Client On-boarding and Customer Information File (CIF)

Creation for Clients of SME Banking Group (SMEBG)

Guidelines and Procedures

July 2021

Prepared by:

Amalia F. Davin
Business Compliance and Operational Risk Department Head

Jerson B. Pascua
Business Compliance Officer
Date:

Endorsed by:

Nerissa C. Toledo
Business Control and Administration Division, Division Head
Date:

Approved by:

FSVP Maria Angela V. Tinio

SMEB Group Head
Date:

For questions/clarifications, please contact:

Amalia F. Davin
Jerson B. Pascua

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I. SCOPE.......................................................................................................................................................... 3

II. GENERAL GUIDELINES.............................................................................................................................. 3

A. Documentary Requirements........................................................................................................................... 3

B. Beneficial Owners........................................................................................................................................... 5

C. Authorized Signatories................................................................................................................................... 6

D. Watch List Checking....................................................................................................................................... 6

E. Face-to-Face (FTF) Contact.......................................................................................................................... 14

F. Source of Wealth/ Funds.............................................................................................................................. 18

G. Standard Validation Procedures.............................................................................................................. 18

H. Risk Assessment....................................................................................................................................... 20

I. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) Assessment Form.......................21

J. Endorsement and Approval Requirements................................................................................................. 23

K. Creation of Client Record in the Bank’s System (Finacle).........................................................................25

L. Treasurer-in-Trust for (TITF) Accounts....................................................................................................... 25

M. Know-Your-Customer (KYC) Certification............................................................................................... 28

N. Filing of a Suspicious Transaction Report (STR)....................................................................................28

O. Operational Risk Management................................................................................................................. 29

P. Enterprise Document Management System (EDMS) – Implementation TBA...........................................32

Q. Record Keeping......................................................................................................................................... 32

III. DETAILED PROCEDURES......................................................................................................................... 32

A. CIF Creation – can be access via Sales force implementation TBA.........................................................32

B. Elevation/Downgrading of AML Risk Rating...............................................................................................36

C. Scanning of Documents via Enterprise Document Management System (EDMS) – Implementation....36

IV. ATTACHMENTS......................................................................................................................................... 39

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 I. SCOPE
This covers the guidelines and procedures in the standard processing of client onboarding and
Customer Information File (CIF) creation for both retail and corporate clients of SME Banking
Group (SMEBG).

II. GENERAL GUIDELINES

A. Documentary Requirements

1. All documentary requirements must be submitted by the clients prior to account opening.
(see Attachment 1)

2. Authorized Signatories of the account shall be subjected to the required Know

Your Customer (KYC) procedures even if no account will be opened under
their individual names. Hence, documentary requirements shall include
identification documents (IDs) of these signatories.

3. Customer Relationship Form (CRF)

a. The Corporate CRF (see Attachment 2) and CRF for Authorized Signatories (see
Attachment 3) contain the minimum information required by the Bangko Sentral ng
Pilipinas (BSP) / Anti-Money Laundering Act (AMLA) for corporate accounts and
Authorized Signatories, respectively. The Business Unit (BU) through the Relationship
Manager (RM) & Relationship Assistants (RA) shall ensure that these CRFs are
properly and completely accomplished by the client.

b. Information indicated in the CRF shall be validated against information reflected on the
documents/ IDs submitted. Any discrepancies must be clarified with the client.
Unsatisfactory validation may be a valid reason for not allowing the on-boarding.

c. Any alteration on the CRF must be countersigned in full by any of the Authorized
Signatories.

4. The following minimum information shall be required from the corporate

client’s Beneficial Owners owning at least 20% of the outstanding capital
stocks:

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 a. Name

b. Present Address

c. Date and Place of Birth

d. Nature of Work

e. Nationality

f. Source of Wealth/Funds

These shall be documented thru the Beneficial Owner Information Sheet (BOIS) (see Attachment 4).

5. For non-resident corporate clients, the following documents must be

submitted:

a. Certification from the Securities and Exchange Commission (SEC) that the non-
resident corporation/partnership is either licensed to do business or not licensed to do
business in the Philippines; and

b. A written permission (see Attachment 5) allowing the Bank to inform the Commissioner
of Internal Revenue that as a non-resident, the depositor is exempt from tax.

6. As mentioned in Branch Circular 2018-127, the following are the signature

requirements for corporate clients:

Table 1: Signature Requirements for Corporate Clients

Type of Document Signing Requirement

CRF - Corporate
Must be signed by the required
number or combination of signatories
Terms and Conditions
authorized to open the account as
provided in the Board Resolution /
FATCA1 Self Certification Form for
Secretary's Certificate.
Entities

Each of the authorized signatories of

the corporate client designated to
open and/or transact/operate the
CRF - Authorized Signatory
account shall be required to
accomplish and sign this document.

1
Foreign Account Tax Compliance Act (FATCA) related documents may be submitted within ninety (90) days from account opening.
W-9 form: Request for Taxpayer Identification Number and Certification. W-8BEN-E: Certificate of Status of Beneficial Owner for United
States Tax Withholding and Reporting Entities.
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Type of Document Signing Requirement
Must be signed by the corporate
client's authorized signatories
designated to transact/operate the
account.
Specimen Signature Card (SSC)
Note: The signing authority (e.g.,
anyone/two, etc.) of the authorized
signatories must be specifically
indicated in the SSC.

7. A post review on the completeness of the documents shall be checked by

Customer Information Servicing Department (CISD). CIFs and accounts of
new clients with incomplete documents shall be suspended by CISD. Detailed
procedures on the post review of newly created CIFs by CISD shall be
covered by CISD’s Operations Manual.

B. Beneficial Owners

1. The natural persons, if any, who ultimately have controlling ownership interest
in a juridical person:

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 a. An individual who owns 20% or more of the legal entity (the Ownership Aspect):

A shareholding or ownership interest of at least twenty percent (20%) in the customer

held by a natural person shall be an indication of direct ownership. A shareholding or
ownership interest of at least twenty percent (20%) in the customer held by a corporate
entity, which is under the control of a natural person(s), or by multiple corporate
entities, which are under the control of the same natural person(s), shall be an
indication of indirect ownership.

b. The natural persons, if any, exercising control over the juridical person through other
means, to the extent that there is a doubt under Item 1.1 above, as to whether the
persons with the controlling ownership interest are the beneficial owners or where no
natural person exerts control through ownership interests.

c. Control through other means includes control exerted by means of trusts, agreements,
arrangements, understandings, or practices, or when an individual can exercise control
through making decisions about financial and operating policies. In addition, control
also includes:

i. Power to govern the financial and operating policies of the enterprise under
statute or an agreement

ii. Power to appoint or remove the majority of the members of the board of
directors or equivalent governing body;

iii. Power to cast the majority votes at a meeting of the board of directors or
equivalent governing body; or

iv. Any other arrangement similar to any of the above.

