Roles and Responsibilities of the Principal Officer
Banks must take reasonable steps to give its PO, or any person to whom the PO’s duties have been delegated, access to any information it has about the customer or transaction(s). The PO will support and co-ordinate senior management focus on managing the money laundering/ terrorist financing risk in individual functions within the bank. The bank should make the PO responsible for the following
- Reporting Requirements: To ensure that the reporting obligations under PMLA are met. The PO should also ensure that all important issues are reported to the senior management of the bank on a periodic basis.
- Review the adequacy of AML systems and controls: Oversight of the implementation of the bank’s AML/ CFT policies and procedures, including the operation of the risk-based approach, is the responsibility of the PO, under delegation from senior management. It must be ensured that appropriate monitoring processes and procedures across the bank are established and maintained.
- Liaison with various stakeholders/ parties: The PO should maintain liaison with various stakeholders/parties, such as regulators (internal and external), FIU-IND, IBA and other member banks. Specifically, the PO should ensure that any queries raised by the regulators are answered within the stipulated deadlines.
- Staff awareness – provision of relevant information to staff: The PO is responsible for oversight of the bank’s compliance with its requirements in respect of staff training, including adequate arrangements for awareness and training of employees. Although this is a bank-wide responsibility, there may be some delegation to appropriate persons/ functions in business areas. The PO is responsible for ensuring that the training is offered, that the standards and scope of the training are appropriate, and that appropriate records are kept. The bank should also make the PO responsible to keep a track of developments in the AML environment at national and international level. The PO should also disseminate relevant information to the business heads and staff in a timely manner.