जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग,

प्रधान कार्ाालर्, प्लाट न०-4, सेक्टर-10, द्वारका, नई दिल्ली-110075

CREDIT TRANSACTIONS MONITORING CELL, FRAUD RISK MANAGEMENT DIVISION,
HEAD OFFICE, PLOT NO. 4, SECTOR 10, DWARKA, NEW DELHI-110075

TO ALL OFFICES Date: 21-03-2024

FRMD CIRCULAR NO. 25 / 2024

MONITORING OF CREDIT TRANSACTIONS IN CURRENT & SAVINGS

ACCOUNTS

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As we witness a significant surge in digital transactions, it is imperative to address the
corresponding rise in digital fraud instances that threaten the security and trust of
consumers and businesses. From phishing scams and identity theft to sophisticated
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malware attacks and fraudulent transactions, the spectrum of digital frauds is vast and
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evolving. Financial institutions play a pivotal role in ensuring the integrity of digital
transactions by implementing stringent authentication protocol, monitoring suspicious
activities through velocity checks and promptly addressing security breaches. So far,
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the focus of our Bank has always been to safeguard our customers against fraud
attacks/ attempts, however, there have been cases wherein it has been observed that
the customers of the bank are deceiving and defrauding other customers/ citizens
resulting in multiple credit transactions of small amounts in their account and
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subsequent debit transactions in large amount within shorter period of time such as 1-
3 days.

It has become a challenge for banks to ascertain if the account holder of the beneficiary
account is the perpetrator/beneficiary of the defrauded amount. Bank is required not
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only to identify such accounts but initiate action against these accounts in addition to
reporting to the financial regulators.

Therefore, monitoring of credit transactions in customer accounts, specifically Current

& Savings Accounts (CASA), is the need of the hour. Accordingly, ORMC in its meeting
dated 06.02.2024 and 12.03.2024, approved setting – up of a new cell named as
Credit Transactions Monitoring Cell (CTMC) which shall work under Fraud Risk
Management Division (FRMD), Head Office for the purpose of monitoring credit
transactions in current and savings accounts.

Transaction monitoring involves tracking and analyzing financial transactions to identify

and prevent suspicious or fraudulent activities. It's crucial for detecting anomalies and
ensuring regulatory compliance in banking industry. To start with, monitoring of credit
transactions shall be implemented in two ways:

Page 1 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

1. Preventive Method

In this mode, CBS shall restrict the debit transactions initiated through online channels
i.e. IBS/ MBS/ UPI/ IMPS in Current accounts which breaches the pre-defined
scenarios placed in CBS on real time basis. As soon as any transaction is declined by
CBS due to breach of checks placed in CBS, an informative SMS in this regard shall
be sent centrally to the customer for decline of each transaction. SMS Template is as
under:

“Dear PNB Customer, your transaction through ADC for A/c No. XXXX2487 have
been temporarily disabled due to security reasons. Plz contact your home
branch –PNB”
Adopting a more customer centric approach, “View” facility will be allowed to the
customers in IBS/ MBS even when the facility to perform transactions is disabled in

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IBS/ MBS. Further there will be no restriction on credit transactions in these accounts.
2. Monitoring Method
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In this mode, monitoring of credit transactions shall be done through daily and monthly
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reports customized in EDW. Report no. FRMD - 006 Credit Transactions in Customers
Account has is made available in EDW for this purpose and can be extracted at
ZO/CO/BO level for the accounts pertaining to the respective offices.
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a. Daily Report:
i) The daily report regarding Current Accounts and Saving Accounts breaching
the pre-defined scenarios based on the transactions of previous day shall be
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extracted through EDW on next day by CTMC Team at HO level. This reports
shall be shared daily with respective Zonal Offices on T+1 basis for
undertaking Enhanced Due Diligence (EDD)/ checking the veracity of
transactions in these accounts and providing the data of genuine accounts
to CTMC on mail id [Link]@[Link] within 3 working days. As a
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precautionary measure, CTMC shall disable the online debit transaction

facility through IBS/ MBS/ UPI/ IMPS channels in all such accounts for which
no response is received from Zonal Offices on T+4th working day.

ii) The role of branch during Enhanced Due Diligence (EDD) and
Transaction Monitoring is pivotal as it is the first face-to-face contact
point for customer. An indicative list for the process to be followed for
conducting EDD and monitoring of transactions by field functionaries is
enclosed as Annexure A for reference. The attached list is only indicative
and not exhaustive. Field functionaries are advised to be guided by
Operations Division (KYC Section) Circular No. 14/2023 dated 14.11.2023
regarding Know Your Customer Policy Version 1.3 for FY 2023-2024 and
other extant Bank’s guidelines issued from time to time for better
understanding of transaction patterns and taking decision to ascertain the
genuineness of the account.

