agha hamidi
TRANSCRIPT
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PRESENTED BY:
SAJJAD HAMIDI
CUSTOMER IDENTIFICATION
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5. Customer Identification
(Key Issues for Supervisors)
National supervisors should develop:
customer identification program
guidelines and best practices reflecting the
various types of transactions that are most
prevalent in the national banking system.
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5. Customer Identification
(Process of Customer Identification)
i. Collecting the identification information
ii. Screening the customer
iii. Assessing the customer’s risk profile
(if general due diligence is believed to be enough) Reconfirming the identification information
(if enhanced due diligence is believed to be required )
iv. Obtaining additional information
v. Reconfirming the identification information
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5. Customer Identification
(Natural Persons)
Identification Information Legal name and any other names used (such as maiden name)
Correct permanent address (the full address should be obtained: aPost Office box number is not sufficient)
Telephone number, fax number, and e-mail address
Date and place of birth
Nationality
Occupation, public position held and/or name of employer An official personal identification number or other unique identifier
contained in an unexpired official documents that bears a photograph
of the customer
Type of account and nature of the banking relationship
Signature (source: General Guide to Account Opening and Customer Identification, BCBS)
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5. Customer Identification
(Natural Persons)
Screening customers
new customer applications existing customer base
against lists of known or suspected money
launderers/terrorists
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5. Customer Identification
(Natural Persons)
Obtaining Additional Identification Documents If the financial institution believes that enhanced due diligence
is required after the initial assessment of the customer’s riskprofile, it should obtain additional information, such as: – Evidence of an individual’s permanent address sought through a
credit reference agency search or through independent verificationby home visits
– Personal reference (i.e. by an existing customer of the sameinstitution)
– Prior bank reference and contact with the bank regarding thecustomer
– Source of wealth – Verification of employment, public position held (where
appropriate)
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5. Customer Identification
(Natural Persons)
Reconfirming the Identification Confirming the date of birth from an official document (birth
certificate, passport, identity card, social security records)
Confirming the permanent address – Utility bill, tax assessment, bank statement, a letter from a public authority
Contacting the customer by telephone or by letter to confirm the
information supplied after an account has been opened – A disconnected phone or returned mail should warrant further investigation
Confirming the validity of the official documentation provided
through certification by an authorized person – Embassy official, notary public
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5. Customer Identification
(Legal Persons/Arrangements)
Legal Elements of the Customer Identification
1. Verify that any person acting on behalf of the legal
person/arrangement is so authorized.
2. Identify any person acting on behalf of the legal
persons/arrangements.
– Verification of the identity of directors/signatories
– Directors: A directors exercises control over the business and thusover funds passing through the account
– Signatories: A signatory to an account is able to exercise control or
authority over funds passing through the account
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5. Customer Identification
(Legal Persons or Arrangements)
Legal Elements of the Customer Identification
3. Identify the legal person/arrangement
– Verification of the lawful existence of the company
– Verification of the license if it is required in operating such
business
– Is the legal person/arrangement regulated?
– Is the legal person/arrangement required to observe AML/CFTcontrols?
– Verification of the type of legal form and business purposes
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5. Customer Identification
(Legal Persons/Arrangements)
Business Elements of the Customer Identification
1. Annual audited accounts, copies of business plan.
2. Location of the headquarter, branches, plants, warehouses,overseas offices.
3. Major customers/suppliers.
4. Other financial institutions the legal person/arrangement hasbusiness relationships.
5. Likely level of account activity and format (cash, checks,wires)
It is important to obtain sufficient documentation to prove or establish that the business exist.
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5. Customer Identification
(Legal Persons/Arrangements)
Company C
Company A
Company B
Company D Mr. WMr. V
Ms. UMr. T
Mr. X Mr. Y Ms. Z
Company E
Company F
Mr. S
Ownership/Identification
Company A requested a
new account. Which entities
should be identified?
Bearer Shares?
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Thank You