staffs
should obviously be aware of the purpose of transaction or make any enquiry indeed
about the intention of using bank's services. Moreover, reliable supporting
documents shall be required from customers.
ƒ For all Bank Draft transactions conducted for customers, prior to sending relevant
documents to Treasury Operation Unit in Operation Division, Head Office, one
relevant officer or marketing officer who is responsible for preparing the documents
for the customer shall check and stamp AML and sign initial adjacent on the top part
of the AML seal on the application form to prove that the transaction has been
thoroughly checked and the applicant or beneficiary is not found in the ACLEDA's
Black List. (Appendix 5)
ƒ Prior to submiting the documents to competent management for approval, Treasury
Operation Unit, Operation Division, shall examine the adequacy and accuracy of the
involved documents and make sure AML stamped and initial signature of the first
officer are properly stamped and signed.
ƒ Authorizer who is entitled to make the final decision on whether to provide services
to customer or not shall not sign and approve of the transactions if there is no stamp
AML and initial sign on the application of the first officer who has prepared the
documents. Otherwise, the authorizer shall be liable for the transactions which have
not been checked and stamped AML properly.
ƒ Designated / relevant staffs shall report to Compliance Officer at the Head Office, if
discovered unusual or unexpected transactions compared with the nature of business
or customer's occupation and other pertinent information gathered.
3.7- TRADE FINANCE PRODUCTS
— Trade Finance Product is an instrument to settle local and international trading
between two or more partners (an exporter and an importer) through which most of
transactions will be conducted on an agreed term and condition. The Trade Finance

OPERATING MANUAL ON AML / CFT -13- 13


products comprise of Letter of Credit, Bank Guarantee, Documentary Collection,
Settlement of foreign bank cheque, buy-sell Traveler Cheque ....etc.
3.7.1 IDENTIFICATION REQUIREMENT AND OTHER NECESSARY DOCUMENTS
ƒ Prior to delivering service to the customers, designated / relevant staffs shall require
customers to furnish the identification or other necessary documents as stipulated in
customer due diligence measure 3.1 above.
ƒ Where the customer has held account or provided the photo identification or other
necessary documents to the bank, it is not necessary to require those documents
again from the customer, but make sure they can be found when it is needed.
ƒ More addition relevant documents for each of the products shall be required from
the customers.
3.7.2 CHECKING PROCESS ON TRADE FINANCE PRODUCTS
3.7.2.1 IMPORT UNIT
ƒ For issuing all Letter of Credit (LC) or receiving the import documentary collection,
designated / relevant staffs who are responsible for preparing documents for
customer shall check and stamp AML and sign initial adjacent on the top part of the
AML seal on the Application for Irrevocable Documentary Credit or Export Bill
Collection which is obtained from the remitting bank to prove that all relevant
information, merchandises, and parties do not appear in the Exclusion List and
ACLEDA's Black List. (Appendix 6)
ƒ Branch level, competent management who is entitled to make the final decision
shall not sign and approve of the Application for Irrevocable Documentary Credit or
Export Bill Collection if there is no AML stamped and initial signature on the
application of the officer who prepares the documents for the customer. Otherwise,
the authorizer shall be liable for the authorized transactions which are not checked
and stamped AML properly. (Appendix 6)
ƒ Head Office, designated / relevant staffs who are responsible for preparing the
documents in Import Unit, Trade Finance Division shall check and stamp AML and
sign initial adjacent on the top part of the AML seal on the Application for
Irrevocable Documentary Credit or Export Bill Collection which has been received
from the remitting bank to prove that all relevant information, merchandises, and
parties do not appear in the Exclusion List and ACLEDA's Black List. Import Unit
shall submit the relevant documents to Anti-Money Laundering Unit for additional
checking against ACLEDA's Black List and sign initial adjacent on the bottom part
of the seal to prove that the relevant parties do not in the ACLEDA's Black List.
(Appendix 6)
ƒ Head Office, competent management who is entitled to make the final decision
shall not sign and approve of the Application for Irrevocable Documentary Credit or
Export Bill Collection if there is no AML stamped and initial signature on the
application of the first officer who prepares the documents and the second officer of
Anti-Money Laundering Unit. Otherwise, the authorizer shall be liable for the
authorized transactions which are not checked and stamped AML properly.
3.7.2.2 EXPORT UNIT
ƒ For issuing all LC or Export Bill Collection under condition of Documentary
Collection or Documentary Credit, designated / relevant staffs who are responsible
for preparing documents shall check and stamp AML and sign initial adjacent on the
top part of the AML seal on the copied of LC (MT700) or other equivalent messages
to MT700 received from the issuing bank, or Application for Irrevocable