Page 2 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

b. Monthly Report:

The monthly report regarding Current Accounts and Saving Accounts breaching the
pre-defined scenarios based on Annual Income/ Annual Turnover fed in CBS shall be
extracted through EDW in the first week of the month for the transaction carried out in
these account during previous month. This report shall be shared by CTMC Team with
respective Zonal Offices on monthly basis for undertaking Enhanced Due Diligence
(EDD)/ checking the veracity of transactions in these accounts and necessary
correction of data in CBS if required in accordance with customer profile.

Whitelisting of Accounts:

Accounts that are found to be genuine on the basis of customer profile/ nature of
transactions and satisfactory Enhanced Due Diligence (EDD) report and veracity of

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transactions may be exempted from the process of disabling of online debit
transactions repetitively as they may be flagged regularly due to scenarios placed in
preventive mode and monitoring mode (daily report). For this exemption, base
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branches should get these accounts Whitelisted in CBS through Circle Offices.
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Whitelisted Accounts are the accounts that are identified to be genuine basis on
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customer profile and nature of transactions and needs to be exempted from disabling
of debit transactions. These may include account belonging to Govt. entities or
accounts with transaction pattern similar to pre-defined scenarios in system but are
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genuine due to their nature of business etc. These accounts shall not be flagged for
disabling of debit transactions and shall continue to remain in this category for a
maximum period of one year. Accounts which have been Whitelisted shall be reviewed
after one year or as and when required after ensuring proper due diligence.
5

Whitelisting of accounts will be allowed only at Circle Office level through menu
“EXMFRM” which can be accessed only by ZC users of Circle Office. Process flow for
using menu option “EXMFRM” for whitelisting of accounts by branch and circle user is
given in Annexure B.
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Role of Branches:

a. As soon as online debit transaction facility is disabled in CBS, branch to endeavor

to re-enable the online debit transaction facility (IBS/ MBS/ IMPS/ UPI) in CBS within
8 hours of the receipt of intimation by the base branch only in cases where Enhanced
Due Diligence (EDD)/ veracity of transactions in the account is found to be in order.
b. Base branch is required to conduct Enhanced Due Diligence (EDD)/ check the
veracity of transactions in the account and update the same in CSB using menu
option “EXMFRM” accessible only by Officers & above in case of satisfactory as well
as unsatisfactory report.
c. Process flow for using menu option “EXMFRM” by branch user for capturing of EDD
details in system and allowing online debit transactions is given in Annexure B.
d. In accounts which are found genuine in terms of EDD and veracity of transactions,
base branch can re-enable the online debit transaction facility through IBS/ MBS/

Page 3 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

IMPS/ UPI channel by selecting option “Yes” for the field “Whether eligible for debit
transactions through IBS/ MBS/ UPI/ IMPS after EDD” using menu option
“EXMFRM”.
e. Base branch is required to maintain and preserve the records of EDD as per Banks
extant guidelines.
f. Branches to complete the process of EDD and checking the veracity of transactions
within the stipulated time period and the status of the same be submitted to Zonal
Offices through Circle Office for onward submission to CTMC in order to prevent any
inconvenience to genuine customers.
g. Base branches to identify the accounts to be Whitelisted and the same be got done
in CBS through Circle Offices.
h. Base branches to make necessary updation/ correction of relevant fields in CBS on
basis of documents obtained during EDD.
i. In case of any suspicion, reporting of such accounts be done as per Bank’s extant

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guidelines to CAML Division, HO for filing of STR without informing to the customers.

Role of Circle Offices:

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a. Circle Offices to facilitate branches in undertaking Enhanced Due Diligence (EDD)
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and submit the consolidated data to Zonal Offices within stipulated time period.
b. Accounts that are to be exempted from the process of disabling of online debit
transactions that may be flagged repetitively due to scenarios placed in preventive
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mode and monitoring mode (daily report) shall be whitelisted in CBS by Circle
Offices after taking approval from Competent Authority (Circle Head/ Dy Circle head
in absence of Circle Head) on receiving specific request from the base branch. The
same is to be allowed only after getting satisfying about Enhanced Due Diligence
5

(EDD) and genuineness of transactions in the accounts.

c. These accounts shall continue to remain in Whitelisted category for a maximum
period of one year and shall be reviewed as and when required ensuring proper due
diligence.
d. Proper data of whitelisted accounts be maintained at Circle Office level and be
04

shared with Zonal Offices from time to time for onward submission to CTMC.