NOTE: The beneficial owner with respect to the Control aspect will only be required if there is NO beneficial
owner with respect to the Ownership Aspect (i.e., no beneficial owner has 20% or more ownership of the
corporation.

2. The BU shall properly explain to the client the definition of beneficial owners. In cases where
the corporate client has an immediate beneficial owner who is also a corporation, the client
shall declare the ULTIMATE BENEFICIAL OWNER (UBO) of the corporation who must be a
NATURAL PERSON.

a. Covered persons are not required to verify the identity of any shareholder or beneficial
owner of companies listed in the stock exchange and subject to disclosure
requirements. Their relevant identification data may be obtained from a public register,
the customer or other reliable sources. However, records on the actions taken to
identify the beneficial owner shall be kept.

3. The beneficial owner declared by the corporate client shall be documented

through the updated BOIS and signed by the Corporate Secretary.

C. Authorized Signatories

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 1. All the Authorized Signatories as indicated in the submitted Secretary’s
Certificate/Board Resolution/Partners’ Resolution shall be required to
accomplish the CRF for Authorized Signatories.

2. In case any one of the Authorized Signatories is not able to complete KYC documents, such
Authorized Signatories shall NOT be created with CIF records and NOT be allowed to
transact with the Bank. However, mandatory KYC information shall still be obtained by the
Bank:

a. Documentation of the mandatory information shall be through the CRF for Authorized
Signatories.

b. Obtaining of the information shall be through interview of the RM with the particular
signatory who is not able to comply with the complete requirements.

c. The RM who conducted the interview shall sign in the KYC Certification portion of the
CRF of the Authorized Signatory.

d. Only when the signatory is able to comply with the complete KYC documents, which
include accomplishment of the revised CRF, shall the Bank allow the signatory to
transact on the corporate account.

D. Watch List Checking

1. The following shall be subjected to watch list checking:

a. The corporation;

b. All Authorized Signatories of the corporation;

c. Beneficial Owners of the corporation owning at least 20% of the outstanding capital
stock; and

d. Primary Officers of high risk corporations

2. Black List (BL) Checking

a. The BU shall conduct BL checking to screen clients who are:

i. Reported under the AML watch lists:

1.Office of Foreign Asset Control (OFAC) list

2.National Defense Arrest Order list

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 3.SEC Advisories

4.AMLC Advisories

ii. Politically Exposed Persons (PEPs)

b. All new clients opening accounts shall be subject to BL checking. Also, new clients
even if they will be linked to an existing account (i.e. as an additional co-accountholder)
shall be subject to BL checking as well.

c. There is no need to conduct BL checking during additional account opening and

periodic KYC updating for existing clients.

d. The BU shall conduct BL checking through the following:

i. BL facility in the Finacle System

1. BL checking shall be done initially through the BL facility in Finacle –

Customer Relationship Management (CRM), Finacle – CQDE

2. The system will not proceed with the client record creation of the BL
checking is not conducted.

3. In case of name match, the complete details will be retrieved by the BU

through the Accuity database (see item ii below)

ii. Accuity

1. Accuity can be accessed through this website:

https://accuity.worldcompliance.com/SignIn.aspx

2.RM and RA shall have access to this system.

e. The RM shall indicate in the Corporate Assessment Form (see Attachment 6) the
results of the BL checking conducted.

Note: There shall be NO need to print the screenshot/results of the BL checking.

f. In case of positive match, handling shall be as follows:

i. Account Opening shall NOT be allowed if the client is classified under the
following:

1. Blacklist

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 2.Restricted (with restrictions imposed by BSP)

ii. Enhanced Due Diligence (EDD) and necessary approvals shall be required if
client is classified under High Risk.

g. Although Accuity checking already included adverse news checking, the BU shall also
consider derogatory information they know on the profile of the client, if any, even
without a positive BL match.

i. Particularly important are negative information related to money laundering,

fraud, terrorism, and any other AML predicate crimes as per BSP Circular
950.

ii. The BU, however, shall only consider information from credible sources and
document any adverse news that they are aware of in the “Unusual/Red
Flag” fields in the Corporate Assessment Form. This information shall be
considered by the BU when assessing if the account opening shall be
allowed, rejected, or subject to EDD, which may result to the following:

1. Recommend elevation of the client’s risk

2. Imposed restriction on the account

3. Negative List (NL) and Negative File Information System (NFIS) checking

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 a. NL and NFIS checking shall be conducted by the BU to screen clients with negative
credit histories (e.g. poor repayment history, records of issuing “bouncing” checks, etc.)
and NOT for AML-related reasons.

i. NL Checking

1. This refers to the internal watch list of the Bank (e.g. clients with
mishandled accounts, clients with unpaid loans)

2. NL checking shall be done initially through the NL facility in Finacle

CRM. The system will not proceed with the client record creation if the
NL checking is not conducted.

3. In case of name match, the complete details will be retrieved by the BU

through NFIS (see item ii below)

ii. NFIS Checking

1.This refers to the watch list maintained by Banker’s Association of the

Philippines (BAP) which consolidates the list of clients with negative
credit histories from all banks/financial institution.

2.NFIS checking can be accessed through BAP Credit Bureau website at

www.bapcb.com.

b. Only corporate clients opening new and additional accounts shall be subject to
NL/NFIS checking. NO need to conduct NL/NFIS checking to Authorized Signatories,
Beneficial Owners and Primary Officers if they will not open personal accounts with the
Bank.

c. In case of a positive match on the NL/NFIS checking, the IUO shall evaluate whether to
open the account or not.

i. The IUO may provide disposition, whether to continue or reject the account
opening, if reason for NL/NFIS match is due to cancelled credit cards.

ii. For all other reasons aside from cancelled credit cards, approval from
Segment Heads shall be required to proceed with the account opening.

iii. There is NO need to conduct EDD due to NL/NFIS positive match.

