Conducting Customer Due Diligence in AML
Conducting Customer Due Diligence in AML: Every reporting entity shall conduct CDD in the manner as may be prescribed and in accordance with provisions of this Act in the following matters, namely:-
(a) entering into a business relationship;
(b) conducting an occasional transaction above the prescribed threshold;
(c) where there is a suspicion of money laundering or terrorist financing; or
(d) where there are doubts about the veracity or adequacy of previously obtained data.
(2) Every reporting entity shall—
(a) identify the customer and verify the customer’s identity on the basis of documents, data or information obtained from reliable and independent sources;
(b) identify the beneficial owner and take reasonable measures to verify the beneficial owner’s identity on the basis of documents, data or information obtained from reliable sources and be satisfied that it knows who the beneficial owner is;
(c) understand and, as appropriate, obtain information on the purpose and intended nature of the business relationship; and
(d) monitor the business relationship on an ongoing basis.
7B. Reliance on third parties.18— A reporting entity may rely on third party to perform CDD in the manner as may be prescribed.
7C. Record keeping. 19— Every reporting entity shall maintain a record of all transactions for a period of at least five years following the completion of the transaction, and records of account files, business correspondence, documents, of all records obtained through CDD and the results of any analysis undertaken for a period of at least five years following the termination of the business relationship.
7D. Inability to complete CDD and tipping off.20— (1) Where a reporting entity is unable to complete CDD requirements, it—
(a) shall not open the account, commence business relations or perform the transaction; or shall terminate the business relationship if any ; and
(b) shall promptly consider filing a Suspicious Transaction Report in relation to the customer.
(2) Where a reporting entity forms a suspicion of money laundering or terrorist financing, and reasonably believes that performing the CDD process will tip-off the customer, the reporting entity shall not pursue the CDD process and shall file a STR.
7E. Anonymous business relationships and transactions.— No reporting entity shall enter into a business relationship or conduct any
transaction with a customer who is anonymous or provides a fictitious name.
7F. Risk understanding.— Every reporting entity shall take appropriate steps to identify, assess and understand the risks to which its
business is subjected to, in accordance with this Act and as prescribed.
7G. Compliance program.— Every reporting entity shall implement compliance management arrangements, including the appointment of a compliance officer at a management level and training programs, having regard to the money laundering and terrorism financing risks and the size of the business during the course of their activities subject to this Act and as prescribed.
7H. Policies and procedures.24— Every reporting entity shall implement policies and procedures to ensure their compliance with the provisions of this Act and orders, rules or regulations made thereunder that impose TFS obligations upon reporting entities.
7I. Sanctions for reporting entities.25– If any reporting entity or natural person contravenes any of the provisions of sections 7(1), 7(3) to 7(6) and 7A to 7H, it may be subjected to sanctions, as mentioned under clause (h) of section 6A of this Act and as may be prescribed.
Anti Money Laundering Training
Anti Money Laundering Training / Financial Crime training is available in Lahore, Islamabad, Karachi Pakistan as “online live training” or “onsite live training”.