• Mandatory Customer Due Diligence (CDD) is completed for each transaction. Ensure paid to the right beneficiary.
• While Customer Due Diligence (CDD) is done for every transaction, Enhanced Due Diligence (EDD) is done against transactions which questions verification of submitted documents, sets an alarm of origin country of remittance, frequency and size of transaction.
• For such cases extra information and documents are sought from the beneficiary.

• It is mandatory for all the beneficiary to fill up the KYC form or the payment voucher slip and verify for the AML and future references.
• Any transactions exceeding the limits set by the Central Bank of Nepal i.e. 1Million NPR in a single day and by a single receiver is reported as Threshold transaction reporting.
• Any suspicious transactions for i.e. having multiple sender-single receiver and vice versa, not only that but also the irrelevant Identification documents, no physical presence, not having proper source of income, purpose of remittance, huge volume of transactions in specific person, entity or account are reported as Suspicious Transaction Reporting.

• Samsara receives lists of PEPs from Central Bank. Upon receiving these lists names are updated into our existing PEPs in our system.
• Any transaction generated with PEP names are automatically detected. This transaction is then put into Compliance Hold and an auto Notification is sent to Compliance Unit.

Customer Risk is depending upon the customer and company relationship. Customer risk is detected by the segmentation that risk perceptions of the customer’s profile. It is conducted when the customer performs an action that provides no parallel to their profile.

Customer risk Assessment is conducted by the various risk indicators.

• Nature and size of business
• Customer types
• Types of products and services offered to customers,

Bank Deposit: Bank Deposit transaction goes through multiple screening.

Samsara System >> NCHL >> Bank

AUTOMATED

• Each transaction received in Samsara System first passes through PEPs/Sanctioned Lists filtration
• Whilst normal transactions filters through Samsara Payment portal; Prohibited Names, entities and businesses remain blocked.
• Such transactions are then immediately reported to the Central Bank of Nepal (F.I.U Department).
• Financial Information Unit (F.I.U.) is itself a Government Compliance of the Central Bank of Nepal, rest of the other actions will be conducted by the Central Bank of Nepal (F.I.U) Department.

SANCTIONED LIST - UK

Fed in Samsara System

Step 1: Hold Status

Step 2: Compliance Notification

• Transaction automatically put on Compliance Hold and Compliance team notified for review. Such transaction is displayed on Operating System (OS) as Compliance Hold, in the meantime.
• Compliance team also gets an automatic notification via email and SMS

Step 3: Suspicious Hold List

Step 4: FIU Reporting

• Any transaction which falls under the category of Threshold or Suspicious is immediately reported to Central Bank of Nepal (Nepal Rastra Bank) F.I.U. Department via goAML (goaml.fiu.nrb.org.np/TST/Home). We must report to the FIU unit of the Central Bank. Example reporting bep@ssw0rd

Every transaction exceeding the Policy and limits set by Central Bank of Nepal has to be immediately reported to the Central Bank Financial Information Unit (FIU). When the inwarded transaction is getting monitored and if found suspicious or crossing the threshold amount it is then reported via “go AML” to the FIU Department. Go AML is a FIU department official reporting website where we have to report every TTR and STR logging into the site https://goaml.fiu.nrb.org.np/TST/Home

Record Retention 

We have Record Retention policy of about 6 years. Every updated KYC, Payment slips, and Account Deposited, fund transfer documents are physically kept in the Record Files.

Independent Audit/Assurance

Generally the Central bank of Nepal (Nepal Rastra Bank) provides us the instructions, information and updated policy regarding the rules and regulations for us. With reference to its circulars we conduct our performance. We hereby follow the instructions and policy besides that we don’t have Independent Audit. Private Companies in Nepal are not required to complete Independent Audit or Internal Audit as we call it. Samsara does have External Audits once in each Fiscal Year.