OPERATING MANUAL ON AML / CFT -14- 14


Documentary Credit or Export Bill Collection to prove that all relevant information,
merchandises, and parties are not in the Exclusion List and ACLEDA's Black List.
(Appendix 7)
ƒ Branches level, competent management who is entitled to make the final decision
shall not sign and approve of the Application of Request for Processing of
Documents Presented Under Export Letter of Credit or for Collection if there is no
AML stamped and initial signature of the first officer who prepares the documents
for customer on the copied of LC (MT700) or other equivalent messages to MT700
obtained from the issuing bank. Otherwise, the authorizer shall be liable for the
transactions which are not checked and stamped AML properly. (Appendix 7)
ƒ Head Office, designated / relevant staffs who are responsible for preparing the
documents for the customer of Export Unit, Trade Finance Division shall check and
stamp AML and sign initial adjacent on the top part of the seal on the copied of LC
(MT700) or other equivalent messages to MT700 received from the issuing bank or
Application of Request for Processing of Documents Presented Under Export Letter
of Credit or for Collection to prove that all relevant information, merchandises, and
parties are not in the Exclusion List and ACLEDA's Black List. Export Unit shall
submit the relevant documents to Anti-Money Laundering Unit for additional
checking against ACLEDA's Black List and sign initial adjacent on the bottom part
of the seal to prove that the relevant parties do not appear in the ACLEDA's Black
List. (Appendix 7)
ƒ Head Office, competent management who is entitled to make the final decision
shall not sign and approve of the transaction if there is no AML stamped and initial
signature of the two relevant officers of Export Unit and an officer of Anti-Money
Laundering Unit on the Application of Request for Processing of Documents
Presented Under Export Letter of Credit or for Collection or the copied of LC
(MT700) or other equivalent messages to MT700 obtained from the issuing bank.
Otherwise, the authorizer shall be liable for the authorized transactions which are
not checked and stamped AML properly.
3.7.2.3 GUARANTEE UNIT
3.7.2.3.1 ISSUING DOMESTIC GUARANTEE
ƒ For issuing all Domestic Guarantee, designed / relevant officers who are responsible
for preparing documents for the customer shall apparently check and stamp AML
and initial signature adjacent on the top part of the seal on the Application Form for
Issue Guarantee (Domestic Only) to prove that the relevant information, documents,
and parties do not match the Exclusion List and ACLEDA's Black List. (Appendix
8)
ƒ Competent management who is entitled to make the final decision shall not sign and
approve of the Application Form for Issue Guarantee (Domestic Only) if there is no
presence of AML and initial signature of the officer who is responsible for preparing
the documents for the customer. On the contrary, the authorizer shall be liable for
the transactions which are not checked and stamped AML properly.
3.7.2.3.2 ISSUING OVERSEAS GUARANTEE
ƒ For issuing all Overseas Guarantee, designated / relevant officers or the first officer
who is responsible for preparing the document for the customer shall thoroughly
check and stamp AML and initial sign adjacent on the top part of the seal on
Application Form for Issue Guarantee (Overseas Only) to prove that the relevant
information, documents, and parties are not in the Exclusion List and ACLEDA's
Black List. (Appendix 9)

OPERATING MANUAL ON AML / CFT -15- 15


ƒ Branch level, competent management who is entitled to make the final decision
shall not sign and approve of the Application Form for Issue Guarantee (Overseas
Only) if there is no AML stamped and initial signature on the copied application of
the first officer who prepares the documents for the customer. Otherwise, the
authorizer shall be liable for the transactions which are not checked and stamped
AML properly. (Appendix 9)
ƒ Head Office, the first officer / relevant staffs who is responsible for preparing the
documents for the customer of Guarantee Unit, Trade Finance Division shall submit
the relevant documents to Anti-Money Laundering Unit for additional checking
against ACLEDA's Black List and sign initial adjacent on the bottom part of the
seal to prove that the relevant parties are not in the ACLEDA's Black List.
(Appendix 9)
ƒ Head Office, competent management who is entitled to make the final decision
shall not sign and approve of the Application Form for Issue Guarantee (Overseas
Only) if there is no AML stamped and initial signature of the two relvant officers as
mentioned above on the documents. Otherwise, the authorizer shall be liable for the
transactions which are not checked and stamped AML properly.
3.7.2.3.3 RECEIVING OVERSEAS GUARANTEE
ƒ For receiving all Overseas Guarantee, the first officer / relevant officers who are
responsible for preparing the document for the customer shall thoroughly check and
stamp AML and sign initial adjacent on the top part of the seal on the copied of the
Overseas Guarantee to prove that the relevant information, documents, and parties
are not in the Exclusion List and ACLEDA's Black List. (Appendix 10)
ƒ Head Office, the first officer / relevant staffs who are responsible for preparing the
documents for the customer of Trade Finance Division shall send the relevant
documents to Anti-Money Laundering Unit for additional checking against
ACLEDA Black List and sign initial adjacent on the bottom part of the seal to prove
that the relevant parties are not in the ACLEDA's Black List. (Appendix 10)
ƒ The competent management who is entitled to make the final decision shall not sign
and approve on the copied document of Receiving Overseas Guarantee if there is no
presence of AML and initial signature of the officer who prepares the documents for
the customer of Trade Finance Division and an officer of Anti-Money Laundering
Unit. Otherwise, the authorizer shall be liable for the transactions which are not
checked and stamped AML properly.
3.7.2.4 BUYING FOREIGN BANK CHEQUE
ƒ For purchasing all Foreign Bank Cheque, designated / relevant officers who are
responsible for preparing the document for the customer shall thoroughly check and
stamp AML and sign initial adjacent on the top part of the seal on the Application of
Purchase Foreign Cheque to prove that the beneficiary and drawer is not in the
ACLEDA's Black List. (Appendix 11)
ƒ The competent management or the relevant units involved in clearing the foreign
cheque shall not approve or settle the cheque if there is no AML stamped and initial
signature of the officer who has prepare the documents for the customer.
Otherwise, the authorizer shall be liable for the transactions which are not checked
and stamped AML properly.
3.7.2.5 BUYING TRAVELLER CHEQUE (T.C)

OPERATING MANUAL ON AML / CFT -16- 16


ƒ For all purchasing of individual Traveler Cheque (TC) from customer designated /
relevant officers shall try to know the beneficiary and require customer to furnish
the photo identification and/or other necessary documents as stipulated in customer
due diligence measure 3.1 above.
ƒ All transactions of purchasing TC exceeding USD 1,000 (or its equivalent in any
other currencies) designated/relevant staffs who prepares the documents for
customer shall thoroughly check and stamp AML and initial sign adjacent on the top
part of the seal of Application For Purchase of Individual Traveller Cheque to prove
that the beneficiary is not in the ACLEDA's Black List. (Appendix 12)
ƒ The competent management or the relevant units involved shall not approve or
settle the cheque if there is no presence of AML seal and initial signature of the
officer who prepares the documents for the customer. On the other hand, the
authorizer or relevant unit involved shall be liable for the transactions which are not
checked and stamped AML properly.
3.7.2.6 SELLING TRAVELLER CHEQUE (T.C)
ƒ Selling Traveler Cheque (TC) to individual or corporate customer exceeding USD
1,000.00 (or its equivalent in any other currencies) designated / relevant officers
shall try to know the applicant (purchaser) and the photo identification and/or other
necessary documents shall be furnished by the customer as stipulated in customer
due diligence measure 3.1 above.
ƒ Designated/relevant staffs who prepare the documents for the customer shall closely
check and stamp AML and initial sign adjacent on the top part of the seal of Seller's
Copy No.1 and Seller's Copy No.2 of the Purchase Record to prove that the
applicant is not in the ACLEDA's Black List. (Appendix 13)
ƒ The competent management or relevant units shall not approve or issue TC for the
customer if there no AML stamped and initial signature of the first officer who
prepares the document for the customer. Otherwise, the authorizer or relevant unit
involved shall be liable for the transactions which are not checked and stamped
AML properly.

