ICAI Indore

Dt.24.01.2014
Legal and Regulatory Aspects
Contents
Banking Law & Practice
Banking Regulation Act
Banking Laws (Amendment) Act, 2012
Types of charges over securities ( Transfer of Property Act,
Indian Contract Act, SARFAESI)
Credit Information Companies (Regulation) Act, 2005
Negotiable Instruments Act
Anti Money Laundering & Know Your Customer
- Key Aspects and elements of AML KYC
Banking Law and Practice
Several enactments
- Banking Regulation Act, 1949
- Reserve Bank of India Act, 1934
- Banking Companies (Acquisition and Transfer of Undertakings) Act,1970 & 1980
- SBI Act, 1955 & SBI (Subsidiary Banks) Act, 1959
- RRB Act, 1976
- Companies Act, 1956
- Negotiable Instruments Act, 1881
- Prevention of Money Laundering Act, 2002
- Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002
- Credit Information Companies Act
- Recovery of Debts due to Banks
- Transfer of Property Act

Regulations

Widely accepted practices
Banking Regulation Act, 1949
Banking Regulation Act, 1949
Definition of banking & banking company

Licensing

Permitted business

Prohibited business

RBIs powers

Control over management
Definitions
Banking means
accepting, for the purpose of lending or investment, of deposits of money from the
public, repayable on demand or otherwise, and withdrawal by cheque, draft, order or
otherwise
{Section 5(b)}

Banking company
means any company which transacts the business of banking in India
- Explanation excludes manufacturing and trading company
{Section 5 (c)}

Use of the word bank, banker, banking or banking company - Section 7
Permitted business
Can carry on business permitted u/s 6
- Borrowing, lending, bill discounting, etc.
Buying, selling and dealing in bullion
Buying and selling of foreign exchange
Travellers cheques
Letters of credit
Underwriting and dealing in shares, debentures, etc.
Safe deposit
Collecting and transmitting of money and securities
Undertaking/ executing trusts
- Activities that are incidental/ conducive to the promotion/ advancement of its business
- Central Govt. empowered to notify permitted business

Act overrides memorandum, articles, etc.
Prohibited business
Trading prohibited vide Sec 6

Non-banking assets Sec 9
- Immoveable property can only be held for own use
- Other disposed within 7 years
RBI can give additional 5 year extension

Restriction on nature of subsidiary companies Sec 19
- Permitted business u/s 6
- Carrying on banking outside India
- Credit information business
- Other business with RBI and CG approval

Licensing
RBI empowered to issue & cancel licences
- Section 22 criteria
Solvency
Affairs/ management not detrimental to depositor and public interest
Adequate capital structure and capital prospects
Public interest will be served
Grant of licence not prejudicial to operation and consolidation of banking system
Foreign banks home country does not discriminate against Indian banks
Other conditions specified by RBI

- New bank licencing requirements
Branch licencing u/s 23
Returns
Section 24
- Monthly return of assets in India
- DTL on reporting Friday
Section 25
- Quarterly return of assets and liabilities at the close of business on the last Friday of every
quarter
Section 27
- Monthly return on Asset & Liability position as on last Friday
- RBI empowered to direct banks to furnish information within a specified time frame
- RRBs also need to submit a copy to NABARD
Section 26
- Return of unclaimed deposits
Section 31
- Three copies of annual returns to be submitted to RBI
Inspection
Section 35
- Inspect books
Also on direction of CG
Copy of report to be given to bank
Empowers RBI Inspecting officer to examine bank officials under
oath
- Also empowers RBI to carry out a scrutiny


Powers of RBI
Sec 35A Power to give directions
Sec 35B Prior RBI approval required for
appointment of Chairman, MD, CEO or director
Sec 36 Further powers and functions of RBI
- Caution/ give advice regarding certain transaction/ class
of transactions
- Call for meeting of directors, depute its officer to board
meeting, appoint observer, etc
- Report on Trend and Progress in Banking in the country

Powers of RBI Control over
management
Sec 36AA Power to remove managerial and
other persons from office
- Appeal lies with Central Government
Sec 35B Power to appoint additional directors
Other important provisions
Sec 14 Prohibition of charge on unpaid capital
Sec 15 Prohibition on payment of dividend
unless intangible assets written off
Sec 17 Creation of reserve fund
Sec 18 Maintenance of cash reserve ratio
Sec 20 Restrictions on loans and advances
Sec 24 SLR

