This article is the part of series on
1. AML/CFT – A Preventive Vigilance Tool.
2. Key Components of the Post Office Savings Bank AML/CFT Framework
3. AML/CFT – A Preventive Vigilance Tool: Understanding FIU-IND and PMLA
Understanding SAS-AML
The SAS-AML Alert system is a critical component in our fight against financial crimes, particularly money laundering. Using the Statistical Analysis System (SAS) version 7.1, powered by the FIU 2.9.1 Utility, this software serves as an essential AML compliance solution for risk management, fraud detection, and customer analytics, enabling extensive data analysis to identify potential threats.
Accessing the SAS-AML Portal
To access the SAS-AML portal, please log in using the following URL:
http://sas.fsi.indiapost.gov.in:7980/SASComplianceSolutionsMid
Processing SAS-AML Alerts
Upon receiving SAS-AML alerts, the Circle Nodal Officer (C.O/CBS-CPC) is tasked with analyzing each alert and confirming its ownership. Any alerts misrouted will be redirected to their original circles.
Regions have been provided with user credentials to export alerts for specified periods into Excel. This information is then communicated to Divisions for further verification.
The Divisional Head will assess the alerts and direct them to either the HO/SO for validation or transfer them to the relevant IP/ASP for verification based on the alert’s severity.
Transaction Verification
The Postmaster plays a pivotal role in verifying the nature of each transaction:
- Internal Transfers, Reversals, or Cheques: Report to the Divisional Head with accompanying remarks.
- Cash Transactions: Verification follows the guidelines outlined in SB Order 12/2023.
Risk Categorization of Alerts
Alerts are categorized based on the amount involved in the transaction at the time of credit or debit, as follows:
- Low Risk: Amount up to ₹50,000
- Medium Risk: Amount exceeding ₹50,000 and up to ₹10 lakhs
- High Risk: Amount exceeding ₹10 lakhs or activity in an inactive/silent account.
Due Diligence and KYC Norms
After categorizing the alerts, the following Customer Due Diligence (CDD) and Know Your Customer (KYC) checks should be performed:
- Low Risk: ID Proof/KYC Document, Address Proof; all documents must be self-attested.
- Medium Risk: Same as low risk, plus PAN Card or a letter from the IT authority quoting PAN details or Form 60/61. Transactions involving deposits/withdrawals of ₹5 lakhs and above require closer scrutiny.
- High Risk: Comprehensive checks including ID Proof/KYC Document, Address Proof, PAN documentation, proof of source of funds, and verification of similar transaction history over the last year.
Reporting and Follow-Up
Postmasters must forward alert details along with their verification reports to the Divisional Head, who is responsible for updating the risk category in Finacle. Verified alerts will then be routed to the Circle Office for further action.
Verification must be based exclusively on Post Office records and system transaction reports. It’s crucial that the account holder is not directly contacted during Prevention of Money Laundering Act (PMLA) verifications.
If any discrepancies or gaps are identified, these should be verified through the relevant IP/ASP. After due diligence, verified reports will be sent to the Circle Office.
Monitoring and Compliance
The Circle Nodal Officer is responsible for day-to-day monitoring and closing alerts in the SAS-AML System. Timely closure is essential; all Currency Transaction Reports (CTRs) from the previous month must be finalized by the 10th of the following month to avoid penalties as stipulated in the PMLA 2002.
Additionally, all Suspicious Transaction Reports (STRs) detected in the SAS-AML system must be closed or reported within 7 days of their occurrence.
In the upcoming article, we will explore the process of closing alerts in the SAS-AML software, detailing the systematic approach for verifying and addressing alerts to ensure compliance and mitigate risks. This process is vital for maintaining the integrity of our anti-money laundering efforts and supporting effective financial vigilance.