4. PEP List:

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 a. PEP refers to a natural person who is (incumbent) or has been (non-incumbent)
entrusted with prominent public positions in:

i. The Philippines with substantial authority over policy, operations or the use of
government-owned resources;

ii. Foreign state; or

iii. An international organization

b. Below is the list of PEPs:

Table 2: List of Politically Exposed Persons

Level Position

National Government President, functioning as both head of state and government,

as well as being the commander-in-chief of the armed forces
Vice-President
Cabinet Members (Secretary level only)
Congress, which consists of the members of the Senate and
House of Representatives
Judiciary Branch of the Government, headed by the Supreme
Court, which has a Chief Justice as its head and 14 Associate
Justices
Ambassadors, Consul Generals
Generals (Philippine Army – Brigadier General and higher,
Philippine Air Force – Brigadier General and higher,
Philippine Navy – Admiral and higher and Philippine National
Police – Chief Superintendent and higher)

Local Government Governor

Vice Governor
Mayor
Vice Mayor

PEPs also include First Degree Relatives by Consanguinity (i.e., parents and
the spouse, partner children, legitimate or illegitimate)
or immediate family First Degree Relatives by Affinity (i.e., parents-in-law and
member or relative children in-law)
within the second Second Degree Relatives by Consanguinity (i.e., siblings,
degree of grandparents and grandchildren, legitimate or illegitimate)
consanguinity and Second Degree Relatives by Affinity (i.e., sisters-in-law,
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 Level Position
affinity. brothers-in-law, grandparents-in-law and grandchildren in-law)

PEPs shall also Joint beneficial ownership of a legal entity or legal

include close arrangement with the main/principal PEP (e.g., joint
relationships and accountholders); or
associates who are Sole beneficial ownership of a legal entity or legal
reputedly known (or arrangement that is known to exist for the benefit of the
actually known by the main/principal PEP.
Bank)

NOTE:

 All other government positions (e.g. Councilors, Barangay Officials) not included in the above list is NOT
considered PEPs.
 Once a client has been classified as PEP, such classification shall remain even if the client is no longer
holding public office. Thus, the circular shall still apply. These clients shall be classified as non-
incumbent officials.

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 c. The BU shall identify if any of the Authorized Signatories, Beneficial Owners and
Primary Officers are PEPs.

i. For authorized signatories/beneficial owners who are PEPs, this shall be

documented under Authorized Signatories/Beneficial Owners considered as
PEPs portion of the Assessment Form.

ii. For Primary Officers who are PEPs, this shall be documented under Primary
Officers portion of the Assessment Form.

iii. Only Beneficial Owners who are also Authorized Signatories shall be risk rated
using the Risk Rating Calculator (See Attachment 7).

iv. The corporate CIF shall be tagged as High Risk in case any of the Beneficial
Owners who are also Authorized Signatories is confirmed to be High Risk.

v. The BU shall NOT risk rate the following:

1. Beneficial Owners, who are NOT Authorized Signatories

2. Authorized Signatories, who are NOT Beneficial Owners

3. Primary Officers

d. PEP clients who are rated as Low/Normal Risk shall require approval up to Segment
Head.

e. PEP clients who are rated as High Risk shall require approval up to Group Head.

NOTE: All requests for approval must be supported by a duly accomplished Assessment Form. EDD section of
the Assessment Form must be accomplished for High-Risk PEPs only.

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 E. Face-to-Face (FTF) Contact

1. The FTF contact conducted shall be certified by the BU in the CRF as part of
the account opening requirements and compliance with the Bank’s Money
Laundering and Terrorist Financing Prevention Program Manual (MLPP).

2. Below shows the guidelines on FTF contact:

a. If FTF is conducted inside the Branch:

FTF to be conducted by:

i. Two (2) branch personnel, where at least one (1) is non-sales

Condition:
i. FTF to be conducted on Corporate Secretary only who certifies the authenticity
of all other signatories; OR

ii. FTF to be conducted with the Authorized signatories.

Note: The minimum required number of signatories to open/transact as provided in the Board Resolution/
Secretary’s Certificate must be satisfied.

iii. Conduct of FTF to be documented in the CRF.

iv. Capture client’s photo via webcam

b. If FTF is conducted outside the Branch:

The FTF contact conducted by one (1) Sales Officer may be

applied to the following transactions:

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 i. Onboarding New Client

ii. Additional Related Party / Co-accountholder in Retail Account

iii. Additional Signatory/ies on a Corporate Account

iv. Updating of Specimen Signature/s for Retail Account

v. Updating of Specimen Signature/s for Corporate Account

vi. Reactivation of Dormant Retail Account

vii. Reactivation of Dormant Corporate Account

viii. Additional Account Opening for Existing Retail and Corporate Clients

Guidelines

A. FTF Outside Bank Premises by Sales Officers from Any Business Unit (BU)
a. FTF outside bank premises (without recorded virtual FTF) may now be
conducted by one (1) Sales Officer from any BU (e.g. RBG, CBG, Wealth,
SMEBanking, Trust) without the need for prior approval. Please refer to the
below table for update:
b. Due to the above changes, please be guided of the following procedures which
shall be the responsibility of the Sales Officer:
i. Capture client's photo.
ii. Review that the required forms are properly accomplished, signed, and
has no alterations. The Sales Officer shall capture the photo of the
accomplished forms.
iii. Request the client to present at least one (1) original valid ID.
1. The ID presented by the client should be scrutinized by the Sales
Officer to ensure that it:
a. is valid and unexpired (for IDs with expiration dates)
b. has a photograph that matches the client's appearance
c. bears the client's signature
d. is free from alterations
e. has the security features (if applicable to the ID presented)
2. The Sales Officer shall take a clear picture of the client's ID.
3. Results of the ID validation above shall be documented by the
Sales Officer through the Assessment form. This shall serve as an
attestation that the ID was originally seen and scrutinized by the
soliciting Sales Officer.
4. Ensure that the signatures in the accomplished forms and ID are
the same.
5. If required based on the type of transaction, the Specimen
Signature Card (SSC) should likewise be requested from the client.
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 6. Witness the actual signing of the SSC upon pick-up of documents.
7. The Sales Officer should compare the signatures in the SSC versus
the accomplished forms and the original ID presented.
8. The Sales Officer shall affix his signature on the "Signature
authenticated by" portion of the SSC to signify that the above has
been conducted.
9. The Sales Officer shall capture the photo of the signed SSC.
c. The documentary requirements which were captured by the Sales Officer shall
be sent to the processing branch not later than the next banking day.
i. The Sales Officer shall send screenshots of the photos showing the date
and time these were taken/captured.

