Circulars/Notifications - Banking Policy & Regulations Department  
 BPRD Circular Letter No. 18 of 2019
July 17, 2019

The Presidents / Chief Executive Officers
All Banks

Dear Sir / Madam,

Standard Operating Procedures (SOPs) to Facilitate and Streamline
Account Opening Process of Politically Exposed Persons (PEPs)

In order to ensure fair and equitable treatment of bank’s customers referred to as Politically Exposed Persons (PEPs), the State Bank of Pakistan (SBP) has devised the following Standard Operating Procedures (SOPs) to facilitate and streamline account opening process without compromising due diligence requirements prescribed under AML / CFT regime:

(i) The bank upon receiving account opening request from PEP shall ensure that the basic requirements like Account Opening Form/Specimen Signature Card and Biometric Verification of the customer are completed on the same day;

(ii) on the same day, the person shall be guided regarding specific requirements / formalities required for opening of an account. Further, the concerned branch shall report the details of the request made by PEP to the focal person nominated by the bank in line with instructions of BPRD Circular Letter No. 27 of 2015;

(iii) within two working days of receipt of documents from PEP, the bank shall inform him / her in writing, the deficiencies, if any, in the documents or further clarifications required;

(iv) once the deficiencies have been removed by PEP and all due diligence requirements have been satisfactorily completed, the account shall be opened by the bank within two working days;

(v) in case the bank decides to refuse any request for account opening, within two working days, the reasons of refusal shall be conveyed in writing to the applicant in line with the instructions of BPRD Circular Letter No. 14 of 2017;

(vi) in line with abovementioned Circular, the bank shall maintain separate files of all approved and rejected cases of PEPs. SBP inspection team during inspection of the bank may review the record especially the rejected cases;

(vii) the bank shall report the following details of rejected cases of PEPs to the Director, Banking Conduct & Consumer Protection Department of SBP on monthly basis within 7 days of the close of every month;

A. Details of Banking Services / Facilities Refused to PEPs (Politicians only) during the month:

Name & Position of PEP
(Politicians Only)
Type of Banking Service / Facility
Requested along with the Date
Reasons for Refusal along
with the Date of Letter

B. Details of Banking Services / Facilities Refused to PEPs (Other than Politicians) during the month:

Name & Position of PEP
(Other than Politicians)
Type of Banking Service / Facility
Requested along with the Date
Reasons for Refusal along
with the Date of Letter

(viii) Any PEP having grievance / disagreement with bank’s decision may contact the bank’s focal person nominated for the purpose. Banks have already been advised to prominently display the contact details of their and SBP’s focal person for PEP’s at their branches. The contact details of focal persons appointed by banks and SBP are also available at SBP website

(ix) The focal person shall guide PEP and ensure early resolution of the issue in light of applicable policies, rules & regulations.

(x) If the grievance of PEP is not resolved within 15 days after registration of his / her complaint with bank’s focal person or if he / she is not satisfied with the conclusion, then he / she may directly contact the focal person appointed by SBP.

(xi) The bank's focal person shall maintain a proper MIS for all requests/grievances received from PEPs (allocating unique diary number) in order to monitor its progress at different stages.

(xii) The focal person shall be responsible to facilitate PEPs and monitor the progress of their request.

(xiii) The bank shall provide special assistance to PEPs and treat them with respect and due care during the account opening process.

2. Banks are advised to immediately disseminate the abovementioned instructions down the line to all of their branches and business locations to ensure compliance of the same in letter and spirit. Any non-compliance would be strictly dealt with penal provisions of Banking Companies Ordinance, 1962.

3. Please acknowledge receipt.


Yours truly,


(Syed Imran Ali)
Additional Director

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