Applicability of BR Act
Nationalised Banks
- Banking Companies (Acquisition and Transfer of Undertakings) Act,1970/1980;
- Section 51 of BR Act makes specific sections applicable

Regional Rural Banks
- Regional Rural Banks Act, 1976
- Section 51 of the BR Act

Cooperative Banks
- Cooperative Societies Act. 1912 or the respective Co-operative Socieities Act of the
state concerned
- Part V of the B R Act BR (AACS) Act
Some important RBI instructions in
context of BR Act
Master Circular
- Loans & Advances Statutory and other restrictions
- Branch authorisation
- Cash Reserve Ratio and Statutory Reserve Ratio

Others
- Restriction on drawdown of reserves
- Guidelines on declaration of dividend
Banking Laws (Amendment) Act
Passed by Parliament in Dec 2012
Some highlights
- Voting rights
26% from existing 10% in private sector banks
10% from existing 1% in public sector banks
- Prior approval for voting rights/ shareholding more than 5%
- Power to RBI to supersede entire board of banks
- Power to call for information from associate and group companies
- Depositor Education and Awareness Fund
- Primary cooperative societies to be licenced by RBI
- Preference shares
- Naionalised banks can issue bonus shares
- Joint inspections of associates with sectoral regulator
Laws relating to securities and
modes of charging
Transfer of Property Act, 1882
Indian Contract Act, 1872
SARFAESI
Overview of charges
Creation of a right in favour of the creditors

Nature of security Types of security Kind of Charge Defined in Act
Immoveable property Land and building Mortgaage Sec 58, Transfer of Property
Act
Actionable claims
(i.e. unsecured
debts)
Book debts, term deposit
receipts, etc.
Assignment Sec 130, Transfer of Property
Act
Moveable property/
goods
Plant & machinery, stocks,
vehicles, etc.
Pledge/
hypothecation/ lien
Pledge-Sec 172 Indian
Contract Act
Hypothecation Sec 2(n)
SARFAESI
Paper securities Shares, debentures, MF,
bonds
Lien Sec 170 and 171Indian
Contract Act
Personal guarantee Promoters & 3
rd
party
guarantees
Personal liability Sec 126 Indian Contract Act
Kinds of charges Fixed v/s Floating
Fixed charge
- created on properties such as land and buildings, plant and machinery
- Identity does not change
- Credit consent required for disposal
- Debtor retains ownership and possession

Floating charge
- Created on assets that undergo change
- Security allowed to be used in ordinary course of business unless charge
crystallises
Kinds of charges
Pari Passu charge
- Several creditors- typically in consortium accounts
- Equal priority

Exclusive charge
- To one creditor
- No intervention of other creditors

First charge
- First right over the proceeds from the security charged

Second charge
- Rights subject to those of first charge holder
Mortgage
Dealt with in Transfer of Property Act, 1882
- A mortgage is the transfer of interest in specific immoveable property, for the
purpose of securing the payment of money advanced or to be advanced by
way of loan, on existing or future debt or the performance of an engagement which
may give rise to pecuniary liability- Section 58
Types
- Simple
- Conditional sale
- Unsufructuary mortgage
- English mortgage
- Equitable Mortgage
- Anomoalous morgage
Simple Mortgage
Without delivering possession of the mortgaged property, the mortgager binds himself
personally to pay the mortgage money and agrees, expressly or impliedly, that in the
event of his failing to pay according to his contract, the mortgagee shall have a right to
cause the mortgaged property to be sold by a decree of the court in a suit and the
proceeds of the sale to be applied so far as may be necessary in payment of the
mortgage money [Sec 58(b)]
Intervention of court required
Mortgagee has no right to get any payments out of the
rents and produce of the mortgaged property
Mortgagee not put in possession of the property
Registration is mandatory
Conditional Sale
The mortgager ostensibly sells the mortgaged property on the condition that:
(a) on default of payment of the mortgage money on a certain date, the sale
shall become absolute, or
(b) on such payment being made the sale shall become void, or
(c) On such payment being made, the buyer shall transfer the property to the
seller [Sec 58(c)]
Sale is ostensible not real
If money not paid ostensible sale shall become
absolute Court decree required
No personal liability for repayment of the loan

