Cheque Issue Policy –As per Risk Management procedure based on risk
categorization in our Bank :
Bank has already put in place the Risk categorization of all customers ( New as well as
existing) under our KYC-AML policy .For the purpose of issuance of cheque facility the
same categorization is adopted and the same is produced here.
Money Laundering Risk Categorization
a. Low Risk:
For the purpose of Money Laundering Risk Categorization, Individuals (other than
High Net Worth) and Entities whose identities and sources of wealth can be easily
identified and transactions in whose accounts by and large conform to the known
profile will be categorized as Low Risk subject to other parameters fixed by bank for
categorizing such customers as Low Risk. In case of Low Risk Customers, bank’s
policy ensures that basic requirements of verifying the identity and location of the
customer are met with.
b. High Risk
Customers that are likely to pose a higher than average Money Laundering Risk to
the bank are categorized as Medium or High Risk customers, depending on their
background, nature and location of activity, country of origin, sources of funds and
his client profile, Annual Income / Turnover etc.
Keeping in view above, bank has prepared
a. List of High / Medium / Low Risk Countries (Annexure-G),
b. Risk categorization Table based on Annual Income / Turn over in the account
of the customer (Annexure-G-1) and
c. Risk Matrix Table for Money Laundering Risk Categorization of various types of
customers.(Annexure-G-2).
Bank will revise and suitably modify Annexure-G, G-1 and G-2 on making any
subsequent changes in its Risk Parameters / Perceptions.
Bank will categorize new as well all the existing customers into various Money
Laundering Risk Categories viz. Low, Medium or High Risk on the basis of Money
Laundering Risk Perceptions / parameters as mentioned in Risk Matrix Table
developed by the bank (Annexure-G-2)
Bank will put stamp of Money Laundering Risk Category on Account Opening
Forms / Signature cards at the time of opening accounts and KYC Forms /
Documents obtained at periodical intervals for updation of identification data of the
existing customers.
Bank has developed in-house utility for assigning Money Laundering Risk category
(MLRC) to customers of branches by the system itself by taking into account three
risk parameters such as (i) Country of domicile (ii) Annual Income / Turnover in the
A/c and (iii) Type of product / service availed by the customer with a view to avoid
human intervention and to have uniformity in risk categorization.
Page 1 of 9
Money Laundering Risk Category (MLRC) of customers on the basis of above
parameters is derived and populated / maintained by Data Center in the CBS
System at free code 1 under MIS TAB in CUMM/HCUMM option for their
examination purpose.
Branches will recheck / verify Money Laundering Risk Category (MLRC) assigned
by the computer system keeping in view the fourth parameter i.e. nature of
business and activity of the customer for the reason that this parameter is not
recognized by the computer system, but it is best known to the branches including
subsequent changes if any in it at a later date.
Branches will make suitable corrections if any in Risk Category assigned by the
computer system based on fourth parameter or any other parameters as fixed by
the bank and as deemed fit to them and or give Risk Category at the time of
opening the account at Free Code 2 under MIS TAB in CUMM/HCUMM option.
While downloading report, the higher of the Risk Category of customer either at
Free Code 1 or Free Code 2 will be taken by the system.
Whenever, the customer Risk categorization in KYC-AML policy is modified , the
same will also be modified in this policy automatically. Present categorization is
approved by the Board is KYC-AML policy dated 15.03.2009.
c. Review of Money Laundering Risk Category
Bank will ensure periodical review of Risk Categorization of accounts and the need
for applying enhanced due diligence measures to meet with the Regulatory
requirements. Such review of Risk Categorization of Customers will be carried out
at a periodicity of not less than once in six months as directed by Reserve Bank of
India. Bank will therefore review Risk Categorization in January and July every
year.
Cheque Issuance Policy:
Cheque book may be issued to all account holders in Savings, Current, Cash Credit,
Overdraft. Liimited cheque book ( 10 cheques per year) is issued in No frill accounts by
whatever name called such as Nagrik Bachat Khata and except in accounts of illiterates
either singly or jointly , small accounts etc.
In Savings Bank account 20 free cheque leaves per half year are provided. There is no
restriction on number of cheque books to be issued. Multiple cheque books to account
holders may be issued if specifically requested for by the customers and justified by
operations in the account as per the guidelines given in Book of Instructions, 2012
chapter on “Current Deposits” reproduced as under:
“Multiple cheque books to account holders may be issued if specifically requested for by
the customers and justified by operations in the account.
Personalised cheque books will be issued by those branches which are connected with
Regional Back Office (RBO) of that area.