3.8- TRANSACTION MONITORING PROCESS


Transaction monitoring is to identify transactions that appear to be suspicious,
within the point of 3.9 REPORTING PROCESS OF SUSPICIOUS TRANSACTIONS.
Designated / relevant staffs shall regularly keep ongoing monitor on relevant activities
in the course of customer's business relationship. The nature of this monitoring will
depend on the nature of the customer's business. The purpose of this monitoring is for
designated/relevant staffs to be vigilant at any significant changes or inconsistencies in
the pattern of transactions. Inconsistency is measured against the stated original
purpose of the account such as the declared transaction profile of the customer.
Possible areas to be monitored could be:
y Transaction type
y Frequency of deposit and withdrawal, wire transfer, and/or other services
y Unusually large amounts
y Geographical origin/destination
y Changes in account signatories

3.9- REPORTING PROCESS OF SUSPICIOUS TRANSACTIONS

OPERATING MANUAL ON AML / CFT -17- 17


— Suspicious Transaction: shall means a transaction that involves funds suspected to
be the proceeds of offense, or funds related to the financing of terrorism. (The
example of suspicious transaction in Appendix 14)
All levels of the bank management and staffs are encouraged to report all types
of suspicious transactions. To effectively track down the suspected transactions
engaged in the money laundering and financing of terrorism, designated / relevant
staffs shall do as follows:
y Understand or be aware of the nature of customer business and / or
occupation
y The purpose of the customers' transaction
y Expected activities and nature of customers' transaction with the bank
y Independent research and profiling
y Regularly monitor and promptly report unusual transactions.
3.9.1- HEAD OFFICE
ƒ Compliance Officer at the Head Office is nominated to receive all the suspicious
transactions from the entire ACLEDA Bank Plc.
ƒ Compliance Officer shall be obliged to independently submit the information of
suspected transactions to National Bank of Cambodia (Financial Intelligence Unit of
Cambodia) within the 24 hours after the reporting has been received and there is a
reasonable ground of suspicion. (The reports formats of suspicious transaction are
set out in Appendix 15)
ƒ The Compliance Officer can not submitting the suspicious transaction report to the
Financial Intelligence Unit, NBC if those transactions doesn't constitute reasonable
ground but s/he shall record his/her opinion.
3.9.2- BRANCHES LEVEL
ƒ Branch Manager is the faciliator and report to Compliance Officer at Head Office
after receiving all types of the suspicious report withing their own branch.
ƒ In the event that urgent disclosure is required, particularly when the account
concerned is part of an on-going investigation, an initial notification should be made
by telephone or Fax to Compliance Officer.
ƒ The report, relevant documents and information of the transactions or customer shall
be sent to Compliance Officer as his/her instruction.
ƒ After reporting to Compliance Officer, Chief Teller / relevant staffs shall retain the
relevant documents and information, and keep monitoring the customer until further
notice or action taken by Compliance Officer.
3.10- CONFIDENTIALITY KEEPING
ƒ All suspicious transactions are strictly prohibited to publicize or inform the involved
customers when the suspected transactions are submitted to the Compliance Officer
or National Bank of Cambodia (Financial Intelligence Unit of Cambodia).
ƒ The bank managements especially Compliance Officer shall ensure that when
preparing and submitting a suspicious transaction report, the customer and the
reporting of the matter remains confidential and is available only to staff, on a strict
need to know basis.

OPERATING MANUAL ON AML / CFT -18- 18


ƒ Violation of keeping confidentiality is a serious misconduct and/or shall be
subjected by article 15 and article 29 of the Law of Anti-Money Laundering and
Combating the Financing of Terrorism.
3.11- RECORD KEEPING
ƒ Operation Division, all relevant divisions/departments and branches of ACLEDA
Bank Plc must maintain records documents and copies of documents involved in all
forms of transactions for at least 5 years after the date of transaction, the accounts
have been closed or the business relations with customer have ended, referred to
article 11 of the Law on Anti-Money Laundering and Combating the Financing of
Terrorism.
ƒ Where the records are subjected to an ongoing investigation or suspicious
transaction submitted, they shall be retained beyond the retention period of five
years (05 years) until it is confirmed by relevant authority that such records are no
longer needed.
ƒ Operation, relevant divisions/departments, and branches of ACLEDA Bank Plc shall
retain the document as original or copies, on microfilm, or in electronic form which
is safe and admissible when needed.
3.12- STAFFS TRAINING PROGRAM
ƒ Training program shall be provided to all new recruits before they start to work for
ACLEDA Bank Plc.
ƒ Refresher training shall be conducted two times per annum to front-line staffs and
relevant staffs such as Chief Teller, Chief Marketing, Chief Trade Finance, Chief
Credit Officer, Chief Accountant, and Chief Internal Auditors.
ƒ Each branche chief shall set up two times per annum the refresher training to all
relevant staffs under his/her response.
ƒ Training Division is obliged to prepare the training program, material, and
equipment where Compliance Officer lecture on the policy and procedure on anti-
money laundering and combating the financing of terrorism and other relevant
information.
ƒ Operation Division, relevant divisions/departments, and branches of ACLEDA Bank
Plc make sure all designated / relevant staffs have been trained and aware of the
Policy and Procedure on Anti-Money Laundering and Combating the Financing of
Terrorism.
ƒ Operation Division, all relevant divisions / departments and branches of ACLEDA
Bank Plc shall request Training Division or directly contact to Compliance Officer
for any additional training sessions on Anti-Money Laundering and Combating the
Financing of Terrorism.
3.12.1 NEW STAFFS
ƒ Knowing a general background to money laundering and financing of terrorism, the
requirement and obligation to identify and report suspicious transactions to the
competent managements or Chief Branch Teller.
ƒ New staff shall be aware of the benefit of Anti-Money Laundering and Combating
the Financing of Terrorism and confidentiality keeping.
ƒ Knowing the pattern of suspicious transactions and customer due diligence.
3.12.2 FRONT-LINE STAFFS

OPERATING MANUAL ON AML / CFT -19- 19


Appendix 1
U

QUESTIONNAIRE ON AML / CFT


U

(For Correspondent Bank)


Please complete all questions and return your response.
Please confirm the areas of your organisation covered by responses to this survey:
Head Office & domestic branches: Yes … No … Domestic subsidiaries: Yes … No …

Overseas branches: Yes … No … Overseas subsidiaries: Yes … No …

If you have answered “no” to any of the above, please provide area of business excluded, including
name, location and contact details.
.................................................................................................................................................................
.................................................................................................................................................................

