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AML & CFT Program

 

Implementation of AML and CFT Program PT Bank Maybank Indonesia Tbk.

Considering the increasing complexities of banking products, activities and information technology, the risk of banks being used for committing crimes of money laundering and financing terrorism increases.

In order to prevent the bank from being targeted by money laundering and terrorist financing, the bank is subject to:

  1. The Law of The Republic of Indonesia Number 8, Year 2010, concerning The Prevention and Eradication of The Crime of Money Laundering
  2. The Law of The Republic of Indonesia Number 9, Year 2013, concerning The Prevention and Eradication of The Crime of Finance of Terrorism
  3. OJK regulation No.12/POJK.01/2017 dated March 21, 2017 concerning The implementation of Anti-Money Laundering and Combating the Financing of Terrorism Program in Financial Services Sector.

In order to increase the effectiveness of the implementation of AML & CFT Principles, the bank has established a system and infrastructure based on 5 pillars.

 

5 Pillars of Implementation of AML and CFT Program :

Active Supervision of The Board of Directors & Commissioners

Active Monitoring of Director

  1. Ensuring the Bank has policies and procedures for AML & CFT Program
  2. Recommends policies and procedures of AML & CFT Program to the Board of Commissioners
  3. Ensuring that the implementation of AML & CFT Program is based on established policies and procedures
  4. Establishing special units assigned to implement AML & CFT Program and/or appointing an officer duly responsible for AML & CFT Program at the Head Office
  5. Supervise the compliance of work units in implementing AML & CFT Program
  6. Ensuring the branch offices are required to have employees or officers who supervise implementation of AML & CFT program
  7. Ensuring the branch offices with high business complexity to fulfill the obligations referred to in item 6 above and be separated from the work unit which implements the policies and procedures of AML & CFT program.
  8. Ensuring that policies and procedures for AML & CFT Program are in line with changes and developments in products, services and information technology of the Bank as well as in line with development in modus for money laundering or terrorist financing; and
  9. Ensuring that all employees, particularly employees of related work units and new employees have participated in ongoing training related to AML & CFT Program

In implementing active monitoring of Directors that The Compliance Director has the duty and responsibility as follows:

  • Menetapkan langkah-langkah yang diperlukan untuk memastikan Bank telah memenuhi ketentuan Bank Indonesia mengenai Program APU dan PPT dan peraturan perundang-undangan lainnya yang terkait,
  • Provide for measures necessary to ensure Bank comply with the provisions of Bank Indonesia Program on AML and CFT policy and other relevant
  • Monitor the implementation of the special unit assignments and/or bank officials responsible for the implementation of APU and PPT Program,
  • Recommends to the President Director who will lead the special unit or bank officials responsible for the implementation of AML & CFT Program,
  • Approving Suspicious Transaction Reports (STR), and
  • To establish and evaluate transactions that require the approval of senior officer.

Active Monitoring of Commisioners

Active supervision by the Board of Commissioners at minimum shall include:

  1. Approval of policies and procedures of AML & CFT Program Implementations; and
  2. Monitoring the execution of the assigned responsibilities of the Board of Directors in implementing AML & CFT Program that including Bank commitment to The Bank Indonesia

Policies and Procedures

Bank has established policies and procedures as follows:

  1. Request of information and documents customer (Customer Due Diligence/CDD and Enhance Due Dilligence/EDD)
  2. Beneficial Owner
  3. Document verifications
  4. Simplified CDD
  5. Implementations of CDD by a third party
  6. Risk Based Approach (RBA) implementation
  7. Provisions concerning high risk areas and Politically Exposed Person (PEP)
  8. Walk in Customer handling
  9. Updating of customer data and transaction monitoring
  10. Cross Border Correspondent Banking (CBCB)
  11. Payable Through Account (PTA)
  12. Fund Transfer
  13. Monitoring AML/CFT implementation of domestic branch and overseas branch
  14. Management Information System
  15. Providing data and information
  16. Blocking and confiscation
  17. Termination and transaction rejection
  18. Human Capital and training employee program
  19. Administration of document
  20. Regulator reporting
  21. Internal control
  22. Know Your Employee (KYE)

Internal Control

To provide effective examination of Implementation of AML and CFT, bank ensures that AML and CFT Program will be monitored and reviewed by Internal and External Audit regularly.

Manajement Information System 

In supporting the monitoring activity of Customer’s profile and transaction in order to run effectively, an information system has been created and developed that is able to monitor, identify, analyze, and supply the report with the characteristic of transaction based on risk made by a Customer.

Training and Human Resource Development

To ensure an expert skill level and better understanding of duties for all staff, bank provides continuing training of AML and CFT which includes:

  1. Implementing laws and regulations as well as policies and procedures associated with AML and CFT Program
  2. Knowledge of typologies of money laundering or terrorist financing; and
  3. Raising the awareness roles and responsibilities of employee to assist in the eradication of money laundering or terrorist financing
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