Circulars/Notifications - Exchange Policy Department  
 EPD Circular Letter No. 08 /EPP.24 (01) EC-2008

September 29, 2008

The Chief Executives of
All Exchange Companies

Dear Sirs/Madam,

Compliance of SBP Rules & Regulations

Attention 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 spirit.

In 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.

While 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).

Please ensure strict compliance of the above instructions.

Yours faithfully,

(Syed Samar Hasnain)

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