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The Bank must establish clear agent due diligence policies. Minimum contents must include methods of identifying Agents, initial due diligence, regular due diligence checks to be performed at specified periods, check list of early warning signals, and corrective actions to ensure proactive agent management.
2.
The Bank must clearly specify roles/responsibilities of functions/departments within the Bank with regard to agent management in the agent due diligence procedures.
3.
The Bank must ensure that proper monitoring processes for AML/CFT and combating embezzlement and financial fraud in the area of Agent Banking are in place. The necessary actions to be taken by Agents in this regard must be communicated to the Agents, and the Agents’ compliance must be monitored regularly.
4.
Due Diligence must, at a minimum, cover the following:
a.
Verification of legal status of the Agent;
b.
Verification of address and location of all prospective Agents;
c.
Establishing that there is no conflict of interest between the Bank and the Agent;
d.
Verification of the adequacy of the prospective Agents’ resources for Agent Banking business, including financial and infrastructure resources (especially information security, technology and personnel);
e.
Agent’s trustworthiness and likelihood of good behavior;
f.
Clear credit history of Agent with a licensed credit bureau;
g.
The Bank’ approval for the Agent’s procedures to ensure compliance with security risk management processes; and