Note:  As a standard feature of iOs/iPhone, screenshots reflecting "Today,Yesterday, Monday,

Tuesday, etc." instead of the date shall likewise be accepted by the processing branch.

ii. After sending, these captured photos shall be deleted immediately from

the Sales Officer's device.
d. If the FTF is being conducted for a transaction that requires accomplishment of
the Assessment Form (AF) e.g., dormant account reactivation, the Sales Officer
shall sign on the AF to certify the following:
1. that he has conducted the FTF with his client
2. that he has seen the original documents
3. that all procedures outlined in this policy were duly conducted
Refer to the attached AFs to be used by the Sales Officer:

(See attached file: Retail Assessment Form - Highlighted for BU Sales Officer.xlsx)(See
attached file: Corporate Assessment Form - Highlighted for BU Sales Officer.xlsx)

Note: All highlighted fields shall be accomplished by the Sales Officer

e. The documentation of the FTF shall be accomplished following the existing

guidelines in Branch Circular No. 2020-136 re: Documentation on FTF Contact
>>.

The above procedures shall be for clients who are not comfortable/amenable with
taking their videos.  FTF with recorded video shall still be encouraged.

B. FTF via Virtual/Video Call by One (1) Sales Officer from Any Business Unit (BU)
a. FTF via virtual/video call may now be conducted by one (1) Sales Officer from
any BU (e.g. RBG SMEBG, Wealth, SMED, Trust).
b. As a general rule, KYC documents must be submitted and reviewed by the Bank
prior to the conduct of the virtual FTF.  Original documents may be submitted to
the branch or scanned copies through email/electronic means.
c. The general FTF procedures when conducting the FTF inside or outside bank
premises shall likewise be observed when conducting virtual FTF:
i. Verify the IDs submitted by client.
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 ii. Compare client's appearance with the photo on the ID submitted.
iii. Check the client's signatures across all required documents and verify
against the IDs presented or SSC on file.
d. During the virtual FTF, the Sales Officer conducting the virtual/video call should
ensure that:
i. The appearance of the client on the video call matches the photograph on
the copy of the ID submitted.
ii. The same ID is presented by the client during the video call.  The bank
personnel should ensure that a close up image of the ID is properly
captured in the video.
iii. The signed forms (i.e. AMF, CRF, SSC, etc.) and documentary
requirements if applicable (i.e. SEC cert, GIS, Articles of Incorporation,
etc.), are clearly shown in the video.
iv. The client shall likewise confirm that he has submitted and
accomplished/signed the applicable forms.
v. The virtual FTF shall be recorded and stored in the Bank's documents
management system (i.e. EDMS), retention of which should follow existing
policies on customer record retention.
vi. Refer to attached spiels as guide:

(See attached file: Attachment 9_Sales Officer Virtual FTF Spiels.docx)

e. If the FTF is being conducted for a transaction that requires accomplishment of

the Assessment Form (AF) e.g., dormant account reactivation, the Sales Officer
shall sign on the AF to certify the following:
i. that he has conducted the FTF with his client
ii. that he has seen the original documents
iii. that all procedures outlined in this policy were duly conducted
Refer to Section II.A.4 above for the AFs to be used.
C. Validations and Other Procedures to be Conducted by Branch Services
a. Prior to processing of any transaction in Section II.A and B above, clients
solicited by Sales Officers in accordance with the above process should still be
validated by branch services as to the following:
i. The documentary requirements and/or SSC submitted should be
complete, signed, and without alterations.  The copy of the ID should be
clear.
ii. The client signatures appearing in the documentary requirements and/or
SSC should be compared and verified vs. the ID presented.

NOTE:  Upon review of signatures, the Service Officer (SO)/Service Manager (SM) should affix
signature on the "Approved/Verified by" portion of the SSC.

iii. The branch shall ensure that the screenshots of the photos of the client,
the documentary requirements and/or SSC, and the ID, includes the date
and time when the photos were captured.

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 iv.ID verification with the issuing office through available channels (e.g. Use
of online registry, SMS verification) is conducted if applicable to the ID
presented.
b. The branch shall validate the contact number provided by performing a call-out to
confirm the request.  In addition, the email address shall be validated by the
branch by sending out an email to client's registered email address.
c. If the FTF was conducted for a transaction that requires accomplishment of the
Assessment Form (AF) e.g., dormant account reactivation, the branch services
personnel shall document the review and validations performed through the AF
in Section II.A.4 above, which should be initially accomplished by the soliciting
Sales Officer.
d. Failure to perform the above validations and procedures shall be considered as
lapses/findings by the Branch Operations and Control Segment (BOCS).

Any deviations to the above guidelines should be handled in accordance to Branch Circular
No. 2019-204 re:  Branch Exceptions Handling >> . 

All other requirements, guidelines, and procedures for the above mentioned transactions that
are consistent to this circular shall continue to be observed.

F. Source of Wealth/ Funds

The corporate client shall be required to declare ALL its source/s of Wealth/funds.

The corporate client shall also be required to provide the “Monthly Expected Credit (Max
Amount)2 for each declared source of wealth/funds.

G. Standard Validation Procedures

2
Refers to the regular monthly expected maximum amount to be credited to the account
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a. Documents submitted by the corporate client must be ascertained as to validity and
authenticity. Refer to Attachment 8 for the required verification procedure, depending on the
document submitted.

b. The IDs submitted by the Corporate Secretary and Authorized Signatories must be
ascertained by the BU as to validity and authenticity. Refer to Attachment 8b for the required
verification procedure, depending on the ID presented.

c. As part of authentication of the client’s signature, signature cards shall be accomplished by

the client in the presence of the RM. The specimen signatures shall be verified by the IUO
against the ID/s submitted by the client and must be the same as the client’s signature on all
forms accomplished during account opening prior to approving the opening of the account.

d. Submission of proof of address is not required anymore EXCEPT for the following:

i. High Risk Clients

ii. Payroll accounts without HR Certification and rated as high risk during RM's

assessment

e. Validation of the presented proof of address shall not be required.

f. The proof of address to be submitted shall reflect the same permanent or present address of
the client as indicated in the CRF. The following are the acceptable proofs of address:

i. General Information Sheet (GIS)

ii. Unexpired Mayor’s/Business Permit

iii. DTI Registration

iv. Insurance billings/policies

v. Latest ITR

vi. Telephone billings*

vii. Delivery courier receipts*

viii. Utility billing statements*

ix. Certificate of Registration issued by Housing and Land Use Regulatory Board
(HLURB)

x. Unified Registration Record

xi. Certificate of Registration Issued by Cooperative Development Authority (CDA)

*shall be dated within the last six (6) months

g. For high risk foreign clients, the following may be submitted as proof of address, aside those
mentioned in no.6 above:

i. Alien Certificate of Registration

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 ii. Same list provided in no.6 above that are issued abroad

iii. Certificate from the lessor or a notarized lease contract together with a proof of
billing under lessor’s name may be submitted.

h. Validate the contact details of the corporate client by:

i. Contacting the office contact number or mobile number of the authorized

representative (i.e., primary contact person indicated in the CRF) of the client.

ii. Sending an email to the email address of the authorized representative (i.e.,
primary contact person indicated in the CRF) of the client.

i. No account opening shall proceed, if any of the above validation is unsatisfactory.