Page 2 of 9
Branches which are not covered under RBO, will issue cheque books directly to the
customer. Cheque book is issued to the customer or his authorized representative as per
the authority given by the customer, personally at branch. As far as possible cheque book
will not be issued to third party.
When frequent cheque return is observed in customer’s account, customer is cautioned.
No fresh cheque book would be issued. Also, the branch may consider closing of account
at its discretion as per the policy of Dishonour of cheques”.
Bank may at its discretion levy cheque book charges in any or in all types of accounts.
Free cheque book in any product is provided as per the features of the product as
approved by the bank from time to time.
Inter-Sol Charges:
Inter-Sol Charges for Transfer and Clearing transactions are NIL.
Latest service charges are available at link
http://www.bankofbaroda.co.in/servicecharges.asp
******
Page 3 of 9
Annexure – G
List of High / Medium / Low Risk Countries.
High Risk Countries
High Risk Countries
Gambia
Georgia
Grenada
Guadeloupe.
Guatemala.
Guinea Bissau.
Guinea.
Guyana.
Haiti.
Honduras.
Indonesia.
Iran
71
72
73
74
75
76
77
78
79
80
81
82
Nicaragua
Niger.
Nigeria.
North Korea.
Palestine.
Romania.
Rwanda.
SaoTome & Principe.
Samoa.
Senegal.
Serbia & Montenegro.
Seychelles.
13
14
15
16
17
Afghanistan
36
Albania
37
Algeria
38
Angola
39
Anguilla
40
Argentina
41
Armenia
42
Aruba
43
Barbados
44
Benin
45
Bolivia.
46
Bosnia
& 47
Herzegovina.
Burkina Faso.
48
Burundi.
49
Cambodia.
50
Cameroon Republic.
51
Cape Verde.
52
83
84
85
86
87
Sierra Leone.
Solomon Islands.
Somalia.
St. Kitts & Nevis.
St. Lucia.
18
Cayman Islands.
53
Iraq
Jamaica.
Jordan.
Kenya.
Kirghizia/Kyrgyzstan/Kyr
gyz
Republic.
Laos
88
19
Central
African
Republic.
Chad.
Comoros.
Congo.
Cote Dlvoire.
Cuba.
Democratic Republic
of Congo.
Djibouti.
Dominica.
East Timor.
Ecuador.
Estonia.
Ethiopia.
Equatorial Guinea.
Eritrea.
Fiji.
Gabon.
54
Lebanon
89
St.
Vincent
Grenadine
Sudan.
55
56
57
58
59
60
Lesotho.
Liberia.
Lithuania.
Macedonia.
Madagascar.
Malawi
90
91
92
93
94
95
Suriname.
Swaziland.
Syria.
Tajikistan.
Tanzania.
Togo.
61
62
63
64
65
66
67
68
69
70
Mali.
Mauritania.
Martinique.
Mongolia.
Montserrat.
Morocco.
Mozambique.
Myanmar.
Namibia.
Nauru.
96
97
98
99
100
101
102
103
104
105
Tonga.
Turkmenistan.
Turks & Caicos.
Uganda.
Uzbekistan.
Vanuatu.
Vietnam.
Yemen
Zambia
Zimbabwe
1
2
3
4
5
6
7
8
9
10
11
12
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
Medium Risk
Countries
1
2
3
Antigua and Barbuda.
Azerbaijan.
Bahrain.
High Risk Countries
Medium Risk
Countries
12
13
14
Egypt.
El Salvador.
Ghana.
&
Medium Risk
Countries
23
24
25
Philippines.
Poland.
Russia.
Page 4 of 9
4
5
6
7
8
9
10
11
Belarus.
Brazil.
Bulgaria.
Colombia.
Cook Islands.
Costa Rica.
Croatia.
Dominican Republic.
15
16
17
18
19
20
21
22
Low Risk Countries
Kazakhstan
Latvia
Libya.
Moldova.
Panama.
Papua New Guinea.
Paraguay.
Peru.
26
27
28
29
30
31
Low Risk Countries
Slovakia
Thailand
Turkey
Ukraine
Uruguay
Venezuela
Low Risk Countries
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
American Samoa
Andorra.
Australia.
Austria.
Bahamas
Bangladesh.
Belgium.
Bermuda.
Bhutan.
Botswana.
British Pacific Islands.
Brunei.
Canada.
Canary Islands.
Channel Isles.
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
Greece
Greenland.
Guam.
Hong Kong.