1. Institution Name:

2. Registration / Licence No:

3. Address:
Registered Office:

Principal place of business:


Location of Headquarters:

4. Website address:

5. Contact Name:
Contact Telephone:
Email address:

Do you have a “physical presence” or are you a regulated affiliate of an entity Yes … No …
6. with a “physical presence”?

For the purposes of this questionnaire “physical presence” means a place of


business:
- Located at a fixed address (other than solely an electronic address, a post
office address or an accommodation address); and
- In a country in which the bank is authorised to conduct banking activities; and
- Where the bank employs 1 or more individuals full-time and maintains
operating records related to banking activities; and
- Where the bank is subject to inspection by the banking authority which
licensed the bank to conduct banking activities.

Ownership Structure
0B

7. Are you publicly owned? Yes … No …

8. Are you listed on any stock exchange? If so, which? Yes … No …


................................................................................................................................
If no, please attach a list of the beneficial owners of the bank (including their
9. nominees, if their shares are held by nominees) who own, control or have power
to vote for 20 percent or more of any class of voting securities or other voting
interests; or of the 10 largest shareholders if no owner has greater than 20%.

OPERATING MANUAL ON AML / CFT


1
Directors
1B

10. Please attach a list of the executive and non-executive directors of the main
Board of Directors.
Policies and Procedures
2B

Section A
Do you have a policy and procedures for prevention of money laundering and
11. terrorist financing? If no, when will you expect to have it? Yes … No …
........................................................................................................................
If yes, does this policy apply to all of the operations covered by this Yes … No …
12.
questionnaire?

If requested, are you prepared to provide ACLEDA BANK Plc. with a copy of Yes … No …
13. the policy?

14. Do you verify the identity of all customers prior to providing accounts? Yes … No …

Do you verify the identity of all customers including “occasional customers”,


15. prior to providing value transfer services (such as telegraphic transfers, bank Yes … No …
cheques or trade transactions)?

Please confirm that you provide banking services only to other banks/financial Yes … No …
16. institutions with a “physical presence”?

Section B
7B

Do you have an employee training program for prevention of money laundering Yes … No …
17. and terrorist financing requiring all staff to undertake training?

If so, how frequently?............................................................................................

Do you have a policy and procedures for independent audit or testing of your Yes … No …
18. anti-money laundering compliance?
If so, how frequently are these audits/tests conducted?
................................................................................................................................
Do you have a Money Laundering Reporting Officer responsible for co- Yes … No …
19. ordinating / monitoring compliance?
If Yes, Please provide name and address
................................................................................................................................
If no, to any question in Section B please provide comment if applicable.
................................................................................................................................

Reminder: Have you attached lists of beneficial owners (and nominees), your directors and
your highest level of executive management - refer Questions 9 and 10 (if applicable)?

I confirm that I am authorised to complete this document.

Name :...........................
Title :...........................
Date :........./........./.......
U

OPERATING MANUAL ON AML / CFT


2
Appendix 2
QUESTIONNAIRE ON AML / CFT
U

(For Micro Finance Institution)


Please complete all questions and return your response.
Please confirm the areas of your organisation covered by responses to this survey:
Head Office & domestic branches: Yes … No … Domestic subsidiaries: Yes … No …

Overseas branches: Yes … No … Overseas subsidiaries: Yes … No …

If you have answered “no” to any of the above, please provide area of business excluded, including
name, location and contact details.
.................................................................................................................................................................
.................................................................................................................................................................

1 Institution Name:

2 Registration / Licence No:

3 Address:
Registered Office:
Principal place of business:
Location of Headquarters:

4 Website address:

5 Contact Name:
Contact Telephone:
Email address:

Do you have a “physical presence” or are you a regulated affiliate of an entity Yes … No …
6 with a “physical presence”?

For the purposes of this questionnaire “physical presence” means a place of


business:
- Located at a fixed address (other than solely an electronic address, a post
office address or an accommodation address); and
- In a country in which the institution is authorised to conduct activities; and
- Where the institution is subject to inspection by the authority which licensed
the institution to conduct activities.
Policies and Procedures
3B

Section A
Do you have a policy and procedures for prevention of money laundering and
7 terrorist financing? If no, when will you expect to have it? Yes … No …
........................................................................................................................

If yes, does this policy comply with the Law and Prakas on Anti-Money Yes … No …
8 Laundering and Counter the financing of Terrorism?

If requested, are you prepared to provide ACLEDA BANK Plc. with a copy of Yes … No …
9 the policy?

OPERATING MANUAL ON AML / CFT


3
Do you verify the identity of all customers prior to providing accounts?
10 If "no", please give comment:................................................................................ Yes … No …
................................................................................................................................
Do you verify the identity of all customers including “occasional customers”,
11 prior to providing value transfer services (such as telegraphic transfers, bank Yes … No …
cheques or trade transactions)?
Section B
8B

Do you have an employee training program for prevention of money laundering Yes … No …
12 and terrorist financing requiring all staff to undertake training?
If so, how frequently?
................................................................................................................................

Do you have a policy and procedures for independent audit or testing of your Yes … No …
13 anti-money laundering compliance?

If so, how frequently are these audits / tests conducted?


................................................................................................................................

Do you have a Money Laundering Reporting Officer responsible for co- Yes … No …
14 ordinating / monitoring compliance?
If "Yes", Please provide name, title, contact number, and address
...............................................................................................................................
...............................................................................................................................
...............................................................................................................................

If no, to any question in Section "B" please provide comment if applicable.


