Terminologies used for AML & CFT Program

Sl. #	Abbreviation	Full Form
1	AML	Anti-Money Laundering
2	CFT	Counter/ Combating Financing of terrorism
3	CTR	Cash Transaction Report. CTR threshold amount is Tk 10 lac or above
4	STR	Suspicious Transaction Report. AML circular No.10/2014. In AML Act 2012,suspicious transaction define as : 1) that is not normal or that is  unusual transactions 2) with regard to any transaction there is ground to suspect that the property is the proceeds of a predicate offence & financing of terrorist activities, a terrorist group or an individual terrorist 3) transactions to avoid CTR   (structuring)
4A	Structuring of transaction	The transaction is made to avoid CTR threshold. It is also called unnecessary transactions which is indicator of STR.
5	FIU	Financial Intelligence Unit. It is a central national agency. Its main function is to develop systems  and  deal with the problem of ML and other financial crime
6	FATF	Financial Action Task Force: Its member country is 36. Its main function is to formulate recommendations  for AML & CFT and implementation of the recommendation & conduct research regarding ML & Terrorist financing
7	BFIU	Bangladesh Financial Intelligence Unit. This is an independent Unit   whose responsibilities is to implement FATF recommendation & implementation of AML policy and CFT policy in line with AML & ATA in Bangladesh.
8	CCU	Central Compliance Unit at ABBL Head office. It is independent unit. Function is to implement AML & CFT policy in the Bank & compliance of BFIU instruction & report to BFIU.
9	CAMLCO	Chief Anti Money Laundering compliance Officer (Generally DMD, Operations designate as CAMLCO in AB Bank)  Mr. Sajjad Hussain DMD is now CAMLCO of AB Bank
10	Deputy CAMLCO	Deputy Chief Anti money laundering compliance officer. He is the member of CCU
11	BAMLCO	Branch Anti Money Laundering compliance Officer(Generally Branch Operation Manager designate as BAMLCO in AB Bank)
12	Predicate offence	Number of predicate offences are -27.  For details   see  AML Policy   Predicate offence means: Money or property earned through committing offence mentioned in AML Act-2012.
13	CDD	Customer Due Diligence. CDD should be apply100% in line with AML policy at the time of establishing customer relationship.
14	EDD	Enhance Due Diligence. (more information for more satisfaction or to mitigate risk on ML/TF)
15	KYC	Know Your Customer. Custer should be assessed as high risk or low risk considering the three parts i.e. 1) personal information 2) business information 3) transactional information.
16	KYCB	Know your customer Business
17	Reporting Agency	Number of Reporting Agency is 17.Reporting Agency means the organization who is responsible to report BFIU, Bangladesh Bank for ML & terrorist financing.  For details See  AML Policy
18	APG	Asia Pacific Group on Money Laundering. Its function is to assess the implementation status of Asia region…
19	Egmont Group	Its member country 132 including Bangladesh. It is an international forum consisting of FIU of different countries of the world. Its main function is to deal with money laundering and terrorist financing information. Every member country will get information regarding ML and terrorist financing information from the group.
20	PEPs	Politically Exposed Persons. Foreign high profile persons i.e. individuals who are or have been entrusted with prominent public functions in a foreign country for example Head of state or of govt. senior politicians senior govt. judicial or military officials, senior executive of the state owned corporations, important political party officials, close relation or business relationship with the PEPS and beneficial owner of the PEPS. Enhanced due diligence should be enhanced. PEPS account will not be opened without the consent of senior management.
