State Bank of Pakistan (SBP) has asked banks/ DFIs to conduct "enhanced" due diligence, including obtaining senior management approval while establishing relationship with non-governmental organisations (NGOs)/ not-for-profit organisations (NPOs) and charities to ensure that these accounts are used for legitimate purposes and the transactions are commensurate with the stated objectives and purposes.

In its circular letter No. 04 of 2012 dated March 12, relating to Prudential Regulations M-1 to M-5, the Central Bank said, the instructions have been issued to protect banks/ DFIs from risks arising out of money laundering and terrorist financing activities, implementation and strict compliance of the following needs to be ensured.

SBP said that the accounts should be opened in the name of relevant NGO/ NPO as per title given in its constituent documents. The individuals who are authorised to operate these accounts and members of their governing body should also be subject to comprehensive customer due diligence (CDD).

Banks/ DFIs should ensure that these persons are not affiliated with any proscribed entity, whether under the same name or a different name.

In case of advertisements through newspapers or any other medium, especially when bank account number is mentioned for donations, Banks/ DFIs will ensure that the title of the account is the same as that of the entity soliciting donations. In case of any difference, immediate caution should be marked on such accounts and the matter should be considered for filing Suspicious Transaction Report (STR).

Personal accounts shall not be allowed to be used for charity purposes/ collection of donations.

All existing relationships of NGOs/ NPOs should be reviewed by June 30, 2012 to ensure that these organisations, their authorised signatories, members of their governing body and the beneficial owners are not linked with any proscribed entities and persons, whether under the same name or a different name. In case of any positive match, Banks/ DFIs should consider filing STR and/ or take other actions as per law.