...............................................................................................................................
...............................................................................................................................
...............................................................................................................................

I confirm that I am authorised to complete this document.

Name :...........................
Title :...........................
Date :........./........./.......
U

OPERATING MANUAL ON AML / CFT


4
Appendix 3

CHECKING FOR ACCOUNT OPENING


U

First Verifier
AML

OPERATING MANUAL ON AML / CFT


5
First Verifier
AML

OPERATING MANUAL ON AML / CFT


6
Appendix 4

CHECKING FOR FUND TRANSFER


U

(Domestic Transfer, Western Union "out", SWIFT "out")

First Verifier
AML
Give to mother

Please put the purpose here

OPERATING MANUAL ON AML / CFT


7
First Verifier
AML

OPERATING MANUAL ON AML / CFT


8
First Verifier
AML

OPERATING MANUAL ON AML / CFT


9
First Verifier
AML

OPERATING MANUAL ON AML / CFT


10
Appendix 5
U

CHECKING FOR BANK DRAFT


U

First Verifier
AML

OPERATING MANUAL ON AML / CFT


11
Appendix 6
CHECKING FOR DOCUMENTARY CREDIT
15BU

First Verifier
AML

Second Verifier

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12
Appendix 7
U
CHECKING FOR L.C or COLLECTION
16BU

First Verifier
AML

Second Verifier

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13
Appendix 8 and 9
CHECKING FOR ISSUING GUARANTEE
U

First Verifier
AML

Second Verifier

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14
Appendix 10
U
CHECKING FOR RECEIVING GUARANTEE
U

First Verifier
AML

Second Verifier

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15
Appendix 11

Bak2es~IsMuTijmUlb3TanbR>tbreTs
APPLICATION FOR PURCHASE OF FOREIGN CHEQUES

elaknayk /nayika FnaKar


The Manager
Gasyd%an:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Address:

kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Date:

eQ`aHKNnI :
Account Name

elxKNnI :
Account No.
TwkRVk'\nmUlb3TanbR>t:
Amount of Cheques

eyIg/}sUmP9ab'CUnmkCamYynUvc3ab'edIm\nmUlb3TanbR>tbreTs niges~IsMu elak/G~k TTYlTijmUlb3Tan


bR>tenH eday … dkkM\resvaCamun … dkkM\resvaeBlbBa|(lTwkRVk'Cak'Es1gcUlKNnIrbs'eyIg/} .
I/We enclose original foreign cheques and would request you to purchase the cheques with recourse to me/us
and credit the proceeds less your charges to my/our account or charges at the time of purchasing.

eyIg/}sUmp1l'siT?iCUn elak/G~k dknUvcMnYnTwkRVk'Cak'Es1g\nmUlb3TanbR>t nigkM\resvaep!gÔBI


;NBn?KNnIrbs'eyIg/} k~-gkrNIEdlmUlb3TanbR>tRtUvVnbg4ilRtLb'mkvij .
You are authorised to debit our account together with any incidental charges for cheques that have been returned
unpaid by the issuers.

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, AML

ht/elxaGtifiCn
Authorised Signature

sMrab'FnaKar
U

For Bank's use only


lk&xN@bBa(|lTwkRVk': P7amÔ /p1l'CUnbn8ab'BIVnTijcMnYn,,,,,,,,\f^
Approved for credit* immediately / after...........days.

erobcMeday : GnuBa0ateday :
Recommended by: Approved by:

U
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,

OPERATING MANUAL ON AML / CFT


16
Appendix 12

Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn
EdlmanTMhMTwkRVk'elIsBI¢,»»»dul7ar rhUtdl'¶,»»»dul7ar
APPLICATION FOR PURCHASE OF INDIVIDUAL
TRAVELLER CHEQUES MORE THAN $1,000.00 TO $5,000.00

elaknayk /nayikasaxa FnaKar


The Manager
Gasyd%an:,,,,,,,,,,,,,,,,,,,,,,,
Address:
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:

eQ`aHGtifiCn :
Customer Name:

Currency Denomination Serial Number Unit Amount

Total:

nagx6-M / x6-MVT es~IsMuelaknayk / nayika edIm3ITTYlTijmUlb3Tanb>RteTscrN_ EdlmanTMhM


TwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .
sUmelaknayk / nayika TTYlnUvkareKarBd*x5g'x5s'GMBInagx6-M / x6-MVT . AML

GnuBa0atieday: bJ9ak'eday: erobcMeday


Approved by: Verified by: Prepared by:
BM Chief Teller Teller

.................................. ................................. ...............................


........../........./............. ........../........./............ ........../........./..........

For Branch

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17
Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn
EdlmanTMhMTwkRVk'elIsBI ¶,»»»dul7ar
APPLICATION FOR PURCHASE OF INDIVIDUAL
TRAVELLER CHEQUES MORE THAN $5,000.00

eKarBCUnelaknaykhirJ0b3TanBaNiC9km`
To: Senior Vice President & Head, Trade Finance Division
Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al
Address: ACLEDA Bank, Headquarters
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:

eQ`aHGtifiCn :
Customer Name:

Currency Denomination Serial Number Unit Amount

Total:

nagx6-M / x6-MVT es~IsMuelaknaykhirJ0b3TanBaNiC9km` edIm3ITTYlTijmUlb3Tanb>RteTscrN_


EdlmanTMhMTwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .
sUmelaknayk TTYlnUvkareKarBd*x5g'x5s'GMBInagx6-M / x6-MVT . AML

GnuBa0atieday: bJ9ak'eday: erobcMeday


Approved by: Verified by: Prepared by:
SVP&Head,TFD BM Branch....... Chief Teller Branch........

.................................. ................................. ...............................


........../........./............. ........../........./............ ........../........./..........

