Headings

CORRESPONDENT BANKING – AML / CFT Presenter : Manoj Ahuja

What Foreign Institutions looking for while carrying out due diligence when onboarding customer prospect for Correspondence Banking? Beneficial Ownership and its structure Exposure as Correspondent Bank / Institutions Sharing of Information outside Standard Questionnaire AML /CFT Risk Appetite Geographical Exposure of Fis % SCC (Sensitive Customers Category) Tolerance level on Sanctions Regime Coverage of Sanctions Regime

What Foreign Institutions looking for while carrying out due diligence when onboarding customer prospect for Correspondence Banking? Continue .. Results of Transactions Testing for the maintenance of Relationship External Searches, Negative Media News / Regulatory Penalties Use Of FI Ratings, wherever available. E.g SIGMA ratings

Strengthening of Payment Transparency Controls Transaction Monitoring of Respondent Accounts Anomalies in behavior (sudden / significant) Hidden relationship (link analysis); monitoring activity between customers incl. respondents and their underlying customers and identifying common beneficiary’s and remitters amongst apparently unconnected accounts / respondents. High Risk Geographies and Entities; Significant increase in activities and / or with high risk geographies Structuring of Transactions Different Thresholds on transaction type for e.g POP Independent testing of data accuracy and completeness of Wire payments Encourage culture of raising Unusual Activity Reports (UAR’s) by all employees Coverage of other Countries Sanctions Regime in Sanctions screening.