1.

Structural Organogram of the Anti-Money Laundering Division (as per policy) of EXIM Bank

Abbreviation:
MD = Managing Director
CEO = Chief Executive Offtcer
CAMLCO = Chief Anti-Money Laundering Compliance Officer
DMD = Deputy Managing Director
DCAMLCO = Deputy Chief Anti-Money Laundering
Compliance Officer
SEVP = Senior Executive Vice President
SAVP = Senior Assistant Vice President
AVP = Assistant Vice President
SPO = Senior Principal Officer
PO = PrincipalOfficer
EO = Executive Officer

'!

2. Functional Organogram of the Anti-Money Laundering Division of EXIM Bank.

Deputy Chief Anti Money Laundering Compliance Officer (DCAMLCO)

Conduct inspection as per

requirement of the Central
Compliance Unit (CCU)

+
Investigation of Suspicious
Transaction Report (STR)
forwarded from Branches

Collection of report from the

branches on monthly, bimonthly and quarterly basis

Collection of replies regarding

enquiries of regulators within
the stipulated time

Compilation of report of the

branches for onward submission
to Bangladesh Bank

Preparation of schedule for

training/norkshop
throughout the wfiole year

Collecting Cash
Transaction Report (CTR)
from the Branches
I

Anangement of training for

the officials of the Bank at
EXIM Bank Training &
Research Academy or
regional basis

Scrutinizing the Cash Transaction

Report reported by the branches for
submission to Bangladesh Bank

+
Invitation of guest
lecfurerc from
Bangladesh Bank

Placing

he

report of STR

before top management

for perusal and decision

Review the compliance report of

Branch inspection conducting by
ICCD (lndependent Testing
Procedures)

Anangement of Central
Compliance Unit (CCU)
meeting on monthly basis

3. General lnformation:
3.1

The Head of Anti-Money Laundering Division (Deputy CAMLCO) reports it's all activities to Deputy
Managing Director & CAMLCO, which has subsequently been informed to the Managing Director &

cEo.
3.2

The AML Policy of EXIM Bank has been approved by the Board of Directors and the same is being
updated as and when required and in-case of any changes / modification brought by the regulators.

3.3

The AML issues of EXIM Bank are escalated as per flowchart:

Branch Report
Anti-Money Laundering Division
Central Compliance Unit (CCU)
Managing
Director and CEO
The Board Risk Management Committee (Monthly & Quarterly basis).

3.4

Summary report of "Self Assessment" (conducted by Branch) and "lndependent Testing

Procedures" (conducted by ICCD) are being placed before Central Compliance Unit (CCU) of the
bank. The key issues/ summary of AML reports are also placed to the Board Risk Management
Committee quarterly or as and when it's meeting takes place.

3.5

Workshops/Training Programs for AMUCTF awareness are being organized on regular basis for all
Executive/Officers of the bank. The trainers (in-house, external or from Central Bank) conducV
demonstrate their workshops/training materials using multimedia presentation for effective/
successful communication among the participants of the training programs. Following issues are
considered for organizi n g a training/workshop prog ramme:-

3.5.1

SelecVnominate participants from functional areas covering from Officers to Executives.

3.5.2 Cover all national and

international sanctions / issues in the programs by illustration, case

study, examples, etc. so that awareness can be developed among the participants on
impacts of the issues in their day to day operations.

3.5.3 Newly recruited employees are also brought under AML Training programs during their
orientation / foundation training.

3.5.4 All abstracts or curriculum of the training programs are being

prepared targeting to achieve

the objectives of the bank.

3.5.5
3.6

Evaluation of courses, trainers and participants are being done to evaluate the success of
the programs.

For development of AMUCTF awareness, Anti-Money Laundering Division has been arranging
daylong Workshops on "Prevention of Money Laundering and Combating Terrorist Financing" in
participation of the officials of different branches. There were 632 participants in the said workshops
during the year 2013. In 2014 the participants were 277 and it continues. In conducting the daylong
training/workshop program EXIM Bank covers the following areas:

3.6.1 Definition of ML & TF, Causes & Consequences, Steps and Techniques,

International
Standards, Legal Framework, Organizational Framework, Role of BFIU and ACC.