For Branch

OPERATING MANUAL ON AML / CFT


18
Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn
EdlmanTMhMTwkRVk'elIsBI¢,»»»dul7ar rhUtdl'¢»,»»»dul7ar
APPLICATION FOR PURCHASE OF INDIVIDUAL
TRAVELLER CHEQUES MORE THAN $1,000.00 TO $10,000.00

eKarBCUnelaknaykRbtibt1iRbtibt1ikar
To: Senior Vice President & Head, Operation Division
Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al
Address: ACLEDA Bank, Headquarters
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:

eQ`aHGtifiCn :
Customer Name:

Currency Denomination Serial Number Unit Amount

Total:

nagx6-M / x6-MVT es~IsMuelaknaykRbtibt1iRbtibt1ikar edIm3ITTYlTijmUlb3Tanb>RteTscrN_


EdlmanTMhMTwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .
sUmelaknayk TTYlnUvkareKarBd*x5g'x5s'GMBInagx6-M / x6-MVT . AML

GnuBa0atieday: bJ9ak'eday: erobcMeday


Approved by: Verified by: Prepared by:
SVP&Head,OPD Chief Teller Teller

.................................. ................................. ...............................


........../........./............. ........../........./............ ........../........./..........

For OPD

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19
Bak2es~IsMuTijmUlb3TanbR>teTscrN_BISkt1Cn
EdlmanTMhMTwkRVk'elIsBI ¢»,»»»dul7ar
APPLICATION FOR PURCHASE OF INDIVIDUAL
TRAVELLER CHEQUES MORE THAN $10,000.00

eKarBCUnelaknaykhirJ0b3TanBaNiC9km`
To: Senior Vice President & Head, Trade Finance Division
Gasyd%an: FnaKareGsuIlIdakariyal>ykN1al
Address: ACLEDA Bank, Headquarters
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,
Date:

eQ`aHGtifiCn :
Customer Name:

Currency Denomination Serial Number Unit Amount

Total:

nagx6-M / x6-MVT es~IsMuelaknaykhirJ0b3TanBaNiC9km` edIm3ITTYlTijmUlb3Tanb>RteTscrN_


EdlmanTMhMTwkRVk'srub dUcVnbg$ajCUnenAk~-gtaragxagelIenH .
sUmelaknayk TTYlnUvkareKarBd*x5g'x5s'GMBInagx6-M / x6-MVT . AML

GnuBa0atieday: bJ9ak'eday: erobcMeday


Approved by: Verified by: Prepared by:
SVP&Head,TFD SVP&Head,OPD AVP&Mgr Teller OPD

.................................. ................................. ...............................


........../........./............. ........../........./............ ........../........./..........

For OPD

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20
Bak2es~IsMuTijmUlb3TanbR>teTscrN_rbs'PaKITIbI
APPLICATION FOR PURCHASE OF THIRD PARTY
TRAVELLER CHEQUES

elaknayk /nayika FnaKar


The Manager
Gasyd%an:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Address:
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
kalbriec<T:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Date:

eQ`aHKNnI :
Account Name

elxKNnI :
Account No.
TwkRVk'\nmUlb3TanbR>t :
Amount of Cheques

eyIg/}sUmP9ab'CUnmkCamYynUvc3ab'edIm\nmUlb3TanbR>teTscrN_ niges~IsMu elak/G~k TTYlTijmUlb3TanbR>t


enHeday … dkkM\resvaCamun … dkkM\resvaeBlbBa|(lTwkRVk'Cak'Es1g cUlKNnIrbs'eyIg/} .
I/We enclose original traveller cheques and would request you to purchase the traveller cheques with recourse to me/us
and credit the proceeds less your charges to my/our account or charges at the time of purchasing.

eyIg/}sUmp1l'siT?iCUn elak/G~k dknUvcMnYnTwkRVk'Cak'Es1g\nmUlb3TanbR>t nigkM\resvaep!gÔBI;NBn?


KNnIrbs'eyIg/} k~-gkrNIEdlmUlb3TanbR>tRtUvVnbg4ilRtLb'mkvij .
You are authorised to debit our account together with any incidental charges for cheques that have been returned unpaid
by the issuers.

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, AML
ht/elxaGtifiCn
Authorised Signature

sMrab'FnaKar
For Bank's use only
lk&xN@bBa(|lTwkRVk': P7amÔ /p1l'CUnbn8ab'BIVnTijcMnYn,,,,,,,,\f^
Approved for credit* immediately / after...........days.

erobcMeday,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, GnuBa0ateday:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
Recommended by: Approved by:

OPERATING MANUAL ON AML / CFT


21
Appendix 13
U

AML

OPERATING MANUAL ON AML / CFT


22
Appendix 14

EXAMPLES OF SUSPICIOUS TRANSACTIONS


U

1- Cash Transactions, Deposit and Withdrawal


U

ƒ Unusually large cash deposits made by an individual or company whose ostensible


business activities would normally be generated by cheques and other instruments.
ƒ Substantial increases in cash deposits of any individual or business without apparent
cause, especially if such deposits are subsequently transferred within a short period
of time, out of the account and/or to a destination not normally associate with the
customer.
ƒ Company accounts whose transactions, both deposits and withdrawals, are
denominated in cash rather than the forms of debit and credit normally associated
with commercial operations (e.g. cheques, Letters of Credit, Bills of Exchange, etc.)
ƒ Customers who constantly pay in or deposit cash to cover requests bankers' draft,
money transfers or other negotiable and readily marketable money instruments.
ƒ Customers who seek to exchange large quantities of low denomination notes for
those of higher denomination.
ƒ Branches of banks and financial institutions that have a great deal more cash
transactions than usual (Head Office statistics detect aberrations in cash
transactions).
ƒ Customers whose deposits contain counterfeit notes or forged instruments.
ƒ Customers transferring large sums of money to or from overseas locations with
instructions for payment in cash.
ƒ Purchasing or selling of foreign currencies in substantial amounts by cash settlement
despite the customer having an account with the institution.
ƒ Customers making large and frequent cash deposits but cheques drawn on the
accounts are mostly to individuals and firms not normally associated with their retail
business.
ƒ Deposits for a business entity in combinations of monetary instruments that are
atypical of the activity normally associated with such a business.
ƒ Mixing of cash deposits and monetary instruments in an account in which such
transactions do not appear to have any relation to the normal use of the account.
ƒ Multiple transactions carried out on the same day at the same branch of a financial
institution but with an apparent to use different tellers.
ƒ The structuring of deposits through multiple branches of the same financial
institution or by groups of individuals who enter a single branch at the same time.
ƒ The deposit or withdrawal of cash in amounts which fall consistently just below
identification or reporting requirements.
ƒ The customer presents funds that have not been counted and upon counting reduces
the fund involved to an amount just below what would trigger reporting or
identification requirements.
ƒ The deposit or withdrawal of multiple monetary instruments at amounts which fall
consistently just below identification or reporting thresholds, particularly if the
instruments are sequentially numbered.

