MORNBFI Vol. 1 - Planters Development Bank

§§ 4806Q.2.e.1.a. - 4806Q.2.h.11.12.31and its own MLPP including the face-to-facecontact requirement to establish theexistence of the ultimate customer and hasin its custody all the minimum informationand/or documents required to be obtainedfrom the customer; and2) The relying covered institution shallhave the ability to obtain identificationdocuments from the third party upon requestwithout delay.(Circular No. 706 dated 05 January 2011)§ 4806Q.2.e.1.b. Third party is an FIoperating outside the Philippines that isother than covered institutions referred toin Subsec. X806.2.e.1.a but conductsbusiness operations and activities similarto them. All the contents required in thesworn certification mentioned in Subsec.4806Q.2.e.1.a shall apply with theadditional requirement that the laws of thecountry where the third party is operatinghas equal or more stringent customeridentification process requirement and thatit has not been cited in violation thereof. Itshall, in addition to performing normal duediligence measures, do the following:1) Gather sufficient information aboutthe third party and the group to which itbelongs to understand fully the nature of itsbusiness and to determine from publiclyavailable information the reputation of theinstitution and the quality of supervision,including whether it has been subject tomoney laundering or terrorist financinginvestigation or regulatory action;2) Document the respectiveresponsibilities of each institution; and3) Obtain approval from seniormanagement at inception of relationshipbefore relying on the third party.(Circular No. 706 dated 05 January 2011)§ 4806Q.2.f. Private banking/wealthmanagement operations. These services,which by their nature involve high measureof client confidentiality, are more open tothe elements of reputational risk especiallyif the customer identification process is notdiligently followed. Covered institutionstherefore shall endeavor to establish andrecord the true and full identity of thesecustomers and establish a policy on whatstandard of due diligence will apply to them.They shall also require approval by asenior officer other than the privatebanking/wealth management/similaractivity relationship officer or the like foracceptance of customers of privatebanking, wealth management and similaractivities.(Circular No. 706 dated 05 January 2011)§ 4806Q.2.g. Politically exposed personA covered institution shall endeavor toestablish and record the true and fullidentity of PEPs as well as their immediatefamily members and the entities related tothem and establish a policy on whatstandard of due diligence will apply to themtaking into consideration their position andthe risks attendant thereto.(Circular No. 706 dated 05 January 2011)§ 4806Q.2.h. Correspondent bankingBecause of the risk associated with dealingwith correspondent accounts where it mayunknowingly facilitate the transmission, orholding and management of proceeds ofunlawful activities or funds intended tofinance terrorist activities coveredinstitutions shall adopt policies andprocedures for correspondent bankingactivities and designate an officerresponsible in ensuring compliance withthese policies and procedures. A coveredinstitution may rely on the customeridentification process undertaken by therespondent bank. In such case, it shallapply the rules on third party relianceunder Subsec. 4806Q.2.e.1., treating therespondent bank as the third party asdefined therein. In addition, thecorrespondent bank shall:Manual of Regulations for Non-Bank Financial InstitutionsQ RegulationsPart VIII - Page 15