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Financial Institution Compliance in Pakistan: MCB Bank’s Efforts to Combat Money Laundering and Terrorist Financing
In a bid to prevent the misuse of its services for money laundering and terrorist financing activities, MCB Bank has taken a robust approach to compliance with anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations in Pakistan.
Compliance and Controls Group
The bank’s Compliance & Controls Group is responsible for:
- Identifying, assessing, advising on, monitoring, and reporting on the risk of sanctions, financial loss, or harm to the bank’s reputation arising from non-compliance with laws, regulations, codes of practice, and international best practices.
Customer Due Diligence and AML/CFT Policy
To mitigate this risk, MCB Bank has implemented a customer due diligence (CDD) and AML/CFT policy approved by its board, which is in line with the AML Act 2010 and SBP AML/CFT regulations.
Risk-Based Screening, Monitoring, and Searching Processes
The bank’s Compliance department has put in place effective:
- Risk-based screening processes to ensure compliance
- Real-time payment screening system that automatically filters relevant payments instructions prior to execution to prevent making funds available in breach of sanctions, embargos, or other measures
- Customer names and associated details are screened against lists provided by relevant authorities, including the UN, EU, OFAC, and others, both at initial on-boarding and during the client relationship
PEPs Identification and Transaction Monitoring
In addition, MCB Bank uses a web-based solution to identify:
- Politically Exposed Persons (PEPs) and their associates
- Automated transaction monitoring system that reviews transactions for unusual activity, including single transactions and flows, for subsequent review and reporting to authorities as necessary
Correspondent Banking Relationships
The bank has taken steps to manage its correspondent banking relationships effectively, adhering to the:
- Wolfsberg Principles for establishing and maintaining foreign correspondent banking relationships
- USA Patriot Act certification/recertification available for use by other financial institutions
- Records of correspondent banks’ beneficial owners, including certificates of foreign status and tax withholding forms
Anti-Money Laundering Questionnaires
Anti-money laundering questionnaires are also required from:
- Correspondent banks
- Exchange companies
- Money service businesses (MSBs)
Contact Information
For any assistance or clarification on these matters, MCB Bank’s Compliance department can be contacted via email at [email address].