Unsufructuary mortgage
mortgage transaction in which
(a) the mortgager delivers possession expressly, or by implication binds himself to deliver possession
of the mortgaged property to the mortgagee, and
(b) Authorises the mortgagee to retain such possession until payment of the mortgage money and to
receive the rents and profits accruing from the property or any part of such rents and profits and to
appropriate the same in lieu of interest, or in payment of the mortgage money, or partly in lieu of
interest and partly in payment of the mortgage money [Sec 58(d)]
Mortgagee in actual legal possession of the property, till dues are repaid
Mortgage has the right to receive rents and profits accruing from the
property
No personal liability of the mortgager
No time limit specified

English mortgage
mortgagee binds himself to repay the mortgaged property absolutely to the
mortgagee, but subject to the provision that he will retransfer it to the
mortgagee upon payment of the mortgage money as agreed [Sec 58(e)]
Personal covenant to pay on a specified date
notwithstanding the absolute transfer of property to
the mortgagee
Absolute transfer
- Subject to reconveyance in event of repayment
Court decree for sale

Equitable mortgage
where a person delivers to a creditor or his agent documents of title to
immoveable property, with the intent to create a security thereon, the
transaction is called a mortgage by deposit of title deeds [Sec 58(f)]

Deposit of title deed with intention to secure debt
- Original deed not required but recommended
- Saves on stamp duty
Deposit at notified places only
- Independent of location of the property

Anomalous mortgage
a mortgage which is not a simple mortgage, a mortgage by conditional
sale and Unsufructuary mortgage and English mortgage or a mortgage by
deposit of title deeds within the meaning of this section [Sec 58(g)]

Should satisfy the basic definition of mortgage
Should not fall in the earlier categories
Usually a combination of two mortgages
Mortgages- Other key aspects
Registration requirements
- Registration required for mortgages other than equitable mortgage Sec
59
- Indian Registration Act- Sec 23 - required within 4 months of execution
- Companies Act, 1956-Sec 125- within 30 days of execution

Priority of mortgages
- First in point of time has better title Sec 48
- Amongst registered instruments- date of execution
- Registered has priority over unregistered
Exception is deposit of title deeds
Mortgages-Other key aspects
Enforcement
- Code of Civil procedure
- Jurisdiction based on location of property
- Preliminary decree
- Final decree
- Sale




Which Mortgage would you
prefer?
Mortgage Personal Liability Possession
Simple Mortgage
Conditional Sale
Unsufructuary Mortgage
English Mortgage
Equitable Mortgage
(Court decisions)

(Deposit of title deeds)
Assignment
Transfer of actionable claim
- Claim to debt other than debt
secured by mortgage of immoveable property
Hypothecation/ pledge of moveable property not in possession
Key features
- Should be in writing
- Due notice to be given to the debtor
- Assignor cannot give better title
- Eg LIC policies used as security
Pledge
Pledge is the bailment (delivery) of goods as security for payment of a debt or performance of a
promise (u/s 172 of Indian Contracts Act)
Key aspects
- Delivery of goods
Need not be physical delivery
May be constructive delivery eg handing over keys of godown
Can only be on existing goods- not on future goods
- Pawnor borrower who gives the goods as security
- Pawnee- lender who takes the goods as security
- Ownership retained with pawnor
- Possession with pawnee
Possession may be parted with against Trust Receipt
Right to retain or sell goods where pawnor makes default in payment
Notice to sell required to be given
Right of pledge prevails over any other dues including Government dues except workers wages
Hypothecation
Defined in SARFAESI, 2002 (Sec 2(n))
- Charge upon moveable property
- Existing/ future
- Without delivery possession with borrower

Drawbacks
- Risk of fraud- multiple charges on same property
- Erosion of security value

Precautions
- Periodic stock statements
- Registration of charge
- Notice of charge
- Insurance of property
Lien
General Lien
- Creditors right to retain property of debtor
- Possession in ordinary course of business
- Limited to possession of property not to sell

Bankers lien
- General lien+ right to sell
- Applicable to negotiable instruments and credit balances
- Not applicable to safe deposit, for sale
Other aspects relating to
Contracts
Proposal and acceptance
Consideration
- Exemption
Free consent
Capacity to contract
- Sound mind
- Not disqualified from entering into a contract
- Minor contract

