AML CFT Policies
Myanmar Metro Bank AML/CFT/CFP Policies and Guidelines
Myanmar Metro Bank is committed to combating money laundering, terrorist financing, and the financing of proliferation. Our policies and guidelines ensure strict adherence to national regulations and international standards. By adopting a risk-based approach, we focus on effective risk management, thorough customer due diligence, and vigilant transaction monitoring. Our continuous efforts in compliance and proactive measures reflect our dedication to safeguarding the financial system and maintaining the highest standards of integrity across all levels of the organization.
Policies and Frameworks
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Anti-Money Laundering, Countering the Financing of Terrorism, and Countering the Financing of Proliferation Policy (AML/CFT/CFP Policy):
This policy outlines Myanmar Metro Bank's comprehensive commitment to combating money laundering (ML), terrorist financing (TF), and the financing of the proliferation of weapons of mass destruction (CFP). It applies to all employees, officers, directors, and business partners, ensuring adherence to both Myanmar’s regulatory framework and international standards like those set by the Financial Action Task Force (FATF). The policy emphasizes a risk-based approach to identifying and mitigating risks, stringent customer due diligence (CDD), vigilant monitoring of transactions, and a robust internal culture of compliance. Continuous improvements and updates are integral, reflecting the evolving nature of financial crimes and regulatory requirements.
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AML/CFT/CFP Risk Management Framework:
This framework provides a structured approach to managing risks associated with ML, TF, and CFP. It covers risk governance, including clear roles and responsibilities from the Board of Directors down to frontline staff. The framework employs a comprehensive methodology for risk identification and assessment, applying a dynamic risk assessment model to adapt to changing threat landscapes. Key components include continuous monitoring practices, detailed reporting mechanisms, and leveraging technology for effective risk management. Regular training and awareness initiatives ensure all staff are prepared to identify and respond to risks appropriately.
Guidelines
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Guidelines on Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for Customers:
These guidelines outline the procedures for onboarding individual customers, verifying their identities, and assessing their risk profiles. Customer Due Diligence (CDD) involves collecting and verifying customer information and monitoring transactions for consistency with expected behavior. Enhanced Due Diligence (EDD) applies to high-risk customers and includes additional scrutiny of their financial background, source of funds, and potential political exposure. The guidelines ensure thorough documentation and regular updates to maintain compliance and mitigate risks associated with financial crimes.
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Guidelines on Customer Risk Categorization:
This document provides a framework for categorizing customer risk based on various factors such as geographic location, industry sector, transaction patterns, and the nature of the business relationship. It defines criteria for low, medium, high, and unacceptable risk levels, helping the bank to apply appropriate levels of due diligence. The guidelines are tailored to address specific risks relevant to Myanmar, including those posed by cash-intensive businesses and operations in high-risk regions, ensuring a proactive stance in managing customer-related risks.
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Guidelines on Internal AML/CFT/CFP Reporting:
These guidelines establish the procedures for reporting and managing potential suspicious activities internally. They outline the roles of all staff in identifying red flags and the steps for escalating these to the Compliance Function. The guidelines provide clear channels and deadlines for reporting, detail the documentation required, and emphasize the importance of timely investigation and decision-making. Regular reports to senior management ensure ongoing oversight and the ability to track trends and outcomes of suspicious activity reports.
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Guidelines on Transaction Monitoring, Investigation, and Reporting:
This document details the processes for monitoring and investigating transactions to detect and report suspicious activities. It includes setting thresholds for various transaction types, using behavioral indicators to identify potential risks, and employing both real-time and batch processing for transaction analysis. The guidelines specify the steps for managing alerts, conducting investigations, and escalating cases for further action. Continuous training and the use of advanced monitoring technology support the bank’s efforts to effectively identify and mitigate risks associated with illicit financial activities.