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Interview with N. M. Eftakharul Alam Bhuiya, Head of Legal & Compliance and Company Secretary, Nagad.

N. M. Eftakharul Alam Bhuiya has broad legal background with more than twelve years of experience in corporate-commercial law. He has obtained his LL.B (Hons) and LL.M in Commercial Law from the University of Dhaka, Bangladesh. He is an enrolled Advocate of the Supreme Court of Bangladesh. Prior to starting practicing, he worked as acting Head of Legal Department, bKash. He has also worked as in-house Legal Counsel for Grameenphone Ltd. and other reputed companies and law firms.

Fintelekt: As a new company in Bangladesh what were the main considerations while setting up the AML compliance governance framework?

Eftakharul: Our Company (Nagad) has launched commercially very recently on 26th March 2019. Since it has just launched recently, my primary objective is to remain compliant from the very beginning. Hence, we want to comply with the applicable laws and regulatory guidelines, monitor transactions regularly, introduce risk-based approach to the risk factors, implement an internal AML-CFT policy in line with applicable laws and the regulatory guidelines.

With financial inclusion being one of the goals of the Company, are there any specific AML compliance challenges that you are encountering or expect to encounter? How do you plan to address these challenges?

In Bangladesh, still 66% of the total population are out of the banking transactions. Hence, financial inclusion is one of our goals and over-the-counter transactions (using someone else’s digital account) are a common phenomenon in this industry where customer’s due diligence cannot be performed properly. Therefore, there is a chance of money laundering using someone else’s digital account. To avoid such risk, we are encouraging self-registration to ensure that all the customers (users) have their own account when they are availing our services. We have introduced self-registration along with registration from agent or other channel partners which is a much more effective and efficient solution. Further, this solution has been introduced for the first time in Bangladesh for this industry.

Going forward what would be your priorities as the AML Compliance Head of your Company?

Going forward, we have several priorities:  (a)  From the very beginning we have implemented integration with national election commission database to cross-verify the identity of each customer with the said database, (b) we are working on raising system-generated red flag issues, (c)  and we are going to screen against the UN Sanction List and the Ministry of Home Affairs’ Sanction

List during registration and at the time of transaction, (d) we have also formed the function Compliance Committee, which is a cross-functional team to maintain the risk register and to address the issues accordingly, (e) we have a vast plan to conduct training for the employees and channel partners, (f) conduct awareness session for the customers through SMS, IVR, TVC, print media, and other means, (g) investigate and field visit to the concerned area, etc.

How did the FCAP program by Fintelekt help you in your objectives?

The FCAP of Fintelekt has helped me in many respects. The resource persons were really experienced in this field, their experience and presentations gave me many insights in which I am planning to introduce within my organization. Again, the participants were from different countries and organizations. Therefore, their experience and way of addressing any issue was invaluable. I look forward to engage with Fintelekt in the future.