Stamping of documents
Stamp duty tax levied on documents
- Originated in Netherlands 1624
- France (1654), Denmark (1657), Prussia (1682)
Key aspects
- Amount of duty
- Type of stamp used
- Cancellation of stamp
- Time of stamping and execution
- Place of stamping and execution
Consequences
- Admissibility as evidence
- Adjudication
Law of limitation
Period within which suit can be filed
- Bars to remedies
- Original right may continue to be exercisable
Right of action revived by
- Fresh set of documents
- Acknowledgement of debt
Writing, signed, stamped and addressed to lender
- Part payment authorised by the borrower
Power of Attorney
Types
- General v/s special
Registration of power of attorney
Precautions
- Scope of powers
- Agent acting within the scope of powers
- Confirmation of validity
SARFAESI Act, 2002
Securitisation and Reconstruction of Financial
Assets and Enforcement of Security Interest Act,
2002
- Coverage
- Securitisation and reconstruction of financial assets
- Enforcement of security interest without court
intervention
- Central Registry

SARFAESI - Coverage
Effective since June 21, 2002
- Retrospective coverage
- Applicable to whole of India including J&K
- Also covers notified Housing Finance Companies
- Sec 31
Lien and pledge
Aircrafts, shipping vessels
Conditional sale, hire purchase, contract where no security interest created
Financial asset<=Rs.1 lakh
Agricultural land
Amount due<20% of the Principal +Interest
- Mardia Chemicals case Supreme Court
Sec 17(2) unconstitutional- arbitrary, oppressive and unreasonable
Subsequent amendment
SARFAESI Securitisation/
Reconstruction Companies
Registration with RBI
- Guidelines issued by DNBS
- Minimum owned fund of Rs100 crore/ 15% of financial assets
to be acquired whichever is lower

Acquisition of financial assets
- Scheme wise
- Funded by investors QIBs
- Issuance of Security Receipts
- Managed by trust

SARFAESI Enforcement of security
interest
No need for court intervention
- Overriding effect over provisions of Transfer of property Act
- Notice mandatory
60 days notice
Details of amount payable and secured asset intended to be enforced
Borrower prohibited from transferring assets
- SC Guidelines in Mardia case
Borrower can raise objections
Bank to apply mind while answering objections
Response to borrower within one week
Rejection of objections cannot be appealed to DRT
- Can appeal to DRT deposit of 50% of the amount due
Can seek help of District Magistrate/ Chief Metropolitan Magistrate

SARFAESI Enforcement of security
interest
Recourse available to lender
- Possession of secured asset
- Management of secured asset
- Appoint person as manager of secured assets
- Require from any person who has acquired the secured asset from the borrower to
pay the amount due to the extent of the secured asset
Appropriation of proceeds
- Expenses->Dues->Balance to debtor
- If winding up dues of workman have pari passu charge
Consortium accounts multiple secured creditors
- Creditors representing of outstanding dues have to agree
Recent amendment- bank may purchase at auction [13(5A)]


SARFAESI Enforcement of security
interest
Safeguards
- Inventory of property taken into possession
- Take care of property as owner of ordinary prudence insure if necessary
- Expedite sale if subject to speedy decay
- Possession notice
affixation at outer door/ conspicuous place
Publication in 2 leading newspapers including one vernacular
- Auction
30 days notice publication in 2 leading newspapers incl. vernacular
Valuation to fix reserve price
- Appeal to DRT - Compensation
Within 45 days of measures being initiated
50% to be deposited- DRT may reduce to 25%






SARFAESI - CERSAI
Sec 25 Company promoted by Government & PSU banks
Maintains registry of
- Securitisation of financial assets
- Reconstruction of financial assets
- Creation of security interests
Registration additional not substitute for existing requirements
Records available for search
Minimisation of frauds due to multiple borrowing on same
security
Recovery of Debts due to Banks and
Financial Institutions Act, 1993
Coverage
- Applicable to whole of India except J&K
- Debt > Rs. 10.00 lakhs

Constituted Debt Recovery Tribunals for speedy recovery
- Established by Central Government
- Single member Presiding Officer
- Appeal against DRT order lies with DRAT
Chairperson
- Jurisdiction of civil courts (other than HC/SC) barred




Credit Information Companies
(Regulation) Act, 2005
Credit Information
Companies(Regulation) Act, 2005