20A	IPS (Influential persons)/Domestic PEPs	Influential persons’ refers to, “Individuals who are or have been entrusted with prominent public functions, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials.” The following individuals must always be classed as Influential persons: (a) heads and deputy heads of state or government; (b) senior members of ruling party; (c) ministers, state ministers and deputy ministers; (d) members of parliament and/or national legislatures; (e) members of the governing bodies of major political parties; (f) Secretary, Additional secretary, joint secretary in the ministries; (g) Judges of supreme courts, constitutional courts or other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances; (h) governors, deputy governors, executive directors and general managers of central bank; (i) heads of the armed forces, other high ranking members of the armed forces and heads of the intelligence services; (j) heads of state-owned enterprises; (k) members of the governing bodies of local political parties; (l) ambassadors, chargés d’affaires or other senior diplomats; (m) city mayors or heads of municipalities who exercise genuine political or economic power; (n) Board members of state-owned enterprises of national political or economic importance.   Whether an individual is an influential person or not will depend on the prominence or importance of the function that he/she holds, and the level of corruption in the country, the reputation and personal links of the individual and whether he/she has any links to industries that are prone to corruption. If the individual does not hold sufficient influence to enable them to abuse his/her power for gain, they should not be classified as an in
21	FT	Financing of Terrorism
22	ATA	Anti-Terrorism ACT 2009, Amendment was made in 2013
23	UNODC	The United Nations Office on Drugs and Crime
24	NPO	Non-Profit Organization  & NGO : non  govt. organization
25	IMF	International Monetary fund
26	INTERPOL	International Police Organization, based in France
27	KYB	Know Your Business
28	Placement	Physical disposal of the initial proceed derived from predicate offence. It is first stage of money laundering
29	Layering	It is the second stage of money laundering process in which funds are transferred or converted in to another form or creating complex layers of financial transactions to hide the illegal money.
30	Integration	It is the third stage of money laundering. It is this stage at which the money is integrated into the legitimate economic and financial system and is adapted with all other assets in the system. Integration of the "cleaned" money into the economy is accomplished by the launderer making it appear to have been legally earned.   3 ( three )stages of money laundering process Placement Layering Integration
31	MSB	Money Services Business
32	UNSCR	United Nations Security Council Resolutions
33	FATF Recommendation	FATF recommendation is now 40 ( both AML & CFT)Revised standard March 2012
34	Record keeping	As per AML Act 2012, customer record must be maintained 05 (Five) years after closing. Document from opening the account
35	TP	Transaction profile declared by the customer. What type of transaction will make as per business transaction or occupational income .It is transactional history of the customer on monthly basis. TP is obtained to monitor actual transaction with declared transactions.
36	Total AML & BFIU Circulars	AML circulars are 29         . BFIU Circulars-      18 (BFIU Master circular No.10 issued dated 28-12-2014 Master circular means consolidation of all circulars.)
37	Name of  AML & ATA Act	Anti-money laundering Act-2012, effective date: January 16, 2012 AML Act amendment 2015 & Anti-Terrorism (amendment) Act-2013, effective date: June 12, 2013. Both are existing.
38	SHEEL Company/Bank	The bank/ company which  have no registration/ license from the authority but conduct business or have license/registration but no office, staff and activities, they are SHELL Company/Bank. We shall not maintain/establish any correspondent relation with them.
39	Walk–in Customer	The customer who have no account relationship with the Bank but provide services. KYC from such customer to be obtained as per form ANX –B in AML policy
40	ACC	Anti-Corruption Commission
41	APRRG	Asia Pacific Regional Review Group
42	ICRG	International Cooperative Review Group
43	DNFBPs	Designated Nonfinancial Business and professions. Its includes i.e., Real Estate Developer ,Dealer in precious metal and stone, Trust and company as service provider, Lawyer, Notary, others law professionals & Accountant. They are reporting agency. They have to report regarding ML & Terrorist financing to BFIU.
44	UN sanction list	It is the list provided by United Nations Security Council to attach/ freeze the account or inform the listed name for terrorist activities to UNO through BFIU, Bangladesh Bank.
45	OFAC list	Office of Foreign Assets Control:  This list is prepared by US Treasury that enforces economic and trade sanctions against countries and groups of individuals involved in terrorism, narcotics and other disreputable activities.
46	goAML	It is a software system provided by United Nations office of drugs and crime (UNODC). It is uniform software for all Banks for reporting CTR and STR to BFIU, Bangladesh Bank through goAML web link.
47	Beneficial owner	Who is the actual owner of the fund or transaction should be identified in case of individual and in case of company BO is considered 20% to above shareholding & controller share holder. In both cases KYC with full information to be obtained & preserved. Where necessary enhance due diligence to be applied.
48	Risk based analysis	Proper assessment of the relevant risk of ML & CFT.     To identify, assess, find out unknown risk and understand the money laundering and terrorist financing risk to which they are exposed and to take AML /CFT measures
49	SAR	suspicious activity report
50	ARS	Alternate remittance system. Send money not in proper channel. Sometimes money launderer laundering money through ARS from one country to another country.

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