3.6.2 Money Laundering Prevention Act (MLPA)-2012, Anti Terrorism Act (ATA)-2009,

Anti

Terrorism (amendmentl Act-2012 & 2013 and FATF Recommendations.

3.6.3 Bangladesh Bank's (AMLD & BFIU) Circulars, Circular Letters & Guideline, Know Your
Customer (KYC), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD),
Transaction Monitoring, CTR & STR, Self Assessment, Independent Testing Procedures,
Sanction (UNSCR, OFAC, IRGC) Screening, PEPs Screening, Wolfsberg Questionnaire.

3.6.4 Case study on: KYC, Risk Grading, Transaction Monitoring & TP, Self
Independent Testing Procedures, STR.

Assessment,

4. AML Examinations and Audit

4.1 Self Assessment:

As per section 6.5 of Guidance Notes on Prevention of Money Laundering provided by Bangladesh Bank,
each branch of EXIM bank determines their position according to banks and National Money Laundering
policy on the basis of the detailed "Self Assessment" answers against the questionnaire stated below:
Questionnaire
1. What are the total no.

of executive /

of the Branch (as per

designation)? What percentage of
executives / officers received
officers

institutional training?

2.

Does the executives

officers What is the process of evaluation?

Money
Laundering policies
the bank,
procedures
program and
Bangladesh Bank guidelines with
national policies?

aware about the Anti

and

of

3. Does meeting take place in the lf taken, at what interval? Does the
branches at regular interval?

agenda distribute to all for their concern?

What important decisions taken in the

meeting? How the decisions of the
meeting complied?

4.

Does the customer information How is the correctness of the information

taken satisfactorily regarding opening evaluated? How is the information
of individual, corporate and others preserved in the Branch?
account (i.e. Current , Savings, S.T.D,
Fixed Deposit, Special Scheme, FC,
RFCD, NFCD)

5.

Does the branch classify their How much high risk account opened till

customer according to risk?

the date? What are the steps taken by the

Branch to open and maintain such
account?

6. Does the process of completion of What is the percentage of completion of

KYC procedures.. regarding account KYC procedures by the Branch? What are
opened before 30'n April 2OO2?

7.

the steps taken by the branch to complete

the matter by January, 2010?

Does the Branch updated KYC How the examination completed and at
by re-examining at fixed what interval?

profile

interval?

8.

Does the Branch follow KYC

/ walk-in-

procedure regarding floating

customer?

9. Does the information of

How the procedure completed?

depositor How this monitoring procss completed?

and withdrawer taken regarding Online
Banking according to the instruction of
Bangladesh Bank?

Branch's opinion

Questionnaire

Branch's opinion

10. Does the Branch monitor the How is it taken?

transaction of the customer with TP
according to risk gradation or
transaction above the fixed limit?
11. How much Suspicious Transaction What kind of process introduced by the
(STR) is detected by the Branch till branch to detect STR?
date?

12. Does the Branch introduce any How the structuring

is detected?

process to detect structuring?

13. ls CTR sending regularly and How the correctness of the information is
correctly by the Branch to the Central evaluated?
Compliance Unit?
14. Does the Branch preserve MLP lf done then write 'Yes' or if not done then
Act, circular, training record, statement write'No'.
and other AML related matters
separately? Does the branch supply

the copy of Act and circular to

all

executives / officers?

15. Does the Branch maintain

any lf yes then what kind of caution followed

Money to open and maintain this account?
Laundering Prevention Circular-1 4?

PEPs account as per

16. Were the weakness / irregularities lf not complied, what are the drawbacks?
mentioned in the inspection report of
Head office and Bangladesh Bank
complied.

17. Does the branch monitor foreign How is it done?

remittance with other inward and
outward remittance?

Name, signature, date and seal of Branch Anti

Money Laundering Compliance officer

Name, signature date and seal of Branch Manager

N.B: All branches of EXIM Bank conduct the above evaluation

process "Self Assessment" regularly and

keep its' records in the branch and also send the same to Anti-Money Laundering Division, Head
Office on quarterly basis. After receiving quarterly report from branches, Anti-Money Laundering
Division places the same to Central Compliance Unit(CCU) for perusal and discussion over the
compliance status. After that Anti-Money Laundering Division prepares a report on half yearly basis
for placing before Managing Director & CEO for his perusal and necessary instruction and finatly
submits the report to Bangladesh Bank within 60 days of ending the half year.
Frequent & repeated checking & monitoring on the above issues and due/proper address/actions for
compliances, the AMUCTF activities of the branches have been achieved at "Satisfactory" rating
level.