Objective- regulation of credit information companies

Registration
- Compulsory registration with RBI
Existing companies to apply within 6 months
- Conditions
Minimum capital Rs. 30 crore (authorised), Rs.20 crore(issued)
Management not prejudicial to interests of users, clients or borrowers, credit information companies
Additional conditions at discretion of RBI
- RBI may determine cap on maximum number of credit information companies
- RBI may cancel registration
- Appeal lies with Central Government



RBI Powers
Registration and cancellation
Frame policy and regulations
Give directions
Inspection
Appoint observers
Supersede board appoint administrator
Specify maximum fee
Recommend exemption and rules




Management of Credit Information
Companies
Management
- Chairman (whole time)/ Managing Director
- 50% of board with specialised knowledge
Public administration, law, banking, management, finance,
accountancy and information technology
- RBI empowered to supersede board appoint
Administrator


Functions
Permitted businesses
- Collect information on trade, credit and standing of borrowers of member credit institutions
- Provide
Information to specific users, credit institutions
Credit scoring
- Research projects
- Other business specified by RBI

Membership
- Credit institutions to become members
- Compulsory to be member of at least one
- Bound to give information

Disclosure of credit information restricted


Information Privacy Principles
Accuracy and secrecy of credit information

Alteration of credit information
- Credit information to be supplied by credit institutions
- Borrower may request updation

Fine for unauthorised access
Credit Information Companies
Regulations, 2006
Specified users
- Member credit institutions (specified in Act itself)
Banks, Financial Institutions, NBFCs, credit card companies, housing finance company, state financial corporation
- Insurance companies
- Cellular phone service providers
- Rating agency
- Broker
- Trading member of recognised commodity exchange
- SEBI
- IRDA
Forms of business
Privacy principles
Maximum fee and charges
- Membership - Rs.15.00 lakh
- Providing credit information report- Rs.500 for individuals, Rs. 5,000 for other borrowers/ specified users

Principles
1. Care in collection of credit information
2. Data security and secrecy
3. Access and modification
4. Data collection limitation
5. Data use limitation
6. Data accuracy
7. Archiving and length of preservation
Credit Information Companies
Credit Information Bureau (India) Ltd,
Equifax Credit Information Services Pvt. Ltd
Experian Credit Information Co. of India Pvt. Ltd,
Highmark Credit Information Services Pvt. Ltd.
Reporting of wilful defaulters
Wilful default
- Default in meeting obligations
Despite capacity to repay
Diversion of funds
Siphoning of funds
Sale of assets
Diversion
- Short term loans used for long term purposes
- Purchasing assets other than those for which the loan was sanctioned
- Transferring to subsidiaries group companies
- Investments of funds in equity/ debti without lenders permission
- Shortfall in deployment vis--vis disbursal



Reporting of wilful defaulters
Penalties
- No additional facilities
- Legal process
- Proactive towards change of management
- Covenant- prohibiting directors from wilful defaulters

Quarterly reporting
- Suit filed
- Rs. 25 lakh and above

Monitoring end use
Negotiable Instruments Act, 1881
Negotiable Instruments Act, 1881
Brought in to
- Encourage use of negotiable instruments
- Improve credibility of negotiable instruments

Important aspects
- Definitions
- Negotiation v/s transfer by assignment
- Presumption of consideration
- Endorsement
- Payment in due course
- Holder in due course

Definitions Negotiable Instrument
What is a negotiable instrument (Sec 13)
- Promissory note (Sec 4)
Unconditional signed undertaking to pay a certain sum of money
- Bill of exchange (Sec 5)
Unconditional signed order by maker
Directing a certain person to pay a certain sum of money
To a certain person/ bearer
- Cheque (Sec 6)
Bill of exchange
Drawn on banker
Payable on demand
Includes image of cheque
NB. All are to be in writing
Definitions - Holder
Holder (Sec 8)
- Person entitled in his own name to possession
- Entitled to receive/ recover amount due

Holder in due course (Sec 9)
- On consideration becomes
Possessor bearer instruments
Endorsee/Payee order instruments
- No cause to believe that title defective
Cheques
Cheques
- Crossing Special vs general
- Order v/s Bearer
- Protection to
Paying banker for payment in due course Sec 128
Collecting banker for receiving payment for customer in
good faith & without negligence Sec 131
Cheques payable to order subsequently endorsed - Sec 85
So what is the difference?
Crossing of Cheques
General Crossing (Sec 123)
- Two parallel transverse lines
- Payment only through banker (Sec 126)