H. Risk Assessment

1. During CIF creation in the Finacle System, the AML Risk Rating of the
corporate client will be automatically calculated.

2. The Finacle System shall classify the client to any of the following AML Risk
Rating:

a. Low Risk

b. Normal Risk

c. High Risk

3. In calculating the AML Risk Rating of the corporate client, the following must
be considered:

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 a. The individual AML Risk Rating of the Authorized Signatories must be considered.

i. The BU shall calculate the AML Risk Rating of the Authorized Signatories, who are
also Beneficial Owners, using the stand-alone AML Risk Rating Calculator. (See
Attachment 7)

ii. If any of the corporate client's Authorized Signatories is also a Beneficial Owner,
and the same has been tagged as High Risk, the corporate client shall be tagged
as High Risk.

b. The industry type of the corporate client.

i. For corporate clients that have more than one (1) industry type 3, the BU shall
capture in Finacle CRM the industry type belonging to extremely high risk
industries (i.e., Casinos and Gambling Operations, Charitable Organizations and
Foundations, Money Changer/Remittance Agent/Forex, Online Gaming Business,
Pawnshop, Private Banking, Investment Banking and Venture Capital).

ii. If none of the declared industry types belong to extremely high risk industries, the
BU shall capture in Finacle CRM, Multiple.

4. On highly meritorious and exceptional cases based on the results of EDD, the
AML Risk Rating of a client may be changed subject to approval (refer to
Table 4 for the Approving Authority Matrix for New and Additional Account
Opening).

5. All corporate clients classified as High Risk Customers shall not be allowed to
open an account with the Bank unless EDD is conducted and required
approvals as detailed in Table 4 below are secured.

I. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

Assessment Form

1. This is a new consolidated form that will used to document the CDD and EDD
conducted by the BU. (See Attachment 6)

2. The form contains the following sections:

Table 3: Assessment Form sections

Section Corporate Assessment Form

a. Additional Information The following additional information provided by the client

shall be documented in this section:
Required information of the Authorized
Signatories/Beneficial Owners who are considered as PEPs
Details of Registered Companies

3
In case the industry type indicated by the client in the CRF has no exact match in the Finacle CRM, the BU shall select the most
appropriate industry type available in the list. This must be documented in the CDD Form.
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Section Corporate Assessment Form

b. Customer Due The validation procedures conducted by the BU shall be

Diligence documented in this section:

Method of validation performed on IDs submitted by

authorized signatories
Watchlist Checking
Details of authorized signatories, who are also identified as
beneficial owners
Validation of client's financial information (i.e., source of
funds, expected monthly credits, initial deposit)
Unusual/Red Flags Cited

c. Enhanced Due The BU shall ONLY accomplish this section if:

Diligence Client is High Risk; or Results of Watchlist Checking
requires EDD; or
There are unusual/red flags cited in CDD, regardless of
client's risk rating

The BU shall document the

following in this section:
Additional Information for EDD
Disposition on Other Risk Factors/Unusual/Red Flags cited
in CDD

d. Overall Assessment The BU shall provide its overall assessment in this section.
A justification shall be required if the assessment requires
elevation of risk rating.

3. This is a mandatory form that must be accomplished by the RM and IUO.

4. If the result of the assessment is satisfactory, approvals shown in Table 4

below shall be established. The CRF and duly accomplished Assessment
Form shall be scanned and emailed to the approvers as basis for the
approval.

5. Based on the result of EDD conducted, the AML Risk Rating of the client can
be elevated or downgraded. In cases like this, the BU shall request CISD for
the system tagging of the elevation and downgrading of the AML Risk Rating
of the client. A copy of the approval shall be forwarded to CISD as basis for
elevation/downgrading.

6. The BU shall reject the account opening for clients who:

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 a. Have unsatisfactory results in EDD conducted;

b. Cannot or refuse to provide the requested additional information and/or documents;

c. Raise doubts as to the accuracy of any of the information provided; or

d. Have no legal or trade obligation, purpose or economic justification that is consistent

with the banking services to be availed of and expected transactions with the Bank.

J. Endorsement and Approval Requirements

1. All new account opening shall require review and approval of IUO with non-
sales function. High Risk clients shall require review and approval of an IUO
with corresponding designation of AVP and above.

2. Clients referred/solicited by the other BUs shall require endorsement of the

soliciting Officer prior to the account opening by the branch. To facilitate
account opening, endorsement shall be sent to the RM thru email prior to
account opening. Otherwise, endorsement shall be documented through the
soliciting Officer’s signature on the CRF.

3. Refer below for the Approving Authority Matrix:

Table 4: Approving Authority Matrix for New and Additional Account Opening
Required Approval
Findings Referred by Other BUs other
than RBG
Independent Unit Officer*
Client with NO watch list findings
(IUO)
PEP (Low/Normal Risk) Up to Segment Head (SH)
PEP (High Risk) Up to Group Head
Low/Normal AML Risk Rating IUO*
High AML Risk Rating IUO*
Elevation of AML Risk Rating
IUO* and SH
(Low/Normal to High)
Downgrading of AML Risk Rating IUO* and CCO
With unusual circumstances (but with
IUO* and CCO
satisfactory EDD results)

*with minimum rank of AVP

Table 5: Summary of Roles and Responsibilities of SMEBG Sales and Independent Unit

SMEBG Sales Independent Unit

Relationship Manager Independent Unit Officer
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 SMEBG Sales Independent Unit
Conduct Customer Identification Review the completeness of the
Process (CIP) (i.e., perform initial account opening documents
risk profiling, secure documentary submitted by the RM.
requirements).
Complete the CDD and provide
Coordinate with the client on the overall assessment.
completion of the account opening
documents. Review and validate the EDD
conducted by the RM.
Conduct FTF interview, CDD to all
referred clients and EDD to high Secure higher approval for clients
risk and suspicious clients. requiring such (e.g., PEP, High
Risk, with positive match in Watch
Creation of CIF in the Finacle list).
System (MA and AS can assist RM)
Verification of CIF in the Finacle
Endorse the account opening. System

Accept and process the account

opening (e.g., duplicate checking,
CIF creation).

a. The RM shall use the Assessment Form (See Attachment 6) to document the CDD and
EDD conducted.

b. To facilitate the conduct and validation of CDD and EDD, the RM and IUO shall
simultaneously perform the interview to the client.

