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TBML Presentation For SBP

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Chango Mansira
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0% found this document useful (1 vote)
17 views

TBML Presentation For SBP

Uploaded by

Chango Mansira
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PPTX, PDF, TXT or read online on Scribd
You are on page 1/ 9

TBML – TRADE SERVICES

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TBML TASK COMPLETED AS PER TBML FRAMEWORK INSTRUCTION

i) TBML SOP and Policy in place refer SBP Circular # 04


ii) Board oversee the ML/TF/PF risk in the bank on due course as per TBML Framework.
iii) Regular Trainings of staffs are being arranged to strengthen controls/check to better combat with the trade related risks and avoid
possible use of trade transaction for ML/TF.
iv) Bank obtain an undertaking from new customer, which intends to do trade business, wherein the customer shall be required to
declare the name(s) of bank(s) with which it has/had trade business relationship along with various type of trade transactions in which
it has been dealing
v) Customer Risk Profiling (CRP) is done through T-24 Core Banking System while onboarding Trade customers, CRP System auto calculate
customer risk through CRP Module in T-24 Core Banking System, all existing and new customers CRP are updated in T-24 and risk
associated is reviewed before execution of trade transaction.
vi) All those customers risk rating / score is reviewed and following criteria is set for next review:
 High Risk Customer’s CRP is reviewed in one year’s time.
 Customers with medium risk score is reviewed in two years’ time.
 Customers with low risk score is reviewed in three years’ time.
vii) FIRCO Compliance Link System is being used for Name Screening for trade transactions i.e.
 Importer/exporter & other parties involved in the trade transaction
 Origin of goods.
 Dual use goods.
 Vessel Tracking
viii) Price verification software system is in place through which goods price and H.S.Code are cross checked for which senior management
have approved a threshold range on 20% over and below the average, if the threshold is breached then the same is forwarded to
Business for clarification and concurrence and senior management concurrence is taken before execution of such transaction.
ix) Price Verification is performed through system against every transaction / every goods which are imported or exported, or services
rendered through TBML Unit.
x) AD Own Risk Profile is also done through System, which is presented to senior management as per TBML Framework for their review.

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PROCESS FOR DEALING WITH NEW TO BANK(NTB) CUSTOMERS

i) Bank obtain an undertaking from new customer, which intends to do trade business, wherein the customer
shall be required to declare the name(s) of bank(s) with which it has/had trade business relationship along
with various type of trade transactions in which it has been dealing.
ii) Upon obtaining the said undertaking, Bank verify the status of customer overdue [Export Bills, Advance
Payment Import, Advance Payment Export, Regulatory Penalties etc.] and default history from the concerned
bank(s) by forwarding a request through TBML Unit.
iii) The overdue, if any, is given due weightage by the Bank while taking the decision to onboard the client.
iv) In the event of on boarding, the overdue is made part of Customer’s Risk Profile.
v) For old customers, periodic review of client is conducted in the light of FE Circular # 04 (TBML Framework).
vi) KYC is updated by the Business Team and any change in business profile is also recorded in CRP.
vii) All existing nontrade clients which intend to deal in trade are also required to be assessed on same
parameters as required for onboarding new clients.
viii) Upon receiving responses from other banks regarding overdues, penalty and default history, same is/are
shared with Business Unit for incorporating the overdue status in Customer Risk Profiling (CRP).
ix) Business Head approval is obtained for 1st trade transaction and if required, again approval is taken on case-
to-case basis.

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NAME SCREENING

Screening at the time of onboarding customers intending to avail trade facilities/services

 Business team conduct KYC/CDD/EDD where required at the time of onboarding new trade client. Different element but
not limited to Nature of Business, Place of Business, Relationship with previous banks, number of foreign clients,
commodity under trade, economic value of goods under trade, requirement of commodities in the importer / exporter
country etc. shall be considered by the business team at the time of onboarding new customers.

Name Screening for Trade Transaction through “Compliance Link” System


 Screening is conducted for all parties involved in trade transaction.
i) Sanction screening from “Compliance Link” software is conducted for all parties including but not limited to
a) importer,
b) exporter,
c) shipper [If other than exporter],
d) consignee [If other than importer],
e) port of loading / discharge,
f) vessel related to the transaction.

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AUDIT OBSERVATIONS & EFFORTS MADE BY BANK FOR RESOLUTION

INTERNAL & SBP AUDIT OBSERVATIONS EFFORTS FOR THEIR RESOLUTION MADE BY BANK
Manual check have been placed for checking CRP before execution of every trade
transaction and same have been made part of Customer Risk Profiling (CRP).
Trade Customer CRP is/are not reviewed before
However, we are in the process of automation of this task in our core banking system,
execution of new trade transaction.
which will restrict new transaction if any component of CRP is/are mismatched with the
current transaction and this will be hold till updation of CRP in core banking system.

We have placed a control in core banking system through which popup message is
Overdue of customers is/are not reviewed before generated intimating about Overdue Import Advance Payment against which shipment
execution on new transaction. not received. However, for export overdue manual checks and controls placed through
which overdue are checked before execution of new Export Transaction.

Non Performing account with overdues need to be Now CRP is blocked of such accounts through which customer is not able to process
blocked new transaction.

Account needs attention to ensure that pattern of


CRP is updated in core banking system, which is reviewed before execution of new
transactions were in line with the profile declared in
trade transaction.
KYC document.

Monthly expected debit & credit value was not


In the process of automation through which system will restrict trade transaction if
matched with estimated cumulative debit & credit value
expected monthly trade debit / credit breach the estimated cumulative.
declared in system KYC

Now we have incorporated H.S.Code & Dual Use Goods (DUG) in system, which
H. S. Code & Dual Use Goods are manaully checked.
popup if hit is generated.

Risk of Customer mentioned in CRP was not identified


Customer rating and next review incorporated in core banking CRP system.
with frequency of next review.

Single Key Buyer and/ or Supplier was tagged in CRP


Single and Multiple Buyer / Supplier field added in CRP System.
instead of multiple ones.

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