OPERATING MANUAL ON AML / CFT


23
2- Transactions Involving Bank Accounts
U

ƒ Accounts that appear to act as pass through accounts with high volumes of credits
and debits and low average monthly balances.
ƒ Customers who wish to maintain a number of trustee or client accounts, which do
not appear consistent with the type of business, including transactions, which
involve nominee names.
ƒ The opening by the same person of multiple accounts into which numerous small
deposits are make that in aggregate are not commensurate with the expected income
of the customer.
ƒ Any individual or company whose account shows no normal personnel banking or
business related activities, but is used to receive or disburse large sums which have
no obvious purpose or relationship to the account holder and/or his business (e.g. a
substantial increase in turnover on an account).
ƒ Reluctance to provide normal information when opening and account, attempts to
reduce the level of information provided to the minimum or providing information
that is difficult or expensive for banks and financial institutions to verify.
ƒ Customers who appear to have accounts with several bank and micro finance
institutions within the same locality, but choose to consolidate monies from such
accounts on regular basis for onward transmission of the funds to another 3rd party
account.
ƒ Paying in large third party cheques endorsed in favour of the customer.
ƒ An inactive account containing a minimal sum suddenly receives a deposit or series
of deposits followed by daily cash withdrawals that continue until the transferred
sum has been removed.
ƒ Greater use of safe deposit facilities, which does not commensurate with the
customer profile.
ƒ Customer avoiding contact with employees of banks and financial institutions for
transaction.
ƒ Substantial increases in deposits of cash or negotiable instrument by a professional
firm or company, using client accounts or in-house company, or trust accounts,
especially if the deposits are promptly transferred between other client's company
and trust accounts.
ƒ Customers who decline to provide information that in normal circumstances would
make the customer eligible for credit or for other banking services that would be
regarded as valuable.
ƒ Large number of individuals making payment into the same account without an
adequate explanation.
ƒ High velocity of funds through an account, i.e. low beginning and ending daily
balances, which do not reflect the large volume of dollars flowing through an
account.
ƒ An account opened in the name of a money-changer that receives structured deposits
(e.g. constant amount of deposit regularly).
ƒ An account operated in the name of an off-shore company with structured
movement of funds.

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24
ƒ Accounts that receive relevant periodical deposits and are inactive at other periods.
These accounts are then used in creating a legitimate appearing financial background
through which additional fraudulent activities may be carried out.
ƒ An account for which several persons have signature authority, yet these persons
appear to have no relation among each other (either family ties or business
relationship).
ƒ An account opened by a legal entity or an organisation that has the same address as
other legal entities or organisations but for which the same person or persons have
signature authority, when there is no apparent economic or legal reason for such an
arrangement (for example, individuals serving as company directors for multiple
companies headquartered at the same location, etc.).
ƒ An account opened in the name of a recently formed legal entity and in which a
higher than expected level of deposits are make in comparison with the income of
the founders of the entity.
ƒ An account opened in the name of a legal entity that is involved in the activities of
an association or foundation whose aims are related to the claims or demands or a
terrorist organisation.
ƒ An account opened in the name of a legal entity, a foundation or an association,
which may be linked to a terrorist organisation and that shows movements of funds
above the expected level of income.

3- International Banking / Trade Finance


U

ƒ Customer introduced by an overseas branch, affiliate or other bank based locations


of specific concern (for example, countries where production of drugs or drug
trafficking may be prevalent, countries designated by national authorities, FATF's
non-cooperative countries and territories, etc.).
ƒ Use of Letter of Credit and other methods of trade finance to move money between
countries where such trade is not consistent with the customer's usual business.
ƒ Customers who make regular and large payments, including wire transactions, that
cannot be clearly identified as bona fide transactions, or receive regular and large
payments from countries which are commonly associated with the production,
processing or marketing of drugs, prescribed terrorist organizations or tax havens.
ƒ Building up of large balance, not consistent with the known turnover of the
customer's business, and subsequent transfer to account(s) held overseas.
ƒ Unexplained electronic fund transfers by customers on an in-and-out basis or
without passing, through an account.
ƒ Frequent requests for or paying in of travelers' cheques or foreign currency drafts or
other negotiable instruments to be issued or originating from overseas.
ƒ Customers sending and receiving wire transfer to/from tax haven countries,
particularly if there are no apparent business reasons for such transfers or such
transfers are not consistent with the customers' business or history.

4- Banks and Financial Institutions Employees and Agents


U

ƒ Changes in employee characteristics, e.g. lavish life styles or avoiding taking


holidays.

OPERATING MANUAL ON AML / CFT


25
ƒ Changes in employee or agent performance, e.g. the salesman selling products for
cash has a remarkable or unexpected increase in performance.
ƒ Any dealing with an agent where the identity of the ultimate beneficiary or
counterpart is undisclosed, contrary to normal procedure for the type of business
concerned.
ƒ Sudden strong performance by employees in special relationship/confidential
relationship banking services such as trust or private banking services or sudden
increase in the wealth/spending of such employees.

5- Secured and Unsecured Lending


U

ƒ Customers who repay problem loans unexpectedly.


ƒ Request to borrow against assets held by banks and financial institutions or a third
party, where the origin of the assets is not known or the assets are inconsistent with
the customer's standing.
ƒ Request by a customer for a bank and micro finance institution to provide or arrange
financial contribution to a deal which is unclear, particularly, where property is
involved.
ƒ Customers who unexpectedly repay in part or full a mortgage or other loan in a way
inconsistent with their earning capacity or asset base.

6- Wire transfer
U

ƒ Wire transfers ordered in small amounts in an apparent effort to avoid triggering


identification or reporting requirements.
ƒ Wire transfers to or for an individual where information on the originator, or the
parson on whose behalf the transaction is conducted, is not provided.
ƒ Use of multiple personal and business accounts or the accounts of non-profit
organisations or charities to collect and then funnel funds immediately or after a
short time to a small number of foreign beneficiaries.