4.2 lndependent Testing Procedures

As per section 6.6 of Guidance Notes on Prevention of Money Laundering provided by Bangladesh Bank,
our Internal Control and Compliance Division (ICCD) evaluates branches Anti-Money Laundering
compliance status. Internal AML audit is being done by Internal Control & Compliance Division (ICCD) at
every branch through "lndependent Testing Procedures" as prescribed by the central Bank at lest once in
every year.
The questionnaire (lndependent Testing Procedures) of internalAML Audit are as follows:-

sl

Area

Questionnaire

Tools of verification

Score

1. whether branch has deployed

experienced and senior
officer as Branch Anti-Money
Laundering Compliance Officer
(BAMLCO)

Check office order. Branch

Manager / 2nd officer or 3
years experience as Head of
General Banking should be

No.
1.

Branch

Compliance
Unit

an

nominated as BAMLCO.

2. Does he receive any training Verify on the basis of interview

regarding Anti

Money and documents.

Laundering activities in the last
two years? Does he aware

sufficiently regarding AML law,

Gircular and Guidance Note?

3. Does BAMLCO follow up and Veriff the procedure and

monitor effectively at a regular process of monitoring and

interval that Anti

Money follow up by BAMLCO.

the
branch complied meticulously.

Laundering activities

of

Does it sufficient that the Verify the process of monitor

measure taken by the BAMLCO of all accounts including High
to monitor all accounts including Risk account by BAMLCO.
High Risk account?

4.

5. Does the branch preserve any

PEPs account as per Money
Laundering Prevention Circular
no.-14?
2.

Verify whether due diligence is

followed as per AML Circular
no.-14 to open and maintain
such account.

Knowledge of 1. How many officer

will
Staff
considered as
officer/Staff
received training regarding AML satisfactory level,
the
regarding AML activities?
percentage will stand 100.
activities
2. Whether all officer staff Evaluate by taking interview at
aware regarding bank's Anti least 20o/o officer
the
Money Laundering policy, branch.
procedure, program and national

It

policy with guidelines

be

if

of

of

Bangladesh Bank?
3. Whether a meeting took place Collect and veriff the minutes
presided by the Branch Manager of that meeting.
with all officials at regular interval
to evaluate AML activities of the
branch?

Score
obtained

sl

Area

Questionnaire

Tools of verification

Score

No.
3.

Know Your

KYC of Account Holder

Customer

1. Whether KYC is taken Examine 23 accounts of each

properly on individual, corporate type. In that case evaluate
and others account? How is it whether the instruction of AML
verified and whether it is circular and section 5.6-5.13 of
properly recorded or not?
Guidance Notes is complied or

(KYc)

not.

2. Does the branch classify their Examine Whether the process of

customer according to risk?
classification is in accordance to
AML circular or not.

3.

4. What is the progress of

Whether additional Examine what types of

information is collected for High information taken in this regard
Risk account?
and are they sufficient?
Whether it will be completed
collecting KYC of the account before 31"t January,2O1O as per
opened on or before 3dh April, AML circular 06 or not and
2002?
evaluate on the basis of Branch's
progress.

5. Does the branch updated Evaluate on the basis of KYC

customer's KYC Profile at a Profile reexamination and
regular interval?

updating process.

lC/C of Floating Customer

1. Does the branch follow KYC Collecting information is whether

procedure of floating / walk in related to AML circular, circular

customer (DD,

TT,

a
J

online letter; it will be justified.

deposit etc.)?
4.

1. Does the branch monitor Minimum 10 (Ten) accounts

actual transaction with declared statement to be examined to
obtaining and transaction of the customer?
veriff the process.
monitoring
2. Does the branch monitor Examine at least ten (10)
inward and outward remittance relevant cases and RFGD A/C.
including foreign rem ittance?
NFCD A/C of huge transaction.
Transaction

Profile

3. Does the branch review and Examine such 10 samples of TP

update TP at a regular interval.
reviewed and updated and

evaluate the effectiveness.

5.

