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Description

CDD Quality Checking for New High and Medium Risk Accounts

• Review KYC/CIF and challenge the input details of KYC/CIF Profiling on a Risk based Approach for all new high-risk accounts (100% population) and medium risk account openings (on sample basis of approx. 20%-40% of the total account openings on weekly basis) and follow up with branches for timely rectifications thereby ensuring strong KYC quality at the onset.

Branch / Area / Region Visits

Following as assigned by RMC:

• Subject to geography, on-site Branch visits every month to identify branch-level activity deficiencies in policy/process/product adherence that may expose Bank to Compliance/Regulatory Risk. Completed ‘Checklists’ for each Branch visit to be sent to HOK on a Fortnightly Basis, with follow-up update till rectification based upon Resolution Target Date. Re-validate as necessary.
• Review sample high and medium Risk periodic accounts to identify gaps & follow-up with first line of defense (Sample size 10% accounts on random basis).
• Review sample Top 100 depositors accounts in branches in light of guidelines by the regulator and Bank’s own relevant Circular(s) to ensure timely rectification of gaps by the branches. (sample size 15% accounts on random basis covering maximum number of branches in region).
• Review to identify & report gaps pertaining to performance and AML-CFT skillset of branch staff during on-site reviews along with recommendations of any requisite training.
• Based on assignment, assist RMC to review, identify & report any out of pattern trends in Foreign Direct Investments (Short & Long Term) Transactions & follow-up with first line of defense for resolution within the region.
• Re-validate documentation related observation for those branches which are revisited. Reporting to be done on Annexure 1 (Annexure – 1 Branch Compliance Review Checklist). Further reporting to RMC on a fortnightly basis.

Reviews of KYC / CDD Profile Changes

• Manage reviews of changes in KYC profile for all high and medium risk customers in their respective regions on a risk based approach, in cases where the changes are not applied during the normal course of a cyclical periodic review, to identify & report suspicious activity/pattern/transaction(s). Where needed, seek justifications for change(s) from Branch Manager/Area Manager.
• Checks for CDD changes made during normal course of a cyclical periodic review to ensure that Branch updates are conducted in the spirit of periodic reviews requirement.

Compliance Awareness & Trainings

(Trainings based upon inclusion as part of AML/CFT Training)

• Create necessary awareness to strengthen the Compliance culture within the region. Provide necessary support to RMC/SRMC to ensure that all necessary classroom trainings (as communicated by L&D) are periodically conducted for branch staff thereby building AML/CFT/CDD awareness. (Only applicable to CO selected by L&D).

Others

• Assist RMC in management of Compliance Risk Activities for the regions. Provide timely feedback on issues/queries raised by RMC or SRMC.
• Perform advisory role to the branches regarding Compliance matters
• Assist RMC/SRMC in executing any Compliance-related and administrative activities as assigned from time-to-time by Head CPD&C.