4. For clients referred by other BUs (e.g., Retail Banking Group, Wealth
Management Group, Trust and Investment Group, etc.)

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 a. The referring BU shall conduct the required KYC process, CDD and EDD procedures
established herein including FTF contact. This shall include creation of CIF in Finacle
CRM.

b. The client may no longer need to go to the branch for the account opening as long as
the required endorsement and approval as established in Table 4 above have been
secured and documentations for such are submitted to SMEBG.

c. The following shall be the minimum required client documents from the other BUs for
the branch to open the account:

i. Copy of the client’s ID validated by the other BUs as evidenced by the other BU’s
signature on the copy with the notation “original seen”.

ii. Signature Card with client’s specimen signatures authenticated by the other BUs;
and

iii. CRF4

K. Creation of Client Record in the Bank’s System (Finacle)

1. During CIF creation in Finacle, the BU shall ensure that only one (1) record is
created for a client (i.e., one CIF – one customer policy).

a. Matched duplicate records noted during CIF creation shall be assessed by the BU if
indeed belonging to the same client.

b. The BU shall only create a new CIF upon confirmation that the client has no existing
records with the Bank.

c. For clients with existing records with the Bank, updates on the customer records shall
follow existing guidelines and procedures on Client Record Maintenance.

(Refer to Branch Circular No. 2017-104a Periodic  Updating of Client Information & Documents based on AML
Risk Rating)

2. A post review on the correctness of the CIF details vis-à-vis the client
accomplished CRF shall be conducted by the Independent Unit. CIF records
with discrepant details shall be reported and returned to the RM for
correction. Basis of Independent Unit’s review are the account opening
documents forwarded by the RM.

L. Treasurer-in-Trust for (TITF) Accounts

TITF accounts refer to accounts held in trust pending SEC registration of the corporation.

1. Documentary Requirements

4
If the original CRF will be safe kept by the referring BU, the CRF to be submitted may be a photocopy of the original or a print-out from
the Finacle CRM.
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 a. Clients who would like to open a TITF account shall be required to accomplish the
following:

i. CRF for Retail Account to be accomplished by the Treasurer of the Corporation to

be established

ii. CRF for Corporate Account for the Corporation to be established 5

iii. Signature Card (for the Treasurer)

b. Clients shall be required to submit the following:

i. Valid ID of the Treasurer

ii. Proposed Articles of Incorporation

iii. Notarized Treasurer's Affidavit

Refer to Attachment 1 for the specific documents required.

2. Watchlist Checking

a. The Treasurer shall be subject to watch list checking (i.e., NFIS, OFAC, BL, NL and
PEP) prior to account opening.

b. Watch list checking of the corporation to be established shall NOT be conducted.

3. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

a. The BU shall perform the necessary validation procedure and document this in the
CDD form.

b. The BU shall prepare a CDD form only for the Treasurer of the corporation. No CDD
form shall be prepared for the corporation to be established.

c. For accounts requiring further review and validation, EDD shall be conducted. The BU
shall prepare an EDD Form only for the Treasurer of the corporation.

d. No EDD Form shall be prepared for the corporation to be established.

4. CIF Record Creation

a. The BU shall create a CIF record only for the Treasurer of the corporation.

b. No corporate CIF record shall be created for the corporation to be established.

5. Account Creation in Finacle

5
The documentary requirements and standard validation procedures for Retail and Corporate Clients as stated in the Account Opening
Operations Manual for Retail and Corporate shall be required and performed by the branch to the Treasurer of the Corporation.

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 a. The BU shall ensure the following are correctly tagged in the system during account
opening:

i. The account must be a Savings Account only.

ii. The account must be opened under the joint relationship “Treasurer-In-Trust For."

iii. The account must bear the correct account name following the format “Treasurer's
Name TITF Corporation” (e.g., Juan S. Dela Cruz TITF ABC Corporation).

iv. The mode of operation of the account must be set to TITF.

v. No "Related Party" must be linked to the account.

vi. The account shall be tagged with “Post No Debit” via Finacle Core Module
(Account Freeze Maintenance Status).

b. Depending on the result of the corporate client’s request for SEC registration, the BU
shall be required to ensure that the following are performed:

i. If SEC registration is approved:

1. The corporate CIF of the TITF account must be maintained. BU shall encode
the SEC Registration date.

2. The TITF account must be closed.

3. KYC on the designated Authorized Signatories must be performed.

4. A new corporate Current Account (CA)/Savings Account (SA) shall be

ii. If SEC registration is disapproved:

1. The corporate CIF of the TITF account must be suspended.

2. TITF account must be closed.

6. Loan Static Fields: - can be access via Sales Force – implementation TBA

a. Loan static shall be filled up or modify by the RMs in finacle. RMs should cross match
all data/information gathered prior to inputting in finacle. The following are the fields
identified under Loan Static:

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 i. Borrower/Customer Type

ii. Customer Group

iii. Economic Activity

iv. Related Party

v. DOSRI

vi. Agri-Agra

vii. SBL Impacting

viii. Firm size

ix. Industry code

x. Environmental Risk Category

xi. Internal Credit Rating

M. Know-Your-Customer (KYC) Certification

The opening and other related/required information and documents shall be certified by the BU to be complete
and compliant with the Bank’s MLPP requirements. Such certification shall be documented through the Bank’s
Use portion of the CRF. By affixing their signatures, the BU certifies the following:

1. Conducted FTF interview with the client;

2. Seen the original IDs submitted by the client;

3. Witnessed the actual signing of the client on the CRF and SSC;

4. Checked the client’s signatures across all documents and verified against the
IDs presented; and

5. Performed CDD and EDD, if required.

N. Filing of a Suspicious Transaction Report (STR)

1. The BU may file an STR if any red flag is encountered such as, but not limited
to, the following:

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 a. Reluctance to provide any information requested for proper identification;

b. Opening of various accounts under one or more names; and

c. Proximity of the branch, where the client is opening an account, is not within
reasonable distance with the business address of the corporate client.

2. The BU may also file an STR even if no account opening takes place due to
any red flag encountered.

3. Filing of STR, if warranted, shall follow existing policies and procedures on

suspicious transaction reporting.