Suspicious
1. Does all the employees of the
Transaction branch
aware about
Report (STR) Suspicious Transaction Report
(srR)?
and Cash
Transaction
How many Suspicious
Report (CTR)
Transaction Report (STR)
reported to BAMLCO / CCU?

are

2.

Examine the concept regarding

this issue of the branch
employee under Chapter Vlll of
Guidance Notes.

a
J

Examine the documents. lf no

STR is forwarded to BAMLCO/
CCU, it will be considered as

a
J

dissatisfactory. Evaluate,
whether any process developed
by the branch to detect STR.

Score
obtained

SI

Area

Questionnaire

Tools of verification

Score

No.

3. Does Cash Transaction

Examine documents

branch properly and accurately?

for at least one month

in

this

Report (CTR) submitted by the regard. Examine cash register

and
evaluate the correctness of the
CTR submitted for that month.

4. Does the branch develop any Evaluate by checking the branch

process or procedure to detect action in this regard.

Structuring as done by the client
to avoid CTR?
6.

Statement
submitted to

ccu

1. How many statements

by the branch to
CCU? Does the branch
submitted

Check documents and paper in

this regard. lf not submitted all
statements or make delay to

submit,

submitted statements timely?

it will be treated as

dissatisfactory.

2.

Evaluation will be made on Examine the documents, if the

the information is not fully complied it
information included in the will be treated as dissatisfactory.

sample basis that

statement

is fully correct

and

complied.
7.

Record

keeping

'l. ls there any system to

preserve customer information
(KYC) and transaction related
record according to Money

Check at least 5 (five) close A/C

and veriff if the branch follow the
guidelines of AML Act-2009,
section 25 (a, b) in this regard.

Laundering Prevention Act-2009

Authority
and Bank's own policy.

25 (a, b), Regulatory

2.

Does the branch provide Check documents. lf information

information as desired by is not provided in time and
regulatory authority or CCU?
accurately, it will be treated as

dissatisfactory.
8.

'l. Does the branch manager

Overall
activities of the play proper role to implement
branch
AML program in branch though
regarding AML he is not a BAMLCO?
activities
2. Does the branch take any
measures
the
weaknesses and irregularities
found in the previous interval
and external audit report under
AML program?

Check the contents of minutes in

the meeting held at branch and

take interview of

Branch

Manager.

Check the previous audit report

and evaluate the steps taken to
rectiff the irregularities.

3. Whether overall performance Evaluate overall activities in

of the branch is satisfactory or accordance to the AML activities

to rectiff

not?

by the branch.

Total

100

Score
obtained

Overall performance score and rating of the branch:

Score

Rating

91-100

Very Good

71-90

Good

56-70

Satisfactory

41-55

Marginal

40 and below

Dissatisfactory

Internal Control and Compliance Division (ICCD) of EXIM Bank conducts the inspection according to the
above "lndependent Testing Procedures" questionnaire and comments with the rating as per secured
score. Thereafter ICCD sends a report to Anti-Money Laundering Division, Head Office on quarterly basis.
After receiving quarterly report from ICCD, Anti-Money Laundering Division places the same to Central
Compliance Unit (CCU) for perusal and discussion over the compliance status. After that Anti-Money
Laundering Division prepares a report on half yearly basis for placing before Managing Director & CEO for
his perusal and necessary instruction and finally submits the report to Bangladesh Bank within 60 days of
ending the half year.

EXIM Bank's all branches have secured the score ranging 65-70 with "Satisfactory" ratings. There is no
branch having "Marginal" rating in EXIM Bank. Frequent & repeated checking & monitoring on the above
issues and due/proper address/actions for compliances, the AMUCTF activities of the branches have been
achieved at'Satisfactory" rating level.
The overallAML activities of EXIM Bank is "Satisfactory" and appreciated by the regulators.

4.3 Last regulatory examination was made on 1210212013 (by central Bank)
4.4 Findings andlor corrective actions result frorn the most recent examination are as follows:-

4.4.1

Yearly announcement by the Managing Director & CEO of the Bank regarding prevention of money
laundering to all the employees of the bank is being continued.

4.4.2 Regular updating of KYC of Correspondent Banks.

4.4.3 For more effectiveness of AMUCTF issues at branches,
4.4.4

4.4.5

Transaction Monitoring with frequent

inspection is being done by the AMLD and report to Central Compliance Unit of the bank.
Properly review 'Self Assessment" statement of branches and effective steps are being taken for
branches by the AMLD and report to Central Compliance Unit.
Instruction is being sent to branches by the AMLD, so that lapses not be repeated.

