Frequently asked questions

1. What are the immediate AML steps a private bank in Bangladesh should take?

Start with a risk assessment, update customer due diligence procedures, put automated transaction monitoring in place or refine existing rules, and ensure timely STR submissions to the BFIU when required.

2. Does a US privacy law such as the CCPA automatically apply to a Bangladeshi bank?

Applicability depends on the bank's data processing activities and whether it targets or processes the personal data of residents covered by that law. Map your data sources and recipients and seek jurisdiction-specific advice.

3. How should firms screen for sanctions across multiple jurisdictions?

Use consolidated sanctions lists, maintain a documented screening policy, apply risk-based enhanced due diligence, and escalate matches for legal review before continuing a relationship or transaction.

4. When is a private trust company appropriate?

A private trust company can be appropriate where families require bespoke governance, centralized trustee services or confidentiality, subject to local regulatory and tax considerations.

5. What triggers mandatory reporting to the BFIU?

Suspicious transactions or activity that meet statutory thresholds and indicators should be reported. Maintain robust internal reporting lines and clear criteria for escalation.

6. How do cross-border tax concerns interact with structuring for wealth management?

Cross-border structures must be assessed for withholding, transfer pricing and local tax reporting. Coordination with tax counsel is essential at the structuring stage.