O. Operational Risk Management

1. SMEBG shall strictly adhere to the Bank’s Operational Risk Management

Framework including Business Continuity and Disaster Recovery.

2. SMEBG shall identify and assess operational risks and evaluate controls in
place to mitigate those risks specific to the department. Identification and
assessment of operational risks will be consistent with the Operational Risk
Management Department’s (ORMD) timeline, policies and procedures.

3. Further, SMEBG recognizes that losses are part of the Bank’s operational risk management.
The department shall report its loss events consistent with the Operational Risk Management
System (ORMS) policies and procedures on such. Reporting of Loss Events shall be through
ORMS, under Loss Events module. The system can be accessed via url:
https://creole/ORMS_Prod.

4. Operational Key Risk Indicators (KRIs) provide insight to emerging risk

exposures. As such, SMEBG shall provide the necessary data to allow
ORMD to prepare reports on KRIs for reporting to the Risk Oversight
Committee (ROC).

5. Issues are occurrences that could happen within the business operations of
the Bank (e.g. weak controls). To prevent the issue from happening, actions
must be created for the issue. Since the Issues and Actions module is part of
the operational risk management framework, SMEBG shall adhere to related
policies and procedures for prompt reporting of issues and implementation of
actions.

Risk Identification Control to Mitigate Risk Owner

AMLA violation due to failure to Observance of clear Relationshi

comply with the required guidelines/standards on safe p Manager
retention period for records and keeping of documents (i.e., 5
documents of closed accounts. years from date of
closure/payments)

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Risk Identification Control to Mitigate Risk Owner
Loss of accomplished vital Observance of clear Relationshi
account opening documents guidelines/standards on safe p Manager
(i.e. CRF, Loan application, keeping of documents (e.g.,
financial documents, valid IDs, designating custodians,
etc.) proper documentation of files
transferred off-site (i.e.,
labels, reference nos., etc.)

Acceptance of clients despite Checking of the IFC exclusion Relationshi

positive findings in the IFC list and Negative File list p Manager
Exclusion list, Blacklist (BL), (internal database)
Negative List (NL), Negative Validation of nationality and
File Information Sheet (NFIS) residence of client to ensure
and/or OFAC List that it is not included in the
OFAC List
System control - automatic
rejection of accounts included
in the system list

Acceptance of fake IDs / Check details of IDs Relationshi

documents due to failure to presented versus details p Manager
conduct proper validation indicated in the accomplished
procedures Loan Application form and/or
CRF
Validation of IDs presented
with third parties (i.e., LTO,
etc.)

Account opening despite Approving officer's review and Relationshi

information/documentary approval signifying the p Manager
deficiencies (e.g., loan following, as applicable:
application information versus (1) documents review;
loan application, etc.) (2) acknowledgment of
responsibility over
completeness, correctness,
propriety of information; and
(3) appropriate procedures
performed.

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Risk Identification Control to Mitigate Risk Owner
AMLA violation leading to legal Comply with policy on EDD Relationshi
liabilities and/or financial loss requirements / validation p Manager
caused by failure to perform procedures / documentary
EDD on new high risk accounts requirements for high risk
opened (e.g., interview, accounts
validation, etc.) Conduct in depth investigation
and validation of information
(i.e., other bank dealings,
company affiliations for
individuals, list of primary
officials/directors with
respective valid IDs shall be
requested
Senior management approval
for opening of high risk
account (i.e., officer with at
least VP rank)

Dealing with unauthorized Verify and record the full Relationshi

trustee, nominee, agent and/or identity of both representative p Manager
representative of the customer and the beneficiary as well as
the nature of their capacity
and duties

Fictitious address of new Checks address in the Loan Relationshi

borrowers/customers Application/CRF versus valid p Manager
ID/proof of billing

Penalties/ Sanctions for Non- Conducts FTF interview of Relationshi

compliance with KYC prospective borrower p Manager
requirements (e.g., FTF Gather basic/required
interview, valid IDs, mandatory documents
information, etc.) Conduct casual interview to
further verify the true and full
identity of the client (company
and owner/s) before starting a
relationship with the client

Signatories contained in the Compare authorized Relationshi

Board Resolution inconsistent signatories per Board p Manager
with the submitted Signature Resolution versus the
Cards submitted signature cards
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 Risk Identification Control to Mitigate Risk Owner

Untagged PEP borrowers Conduct casual interview to Relationshi

resulting in unmonitored determine if client is PEP p Manager
unlawful transactions coursed If PEP, officer's approval (with
through the Bank rank of VP up) prior to
processing loan application of
client
Tagging of clients identified
as PEP
Continuing review of business
relations with customer to
ensure that the loan accounts
are not used for unlawful
activities

P. Enterprise Document Management System (EDMS) – Implementation

TBA

1. This is the central repository of digitized bank documents – both account

opening and transactional documents.

2. All account opening and supporting documents shall be scanned and

uploaded to EDMS by the BU

3. Such documents shall be reviewed and approved by the IUO.

Q. Record Keeping

1. Approved documents for accounts based in Head Office shall be safe kept by
the BU’s Independent Unit based on the Bank’s Record Management Policy.

2. Approved documents for accounts based in satellite offices and lending

centers shall be retained in the vault of the branch nearest the client’s
location.

3. Documents shall be filed accordingly per client.

4. The BU shall ensure that the label of box/folder containing the scanned
documents matches with the EDMS Document Box ID assigned.

III. DETAILED PROCEDURES

A. CIF Creation – can be access via Sales force implementation TBA

Account Specialist (AS)

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 1. Access Finacle CRM, and perform the following:

a. Duplicate checking - to determine if the client has an existing record with the Bank and
screenshot the result

b. Blacklist checking

c. Encode the client’s information as indicated in the CRF;

d. Click “Calculate Risk Rating” to invoke the AML Risk Rating of the account

e. Make sure the account is tagged under the RM’s name and Responsibility Center (RC)

2. Print the screenshots of the following:

a. Results of the duplicate checking

3. Prepare the New Account Opening Requirements Checklist (Attachment 1).

4. Validate the corporate documents submitted. Print the screenshots of the

validation performed (i.e., results of online checking, copies of official receipts
submitted).