4.4.6 Arrange daylong TrainingMorkshop in participation of the officials of the branches who are yet to
receive any such formalTraining.

4.4.7 More importance is being given for AML TrainingMorkshop and evaluation after Training/
Workshop

4.4.8
5.
5.1

Updated information regarding AMUCTF is being communicated to all branches by the AMLD from
time to time.

Customer Due Diligence:

Comply the minimum documentation requirements required for new clients: Copy of passporU
National lD Card/Driving License/Office lD CardMord Commissioner's CertincatJRny lD card
acceptable to the bank.

5.2

ConducUEvaluate risk rating of all clients. The risk assessment made by using the Uniform l(YC
Profile Form in which following seven risk categories are scored using a scale of 1 to 5 where scale
4-5 denotes High Risk, 3- Medium and i-2 Low Risk:

5.2.1
5.2.2
5.2.3
5.2.4
5.2.5
5.2.6
5.2.7

5.3
5.4
5.5
6.

Customer's Profession/Nature of the Business.

Net Worth of Customer.

Nature of Account.
Monthly expected amount of Transaction of the Account Holder.
Monthly expected Number of Transactions.
Monthly expected amount of Cash Transaction.
Monthly expected Number of Cash Transaction.

The risk scoring of less than 14 indicates "Low Risk" and equal or more than 14 indicates "High
Risk". The risk assessment scores are documented in the KYC Profile Form.
Volume of high risk Account is 1579 (up to June'2014).
All high risk clients including PEPs are subject to enhanced due diligence.
Customer Due Diligence/KYC information is updated at least annually.

Transaction Monitoring and Screening:

6.1
6.2
6.3

Transaction monitoring system is automated.

In-house automated system is developed for monitoring the transactions.
Automated system is available to find report generation when Customer declaration of Transaction
Profile limit exceeds.

6.4
6.5
6.6
6.7
6.8
6'9

Cash Transactions are incorporated into the automated system.

Monthly number of alert generated

15,OOO

approximately.

Dedicated staffs are there to process alerts.

4 (four) SARs have been filed during the past years.
No Foreign currency transaction reports filed during the past years.

All procedures are in place to screen and prohibit transaction from entitles/countries that have
been sanctioned by the UN, OFAC or our Local Regulator.

6.10

Sanctions screening is being performed through in-house developed semi-automated software

system.

7. Other Information:
7.1 There is no instance of any negative news or regulatory enforcement actions as well as any
associated corrective actions.

7.2

There is no changes in ownership or senior management in the past year.

l0

8. Special Risks:

8.1

We don't offer correspondent banking services to other bank's and we have no Vostro Account of
other banks at present as well. But we have Correspondent Relationship with 389 Banks in 106
countries and we have regular on going KYC/AML process for all of them.

8.2

The risk management principles that the Bank uses in traditional operational areas and is being
applied to assess and manage AML risk. A well developed risk assessment tools/tech technique
assists in identifying the bank's AML risk profile. Understanding the risk profile enables the bank to
apply appropriate risk management processes to the AML compliance program to mitigate risk.

8.3

Compliance is observed for MT202|MT202COV payment requirements at both checker/maker

level.

8.4
9.

There is no branch/subsidiary of EXIM Bank in sanction countries.

AdditionalComments:

9.1

Export lmport Bank of Bangladesh Limited is one of the compliant bank (lnternational standard) in
respect of AMUCTF compliance.

9.2

EXIM Bank Emphasises to develop it's all human resources knowledge base and well aware about
standard activities in respect of AMUCTF Laws/Rules/Regulations of home and abroad.

I, the undersigned, confirm to the best of my knowledge that the information provided in this call report is
correct, accurate and presenting the status & effectiveness of Anti-Money Laundering & Anti Terrorist
Financing activities of Export lmport Bank of Bangladesh Ltd.

Signature
Name
Designation

Deputy Managing Director & Chief Anti-Money Laundering Compliance Officer

Date

14t08t2014

Contact no.

01819242433

E-mail

haq ue7@exim bankbd.com

ll