Dear Editor,
There seems to be a discrepancy in the Bank of Guyana (BOG) Supervision Guidelines relevant to Anti-Money Laundering (AML) verification requirements, which is creating some confusion among banks and friction with customers.
I believe it is a very simple matter that the Guyana Association of Bankers (GAB) and the Guyana Revenue Authority (GRA) seem to have overlooked or are taking too long to comprehensively address, resolve and seek to have our BOG guidelines amended and updated accordingly.
On September 19, 2018, I had an intense discussion with the Senior Manager of one of the Commercial Banks operating in Georgetown regarding the cited discrepancy. The bank is one under which my banking career blossomed for over 15 years. I have maintained cordial customer relations with that bank and most of my former peers even after I changed careers a few years ago. That bank is the only international brand that kept operating here in Guyana while others sailed off during Guyana’s economic crunches in the 1980s.
The discrepancy to which I refer is under Supervision Guideline No. 13, part 4.2.4, Specific Identification and Verification Procedures, (a) (l) (page 31 for ease of reference).
Part 4.2.4 (a) Natural Persons (individual Customers) reads as follows: “A financial institution should obtain relevant information on the identity of its customers and seek to verify some of the information on a risk basis, through the use of reliable, independent source documents, data or information to prove to its satisfaction that the individual is who that individual claims to be.”
The requirement under paragraph (a), item (l) requires “taxpayers identification number”. The sentence is stated as ‘taxpayers identification number (TIN) certificate. Now that notation is creating havoc. I, like many others even within the banking sector, believe a “virgule” (/) was inadvertently omitted and overlooked between taxpayers identification number and (TIN) certificate, since there are other authenticating documents that bear GRA TIN numbers.
There is chaos regarding its intent and interpretation.
A particular bank is strictly demanding an original TIN certificate. No other GRA issued original documents with a TIN number are being accepted. No Guyana Driver’s Licence, which is numbered with the TIN is being accepted, although the Driver’s Licence with special security features is issued by GRA. No original Certificate of Compliance bearing the TIN number as issued by GRA is being accepted. No original Individual Income Tax assessment document bearing the TIN number and issued by the GRA is being accepted.
All of the above are authentic GRA issued documents bearing TIN numbers, which I submit should be acceptable forms of TIN verification. Because, it is the TIN number which is the focus and proof that the named customer is associated with that TIN.
I found the rejection of the newly issued Guyana Driver’s Licence for verification of the TIN number particularly absurd by one particular bank, while it is being accepted by others where I have already complied with AML verification.
So had I been travelling from Annai or Karasabai to do my verification, my efforts to comply with the BOG AML guidelines would have been denied if my huge paper-based TIN certificate had blown away along the dusty trail and down a deep ravine, or otherwise been lost, although I have my newly issued and security laced Guyana Driver’s Licence with GRA TIN number. The bank would instruct me to get a new TIN certificate. A replacement TIN certificate costs GYD$5,000, which for the average citizen is still a hard blow, right in the solar plexus.
I trust that the Directors of the BOG, GAB and Commissioner General of the GRA will revisit and cause amendments to be made to that particular section of the AML verification requisites and/or GRA policy, so as to create a more compliant friendly environment for banking customers in this country.
Yours faithfully,
Orette Cutting
