agha hamidi

7/31/2019 agha hamidi

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PRESENTED BY:

SAJJAD HAMIDI

CUSTOMER IDENTIFICATION



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.




(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




(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)




(Natural Persons)

Screening customers

new customer applications existing customer base

against lists of known or suspected money

launderers/terrorists




(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)




(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




(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




(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





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.





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?



Thank You