Hungary.
Iceland
Ireland
Israel
Italy
Japan
Kuwait
Leeward Islands
Liechtenstein
Luxembourg
Macao.
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
16
17
18
19
20
21
22
23
24
25
26
27
28
29
Chile.
China.
Cyprus.
Czech Republic.
Denmark
Falkland Islands
Faroe Islands.
Finland
France.
French Guinea.
French Pacific Islands
French West Isles.
Germany.
Gibraltar.
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Malaysia
Maldives
Malta.
Mauritius.
Mayotte.
Mexico.
Monaco.
Nepal.
Netherland Antilles.
Netherland W.Indies.
Netherlands.
New Zealand.
Norfolk Islands.
Norway
74
75
76
77
78
79
80
81
82
83
84
85
86
Oman.
Pakistan
Panama Canal Zone.
Portugal.
Puerto Rico.
Qatar.
Reunion Islands.
Saudi Arabia.
Singapore.
Slovenia.
South Africa.
South Korea.
Spain.
Sri Lanka.
St.
Helena
&
Ascension.
St. Pierre & Mizuelon.
Sweden.
Switzerland.
Taiwan.
Trinidad &Tobago.
Tunisia.
U.A.E.
U.K.
U.S.A.
U.S. Pacific Islands.
Vatican City.
Virgin Islands.
India.
Page 5 of 9
ANNEXURE –G-1
RISK CATEGORISATION OF CUSTOMERS BASED ON ANNUAL INCOME
OR TURN OVER IN THE ACCOUNT OF CUSTOMER
HIGH RISK CUSTOMERS
Category / Constitution
Annual Income / Turn Over
Individuals
Rs.100/- Lakhs & above.
Sole Proprietary concerns
Rs.5/- Crores & above.
Partnership firms
Rs.10/- Crores & above.
Limited Companies (both public & private)
Rs.50/- Crores & above.
Trusts
Irrespective of Turnover
Associations, Clubs etc.
Irrespective of Turnover.
MEDIUM RISK CUSTOMERS
Category / Constitution
Annual Income / Turn Over
Individuals
Above Rs.10/- Lakhs but below Rs.100/- lakhs.
Sole Proprietary concerns
Above Rs.1/- Crore but below Rs.5/- Crores.
Partnership firms
Above Rs.5/- Crores but below Rs.10/- Crores.
Limited Companies (both public & Above Rs.10/- Crores but below Rs.50/- Crores.
private)
LOW RISK CUSTOMERS
Category / Constitution
Annual Income / Turn Over
Individuals
Upto and inclusive of Rs.10/- Lakhs.
Sole Proprietary concerns
Upto and inclusive of Rs.1/- Crore.
Partnership firms
Upto and inclusive of Rs.5/- Crores.
Limited Companies (both public & private)
Upto and inclusive of Rs.10/- Crores.
Page 6 of 9
RISK MATRIX TABLE
Annexure G-2
COUNTRY OF DOMICILE / ACTIVITY / NATURE OF BUSINESS / SERVICE / ANNUAL INCOME / TURN OVER
BASED CLASSIFICATION OF CUSTOMERS INTO HIGH RISK, MEDIUM RISK AND LOW RISK
Sr.
No.
01
A
Type of
Custom
ers
02
Country of
Residence /
Counter party
03
High Risk Countries, very
high risk, NCCT – Non
cooperating countries and
territories
(nationality
irrevalent)
Risk
level
Moderate / Medium Risk
Countries,
(nationality
irrevalent)
Low risk / other countries
(nationality irrevalent)
M
04
H
Individu
als
L
Activity / Nature of business / service
Risk
level
Annual Income
Or Turn Over
Risk
level
05
Politically exposed persons (PEPs) i.e. individuals who are
or have been entrusted with prominent public functions in
foreign countries, important political party officials etc.
2.
Individual with high networth.
3.
Non resident Indians.
4.
Individuals dealing in Antiques, Arms, Money Services
Bureaus.
5.
Guardians of estates, executors, administrators, assignees,
receivers etc.
6.
Pooled accounts managed by lawyers, Chartered
Accountants or Stock Brokers on behalf of range of clients.
7.
Persons / individuals with dubious reputation as per public
information available.
Accounts which do not come under low risk or high risk category
may be covered under the medium risk.
06
H
07
Rs.100/- Lakhs and above.
08
H
M
Above Rs.10/- Lakhs but
below Rs.100/- Lakhs.
M
1.
2.
3.
L
Upto and including Rs.10/Lakhs.
