AML/CFT – a preventive vigilance tool

KYC [Know your Customer] / AML [Anti-Money Laundering / CFG [Combating of Financing of Terrorism was introduced in DOP vide SB Order 08/2010 dated 23.04.2010 followed by a Master  Circular No.1 vide SB Order 14/2012 dated 09.10.2012.

All these instructions are now superseded by SB Order 12/2023 dated 25.05.2023 & its Corrigendum dated 29.05.2023 [Master Circular No.2] in consequent of implementation of GSPR 2018 & NSSR 2019 and in the backdrop of CBS.

The objective of KYC/AML/CFT guidelines is to prevent money laundering or terrorist financing activities by use of Post Office Savings Bank intentionally or unintentionally by criminal elements. KYC procedures also enable to post office Savings Banks to know/understand their customers better which in turn help them manage their risks prudently.

Under PMLA provisions, Post Office Savings Bank declares its KYC Policy on the following four elements:
(a) Customer Acceptance Policy.
(b) Risk Management
(c) Customer Identification Procedure.
(d) Monitoring of Transactions; Record keeping and Reporting

(a) Customer Acceptance Policy.
1. No account is opened in anonymous or fictitious name/benami 
2. Not to open an account or close an existing account where the Post Office Savings Bank is unable to apply appropriate Customer Due Diligence measures i.e., unable to verify the identity and/or obtain documents required as prescribed due to non- cooperation of the customer or non-reliability of data/information furnished by the customer.
3. However, the customer should not be harassed and any decision to close the account should be taken by head of the Postal Division by giving suitable notice to the customer.

(b) Risk Management
All customers according to the amount involved at the time of opening of account or purchase of Savings Certificates or credit into an existing account have been categorized with the perspective of risk involved.
Low Risk : Where the customer opens account or applies for purchase of certificates or applies for credit of maturity/prematurity value of any existing savings instrument with an amount up to ₹ 50,000/- and balance in all accounts and savings certificates does not exceed ₹ 50,000/-.
Medium Risk : Where the customer opens account or applies for purchase of certificates or applies for credit of maturity/prematurity value of any existing savings instrument with an amount exceeding ₹ 50,000/- but up to ₹ 10 lakh and balance in all accounts and savings certificates does not exceed ₹ 10 lakh.
(b) Risk Management…… continued
High Risk : Where the customer opens account or applies for purchase of certificates or applies for credit of maturity/prematurity value of any existing savings instrument with an amount exceeding ₹ 10 lakh and balance in all accounts and certificates exceeds ₹ 10 lakh.
Note : The accounts related to Politically Exposed Persons (PEPs) residing outside India shall fall under High Risk Category.
Definition of PEP : Politically Exposed Persons (PEPs) are individuals have been entrusted with prominent public functions by a foreign country, including the Heads of States/Governments, senior politicians, senior government or judicial or military officers, senior executives of state-owned corporations and important political party persons.
(c) Customer Identification Procedure.
CDD/KYC to be followed for all risk categories
Photograph : Two (three in case of BO) recent Passport Size Photographs are to be given. In
case of Joint Account, photograph of all joint holders should be given.
Identification Proof: (1) Aadhaar Number or Aadhaar Enrollment Number [Aadhaar number
to be furnished within a period of six months from the date of opening]
(2) PAN or Form 60 [if PAN is not submitted, it should be submitted within a period of two
months from the date of happening of any of the following events whichever is the earliest.
➢ the balance at any point of time in the account exceeds fifty thousand rupees (or)
➢ the aggregate of all credits in the account in any financial year exceeds one lakh Rupees (or)
➢ the aggregate of all withdrawals and transfers in a month from the account exceeds ten thousand rupees

(c) Customer Identification Procedure Continued…2
In the event of the failure of the depositor to submit the Permanent Account Number within the specified
period of two months, the account shall cease to be operational till the time depositor submits the
Permanent Account Number at the post office where the account exists.
Address Proof 1. Aadhaar or 2. PAN
If Aadhaar or PAN does not contain the present address, any of the following OVD (Officially
Valid Documents)
❖ Passport
❖ Driving License
❖ Voter’s Identity Card issue by ECI
❖ Job Card issued under MGNREGS Act by State Govt.
❖ Letter issued by National Population Register containing details of name and address18-10-2024 10
(c) Customer Identification Procedure Continued…3
If Officially Valid Documents did not have the updated address, then
❖ Utility bill which is not more than two months old of any service provider (electricity,
telephone, post-paid mobile phone, piped gas, water bill);
❖ Property or Municipal Tax Receipt.
❖ Pension or family pension payment orders issued to retired employees by Government
Departments or Public Sector Undertakings.
❖ Letter of allotment of accommodation from employer issued by the State Government
or Central Government Departments, statutory or regulatory bodies, public sector
undertakings, scheduled commercial banks, financial institutions and listed companies.18-10-2024 11
(c) Customer Identification Procedure Continued…4
Attestation of Photocopy of documents
✓ Documents should be self-attested or in case of illiterate depositors, documents
should be attested by Gazetted Officer/Sarpanch/ Branch /Sub/ Deputy
/Assistant/Head/Chief Postmaster(s)or Postman/ABPM/DS.
✓ In case of investment through agent, the agent shall also affix his signatures and
mention the particulars of his agency [agency number & date of validity] on
these documents in addition to those of the depositor.18-10-2024 12
(c) Customer Identification Procedure Continued…5
OTHER INSTRUCTIONS
1. In case of Joint Account, ID and Address proof of all joint depositors are required.
2. In case of Basic Savings Account, the document proving that the depositor is beneficiary of any Govt. Scheme
is mandatory.
3. Proof of age of minor in case of account opened by a minor or on behalf of a minor and Birth Certificate of
the Girl Child in case of opening of Sukanya Samriddhi Account is mandatory.
4. A certificate from Superintendent of mental hospital where a person of unsound mind is confined or treated,
as the case may be, in case the account is opened on behalf of the person of unsound mind.
5. In case of an account opened on behalf of a minor or a person of unsound mind the KYC documents of the
guardian shall be furnished.18-10-2024 13
(c) Customer Identification Procedure Continued…6
For High Risk Categories
In addition to the documents mentioned in the previous slides, source of fund is mandatory.
PROOF OF SOURCE OF FUND
The customer has to submit copy of document showing source of receipt of funds tendered
for investment. Any of the following documents may be obtained as Proof of Source of Fund.
(i) Bank / Post Office Account Statement (which reflects the source / receipt of fund)
(ii) Any one of the Income Tax Returns filed during the last three financial years (which corelates the investment with the gross income)
(iii) Sale deed / Gift deed / Will / Letter of Administration / Succession Certificate
(iv) Any other document which reflects the income / source of fund.18-10-2024 14


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