Special Crossing (Sec 124)
- Name of the banker also mentioned
- Payment only through banker whose name is mentioned (Sec 126)

Liability to true owner continues if not paid through a bank (Sec 129)
Protection to paying and collecting
bankers
Protection to paying banker
- Sec 128 protection for payment in due course
Same rights and same position if the cheque had been paid to
and received by the true owner thereof

Protection to collecting banker
Sec 131
Good faith and without negligence
No liability if title proves defective
Payment in due course
Payment in accordance with
- Apparent tenor of the instrument
- Good faith
- Without negligence
- No reasonable ground for believing that possessor
of NI not entitled for to receive payment
Order and Bearer Cheques
Order
- Drawn payable to order
- If endorsed by/behalf of payee, drawee discharged by payment in due
course

Bearer
- Expressed payable to bearer
- Discharge by payment to bearer
Irrespective of subsequent endorsements
- Endorsement in blank
payable to bearer even if originally payable to order

Account Payee
Not provided in the NI Act
Developed as practice
RBI instructions
- January 23, 2006
- Limited exemptions to cooperative societies
- Demand drafts over Rs.20,000 (AML aspect)
Anti Money Laundering
Know Your Customer
AML & KYC
Background
- June 1998 UN call on member states to adopt
national money laundering legislation
- Prevention of Money Laundering Act, 2002

Objective
Prevent banks from being used by criminals for money
laundering and terrorist activities


Key aspects
Customer
- Account holder/ business relationship
- Beneficial owner
- Any person connected to the transaction which can cause significant reputational/
other risks to the bank/FI

General guidelines
- Confidentiality of customer information
- Remittances over Rs.50,000 only by debit to customers account/ cheque
- Tenor of instrument reduced to 3 months
- Adherence to provisions of Foreign Contribution (Regulation) Act, 2010
Elements of KYC Policy
Customer Acceptance Policy

Customer Identification Procedures

Monitoring of Transactions

Risk Management
Customer Acceptance Policy
No accounts in fictitious/ benami names
Parameters for categorising customers based on risk perception
Documentation to be collected
Not to open/ close accounts where due diligence not possible
Circumstances where agency/ fiduciary capacity allowed
Background checks
Product wise/ geography wise controls
Profile of each customer
Examples of customers requiring
higher due diligence
Non Resident customers
High Net Worth individuals
Politically exposed persons & their relatives
Companies having close family shareholding/firms
with sleeping partners
Non face to face customers
Trusts, charities, NGOs, etc receiving donations
- Exemption for NGOs promoted by UN
Customer Identification
Procedure
Policy should be specified for various stages
- Initiating the relationship
- Carrying out a financial transaction
- Doubts about veracity of data
Natural persons
- Identity of customer
- Address
- Photograph
Legal persons/ entities
- Legal status
- Authorised persons
- Ownership and control structure
Unique Customer Identification Code (UCIC)
Avoid undue hardship to customers
Customer identification requirements
Indicative Guidelines
Walk in customers
Salaried employees
Trustee accounts
Companies and firms
Accounts managed by professional intermediaries
Politically exposed persons
Non face-to-face customers
Proprietary concerns



Simplified KYC
Targeted at low income groups - urban and rural poor

Limits
- Balance not to exceed Rs.50,000
- Total credits not to exceed Rs.1,00,000

Simplified KYC procedure
- Introduction from another account holder with full KYC
- Other documents that satisfy the bank about the identity
Money Mules
Third parties act on behalf of criminals

Recruited through
- Spam emails
- Advertisements on genuine websites/ newspapers
- Social networking sites

Banks advised to strictly adhere to guidelines on KYC/AML

Monitoring of transactions
Understanding of normal and reasonable pattern of
activity
Monitoring dependent upon the risk classification of
the account
Special attention to large and complex transactions
Threshold limits
Cash transactions

Risk Management
Board to ensure effective KYC,AML system in
place
Role of audit and compliance mechanisms
Quarterly review before Board
Cash Transaction Report
Suspicious Transaction Report
Screening & training of employees
Thank you