L
H
Rs.5/- Crores and above.
H
1.
4.
B
Sole
Propriet
ary
High Risk Countries, very
high risk, NCCT – Non
cooperating countries and
territories
(nationality
irrevalent)
Moderate / Medium Risk
Countries
(nationality
irrevalent)
Low risk / other countries
(nationality irrevalent)
H
1.
2.
Individuals other than high network.
Individuals salaried person with clear salary structure.
Individual of low income group with small turn over in the
account.
All borrowal customers (other than high risk categories)
where due diligence is done at the time of sanctioning
facility.
Entities dealing in Antiques, Arms, Money Services Bureaus
(entities and not its employees)
Pooled accounts managed by lawyers, Chartered
Accountants or Stock Brokers on behalf of range of clients.
M
Accounts which do not come under low risk or high risk category
may be covered under the medium risk.
M
Above Rs.1/- Crore but
below Rs.5/- Crores.
M
L
All borrowal customers (other than high risk categories) where due
diligence is done at the time of sanctioning facility.
L
Upto and including Rs.1/Crore.
L
Highest
of
4, 6 & 8
09
Page 7 of 9
Sr.
No.
Type of
Customers
01
02
C
D
Country of
Residence /
Counter party
03
High Risk Countries, very
high risk, NCCT – Non
cooperating countries and
territories
(nationality
irrevalent)
Risk
level
Moderate / Medium Risk
Countries
(nationality
irrevalent)
Low risk / other countries
(nationality irrevalent)
High Risk Countries, very
high risk, NCCT – Non
cooperating countries and
territories
(nationality
irrevalent)
M
Moderate / Medium Risk
Countries
(nationality
irrevalent)
Low risk / other countries
(nationality irrevalent)
M
04
H
Partnership
Public &
Private
Limited
Companies
L
H
L
Activity / Nature of business / service
Risk
level
05
Firms With sleeping partners.
Entities dealing in Antiques, Arms, Money Services
Bureaus (entities and not its employees)
3.
Pooled accounts managed by lawyers, Chartered
Accountants or Stock Brokers on behalf of range of
clients.
Accounts which do not come under low risk or high risk
category may be covered under the medium risk.
06
H
M
Above Rs.5/- Crores but
below Rs.10/- Crores
M
All borrowal customers (other than high risk categories) where
due diligence is done at the time of sanctioning facility.
1.
Companies whose shareholders are family members.
2.
Entities dealing in Antiques, Arms, Money Services
Bureaus (entities and not its employees).
3.
Pooled accounts managed by lawyers, Chartered
Accountants or Stock Brokers on behalf of range of
clients.
Accounts which do not come under low risk or high risk
category may be covered under the medium risk.
L
Upto and including Rs.5/Crores.
Rs.50/Crores
and
above.
L
1.
2.
1.
2.
3.
Current Account customers which are listed companies,
regulated entities etc. where sufficient knowledge in
public domain is available.
All borrowal customers (other than high risk category)
where due diligence is done at the time of sanctioning
facility.
Government Departments and Government owned
companies, regulators and statutory bodies etc.
H
Annual Income
Or Turn Over
Rs.10/above.
07
Crores
Risk
level
and
08
H
Highest
of
4, 6 & 8
09
H
M
Above Rs.10/- Crores but
below Rs.50/- Crores.
M
L
Upto
and
including
Rs.10/- Crores.
L
Page 8 of 9
Sr.
No.
Type of
Customers
01
02
Country of
Residence /
Counter party
03
Irrespective of country
Residence.
Risk
level
of
Trusts
04
H
H
E
Irrespective
Residence.
of
country
of
H
Activity / Nature of business / service
Risk
level
05
Trust
Irrespective of nature of activity/business.
Pooled accounts managed by professional intermediaries on behalf
of entities like mutual funds, pension funds etc.
Irrespective of nature of activity/business.
06
H
Associations, Clubs, Charities, NGOs receiving donations.
Irrespective of nature of activity/business.
H
H
Annual Income
Or Turn Over
07
Irrespective
Turnover
Irrespective
Turnover
Irrespective
Turnover
Risk
level
of
08
H
of
H
of
H
Highest
of
4, 6 & 8
09
Association
s, Clubs etc.
F
NOTE :-
First categorize customers into high risk, medium risk and low risk on the basis of column “3”, “5” & “7” separately in
column No.”4”, “6” & “8” respectively. Then assign risk category to the customer which is highest of “4”, “6” & “8” in Column No.’9’.
Page 9 of 9