5. Conduct the necessary watch list checking (refer to Table 3: Watch List
Checking for New and Additional Account Opening)

6. Accomplish the following portions of the CRF:

a. Indicate the “FATCA Status”

b. Affix name, signature and date on the “CIF Created/Updated by:”

7. Accomplish the following portions of the New Account Opening Requirements

Checklist:

a. Fill out the appropriate boxes based on the documents provided by the customer as
well as the required approvals.

b. Affix name, signature and date on the “Prepared by:” portion

Relationship Manager (RM)

1. Accomplish the following portions of the CRF:

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 a. Method of validation procedures used to verify and ascertain the information provided
by the client (i.e., phone/email verification, online verification of documents, signature
validation)

b. Results on validation conducted

c. Affix name, signature and date on the following:

i. Face to face Certification

ii. CIF Created / Updated by

iii. Relationship Manager

2. Accomplish the following portions of the New Account Opening Requirements

Checklist:

a. Fill out the appropriate boxes based on the documents provided

b. Affix printed name, signature and date on the “Prepared by:” portion of the checklist.

3. Affix signature on the “Relationship Manager” portion of the SSC.

4. Prepare and accomplish the following portions of the Assessment Form (Attachment 6):

a. If the AML Risk Rating of the account is Low/Medium, accomplish up to CDD portion of
the Assessment Form.

b. If the AML Risk Rating of the account is High, accomplish CDD and EDD portions of
the Assessment Form.

c. Affix printed name, signature and date on the RM portion of the checklist

5. Access Finacle CRM and verify the details encoded by the MA/AS with the
documents submitted by the client and submit the CIF to IUO for review and
approval.

6. Send an email to the IUO to request for approval for the CIF.

7. Forward the following documents to IUO for review and approval:

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 a. CRFs of the following:

i. Corporate

ii. Authorized Signatories

b. New Account Opening Requirements Checklist

c. All Valid IDs/supporting documents (original and photocopies)

d. Beneficial Owner Information Sheet

e. Screenshots of the following:

i. Results of duplicate checking conducted

ii. Results of AML Risk Rating of the corporate client computed from Finacle CRM

iii. Results of AML Risk Rating of the Authorized Signatories computed from the AML
Risk Rating Calculator.

iv. Results of watch list checking conducted:

1. Negative list checking from Finacle CRM

2. Negative list checking from the BAP Credit Bureau website

v. Results of the validation conducted (i.e., online verification)

f. SSC

g. Assessment Form

Independent Unit Officer

1. Review and validate all documents forwarded by the RM. Ensure that all the
required documents are submitted and properly accomplished.

2. Compare signature on the Signature Card versus the signatures on the

following:

a. Board Resolution / Partnership Resolution / Secretary’s Certificate;

b. Valid IDs presented;

c. CRF; and

d. Terms and Conditions

3. Affix signature on the “Approved/Verified by” portion of the SSC.

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 4. Access Finacle CRM to review and verify details entered in the system vs.
account opening documents.

5. Affix name, signature and date on the following:

a. Face-to-face Certification portion of the CRF

b. CIF Approved by portion of the CRF

c. Reviewed by portion of the New Account Opening Requirement Checklist

6. Review and validate Assessment Form. Affix name, signature and date in the
“Conducted by” portion of the Assessment Form.

a. If overall assessment is open the account, proceed to item 22.

b. If overall assessment is do not open the account, politely decline the account opening
request of the client.

c. If overall assessment is filing of STR, politely decline the account opening and prepare
the

d. If overall assessment is to conduct EDD, perform and document it in the EDD portion of
the Assessment Form.

7. Secure further approvals, if required. (Refer to Table 4 for the Approving

Authority Matrix of New and Additional Account Opening)

8. Approve the CIF in Finacle CRM and send an email to the RM as notification
of approval.

9. Return approved documents to RM.

B. Elevation/Downgrading of AML Risk Rating

Relationship Manager (RM)

1. Ensure that ALL account opening and supporting documents (i.e., CRFs,
T&C, checklists, screenshots, Assessment Form) are secured.

2. Ensure that the request for elevation/downgrading of AML Risk Rating have
its corresponding approvals.

3. Update the AML Risk Rating in Finacle CRM and submit CIF to IUO for
approval.

4. TBA Send an email to IUO for the request for approval of updates in CIF.

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 C. Scanning of Documents via Enterprise Document Management
System (EDMS) – Implementation

1. Account Specialist (AS) / Relationship Manager (RM)

a. Scan all account opening and supporting documents and upload in the EDMS .

2. Independent Unit Officer

a. Access EDMS and ensure that the scanned documents are correct and the qualities of
the images are clear and readable.

b. Approve the scanning and uploading of documents.

3. Account Specialist (AS) / Relationship Manager (RM)

a. File all account opening forms following the procedures on record keeping.

Special Handling

Money Service Business (MSBs)

i. Money Changer, Remittance and Foreign Exchange

ii. The Dominant Business Unit (DBU) or owning BU that solicited the MSB shall be
responsible for the

iii. CDD and EDD during account onboarding and annual updating.

MSB Client Dominant Business Unit

a. With credit and loan Corporate Banking Group (CBG)
b. Without credit and loan Refer to the Masterlist:
Branch Circular No 2019-094
c. With MPOS settlement account Digital Enterprise and Innovation Group
(but without credit  (DEIG)
and loan)

4. Additional Documentary Requirements

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a. Valid BSP Certificate of Registration - containing the exact address of business
declared by the customer on business license/permit

b. Memorandum of Agreement (MOA) on the responsibility of the MSB in conducting KYC

with RCBC

c. Un-expired AMLC registration (valid for 2 years)

d. MLPP or (AML/CFT) policies/program and measures adopted by the MSB or equivalent

document

e. The MSB CIF shall only be created by the Independent Unit upon the approval of the
BU Segment Head and the BU Group Head.

Tips on identifying MSBs

A Look for key words in the business name such as "currency, exchange, coins,
pawnshop"

B Call the pawnshop and discreetly inquire if they have remittance or foreign exchange
services

C Check MSB list under BSP/ AMLC

D Check the business documents such as Articles of Incorporation (AOI), Mayor’s Permit,
etc. for any indication

E Run client name in Accuity watchlist checking

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IV. ATTACHMENTS
Ref No. Title / Description
1 New Account Opening Requirements Checklist – Corporate
2 Customer Relationship Form (CRF) – Corporate
3 Customer Relationship Form (CRF) – Authorized Signatory
4 Beneficial Owner Information Sheet
5 Written Permission to Bureau of Internal Revenue (BIR)
6 Assessment Form
7 Risk Rating Calculator
8 Validation Guidelines – Documents
8b Validation Guidelines – IDs
9 Sales Officer Virtual FTF Spiels

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