of Exchange Companies is invited to SBP instructions issued
from time to time on the minimum criteria to be observed
with respect to proper documentation of transactions,
maintenance of proper AML / KYC standards, reporting of
business transaction and other activities of exchange
companies. In this connection, we expect Exchange Companies
to exercise utmost diligence while dealing with their
customers in terms of maintaining KYC standards, establishing
bonafide and satisfying themselves with the beneficial
ownership of transactions routed through them. Despite
clear instructions, it has been noticed that some companies
are not following SBP instructions in true letter and
light of the above, it is advised that each Exchange Company
would revisit the compliance status of each of its business
location including branches, CEBs, franchises, payment
booths with respect to documentation of transactions and
adherence to SBP rules and regulations through all available
means including on-site visits of business locations.
Accordingly all Exchange Companies shall submit a certificate
to this effect by October 31, 2008, duly signed by the
CEO and all Directors of the company confirming therein
that the company management is satisfied with the compliance
status of each of its business location.
conducting the above exercise, cases where the compliance
status is found below the requisite levels, the Exchange
Companies are advised to immediately furnish a detailed
report about each of such business location immediately
to this Department. It may be clarified that such reporting
shall not debar an Exchange Company to take appropriate
actions as per related rules and regulations and covenants
of governing agreement(s).
ensure strict compliance of the above instructions.