7- Characteristic of Customer or His/Her Business Activity


U U

ƒ Funds generated by a business owned by individuals or involved by multiple


individuals of the same origin from countries of specific concern acting on behalf of
similar business types.
ƒ Shared address for individuals involved in cash transactions, particularly when the
address is also a business location and/or does not seem to correspond to the stated
occupation (for example students, unemployed, self-employed, etc.).
ƒ Stated occupation of the customer does not commensurate with the level or type of
activity (for example, a student or an unemployed individual who receives or sends
large numbers of wire transfers, or who makes daily maximum cash withdrawals at
multiple locations over a wide geographic area).
ƒ Regarding non-profit or charitable organisations, financial transaction for which
there appears to be no logical economic purpose or in which there appears to be no
link between the stated activity of the organisation and the other parties in the
transaction.

OPERATING MANUAL ON AML / CFT


26
ƒ Unexplained inconsistencies arising from the process of identifying or verifying the
customer (for example, regarding previous or current country of residence, country
of issue of the passport, countries visited according to the passport, and documents
furnished to confirm name, address and date of birth).

8- Transaction Linked to Locations of Concern


U

ƒ Deposits are followed within a short time by wire transfers of funds, particularly to
or through a location of specific concern (for example, countries designated by
national authorities, FATF non-cooperative countries and territories, etc.)
ƒ A business account through which a large number of incoming or outgoing wire
transfers take place and for which there appears to be no logical business or other
economic purpose, particularly when this activity is to, through or from locations of
specific concern.
ƒ A customer obtains a credit instrument or engages in commercial financial
transactions involving movement of funds to for from locations of specific concern
when there appears to be no logical business reasons for dealing with those
locations.

OPERATING MANUAL ON AML / CFT


27
Appendix 15

FORMAT OF SUSPICIOUS TRANSACTIONS REPORTS (STR)


U

ACLEDA Bank Plc.

Suspicious Transaction Report


9B

NATURAL PERSONS
10B

Reporting Bank:
18B

Name:
Branch:

Address:

Telephone:

Bank Reporting officer:

Name:
Designation:

Report Reference:

Contact Officer: (If different


from Reporting Officer)
Designation:
Customer's Particulars:

Name:

ID/Passport No:

Birth Date:

Nationality:

Address:

Telephone:

Occupation:

Employment Details:

Employer's Name:

Address:

Telephone:

Business Relationship(s) with Customer


4B

Bank A/C No.:

Type of A/C:

Date A/C Opened:

OPERATING MANUAL ON AML / CFT


28
A/c Balance (Dr/Cr)

As at date:

Other Business Relationship

Suspicious Transaction(s)
Amount
19BU Description of Transaction
(Dr/Cr) Date (E.g. Funds transfer, source of funds, destination, etc)

Reason(s) for Suspicion:

Other relevant Information (Including Any Actions Taken):

Copies of the following documents are attached:


Account opening form
Account Statement
Customer identification Documents
Relevant Documents Supporting the Suspicious transactions

________________________________
(Signature of reporting officer)
Date:

*Delete whichever is inappropriate

OPERATING MANUAL ON AML / CFT


29
ACLEDA Bank Plc.

Suspicious Transaction Report


1BU

COPERATIONS
12B

Reporting Bank:

Name:
Branch:

Address:

Telephone:

Bank Reporting officer:

Name:

Designation:

Report Reference:
Contact Officer: (If different
from Reporting Officer)
Designation:

Customer's Particulars:

Name:

Country of Registration:

Registration Date:

Registration No.:

Address:

Telephone:

Name of CEO

Business Relationship(s) with Customer


5B

Bank A/C No.:


Type of A/C:

Date A/C Opened:

A/c Balance (Dr/Cr)

As At date:

Other Business Relationship

Authorised Signatories' Particulars**

1- Name:

Birth Date:

OPERATING MANUAL ON AML / CFT


30
Nationality:

ID/Passport No.:

Home Address:
**The reporting officer of the bank shall provide data on other authorised signatories, if any

Suspicious Transaction(s)
Amount Description of Transaction
Date
(Dr/Cr) (E.g. Funds transfer, source of funds, destination, etc)

Reason(s) for Suspicion:

Other relevant Information (Including Any Actions Taken):

Copies of the following documents are attached:


Account opening form
Account Statement
Customer identification Documents
Relevant Documents Supporting the Suspicious transactions

________________________________
(Signature of reporting officer)
Date:

*Delete whichever is inappropriate

OPERATING MANUAL ON AML / CFT


31
ACLEDA Bank Plc.
13B

Suspicious Transaction Report


17BU

PARTNERSHIPS / SOLE PROPRIETORS / FOUNDATION


14B

Reporting Bank:

Name:

Branch:

Address:

Telephone:

Bank Reporting officer:

Name:

Designation:

Report Reference:
Contact Officer: (If different
from Reporting Officer)
Designation:

Customer's Particulars:

Name:

Country of Registration:

Registration Date:

Registration No.:

Address:

Telephone:
Name of Partnerships / Sole
proprietors / Trustees or
equivalent:
Business Relationship(s) with Customer
6B

Bank A/c No.:

Type of A/c:

Date of A/c Opened:

A/c Balance (Dr/Cr)

As At date:

Other Business Relationship

*Delete whichever is inappropriate

OPERATING MANUAL ON AML / CFT


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Authorised Signatories' Particulars**

1- Name:

Birth Date:

Nationality:

ID/Passport No.:

Home Address:

Occupation:
Employer's Name:
(If applicable)
Address:
**The reporting officer of the bank shall provide data on other authorised signatories, if any

Suspicious Transaction(s)
Amount Description of Transaction
(Dr/Cr) Date (E.g. Funds transfer, source of funds, destination, etc)

Reason(s) for Suspicion:

Other relevant Information (Including Any Actions Taken):

*Delete whichever is inappropriate

Copies of the following documents are attached:


Account opening form
Account Statement
Customer identification Documents
Relevant Documents Supporting the Suspicious transactions

________________________________
(Signature of reporting officer)
Date:

OPERATING MANUAL ON AML / CFT


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