Role of Zonal Offices:

a. Zonal Offices shall work as single contact point for CTMC for sharing/ reporting of
genuine accounts/ disabling/ enabling of online debit transaction facilities/
whitelisted accounts etc.
b. Zonal Offices to arrange to examine/ undertake EDD/ checking the veracity of
transactions by the field functionaries in respect of accounts shared by CTMC based
on daily reports within 3 working days and submit the consolidated list of accounts
found genuine with CTMC on mail id [Link]@[Link].
c. Additionally, for reports shared by CTMC on monthly basis, Zonal Offices to arrange
to examine/ undertake EDD/ checking the veracity of transactions by the field
functionaries and submit the status report within 5 days to CTMC.
d. Consolidated data of whitelisted accounts be shared with CTMC from time to time.

Page 4 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

Role of CTMC, FRMD:

a. Monitoring of credit transactions shall be done by CTMC team through

aforementioned daily and monthly reports available in EDW on T+1 basis.
b. CTMC team shall analyze alerts/ accounts in respect of transactions inconsistent
with customer profile (annual income or turnover) etc. based upon the reports
generated.
c. After analysis of alerts/ accounts by CTMC team, the daily report shall be shared
with the respective Zonal Offices and Circle Offices for examining/ undertaking EDD/
checking the veracity of transactions by the field functionaries on T+1 basis through
email.
d. Additionally, CTMC shall share the monthly report with respective Zonal Offices in
the first week of the month for the transactions carried out during previous month.
e. Furthermore, online debit transaction facility in the accounts for which no response

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is received from Zonal Offices shall be disabled for IBS/ MBS/ UPI/ IMPS channel
by CTMC on T+4th working day.
f. Overall monitoring accounts wherein online debit transaction facility has been
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disabled through IBS/ MBS/ UPI/ IMPS channel, shall be done at FRMD, HO. All
22
such accounts where scenarios have been invoked and online debit transactions
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have been disabled, shall be placed to GM of the division on fortnightly basis for
oversight.
g. Additionally, all accounts where debit transactions are enabled by branches after
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EDD as well as accounts whitelisted by circle offices shall be placed before GM of

the division on fortnightly basis.
h. Note for review of efficacy of the scenarios/ reports at least once in six months be
placed before the competent authority.
5

It be noted that all correspondence in respect of credit transactions monitoring viz.

submitting of status of accounts on daily/ monthly basis, list of whitelisted accounts,
Enhanced Due Diligence (EDD)/ veracity of transactions etc. be done on designated
email [Link]@[Link] only. Correspondence received through any other means
04

may not be entertained.

All field functionaries are advised to note the above for meticulous compliance.

General Manager
(Soumendu Kumar Dash)

Page 5 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

Annexure A

Indicative list of process to be adopted for undertaking Enhanced Due Diligence

(EDD) and monitoring of credit transactions in current and savings account:

During EDD process, branch is required to ensure the following based upon the profile
of customer, past dealings with the bank or adverse media reports, if any:

a. Updation of KYC by obtaining latest KYC

b. Apart from obtaining the current address proof, concerned official shall verify the
current address through positive confirmation before allowing operations in the
account. Positive confirmation may be carried out by means such as physical
verification/ address verification letter/ contact point verification/ deliverables, etc.

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c. Ensuring that customer profile i.e., constitution, activity, income, turnover details
etc., are updated by obtaining recent data & information from customer.
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The role of branches in transaction monitoring is to focus on following broad factors in
22
order to identify accounts posing deviations from the norms, potential risks, or unusual
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activities that might indicate suspected fraud:

a. Large and complex transactions including RTGS transactions.

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b. Unusual patterns w.r.t. past transactions.

c. Inconsistent with the normal and expected activity of the customer.
d. Having no apparent economic rationale or legitimate purpose.
e. Exceeding the thresholds prescribed for specific categories of accounts.
5

f. High account turnover inconsistent with the size of the balance maintained.
g. Behaviour/ transaction pattern and transaction type i.e. heavy cash deposit related
to nature of activity.
h. Large sums being transferred from overseas/ multiple jurisdictions for making
payments.
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i. Incoming and outgoing pattern shows inconsistency.

j. Accounts of customer and other account of customer linked to PAN, Aadhar, Mobile
number.
k. Counterparty details.
l. Account opening date i.e. whether newly opened accounts.

Page 6 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

Annexure B

PROCESS FOR CAPTURING EDD & ENABLING ONLINE DEBIT TRANSACTIONS BY

BRANCH USER THROUGH MENU EXMFRM:
In order to capture the details of EDD in CBS, branch official to use menu option “EXMFRM”.
It is to be noted that EDD captured shall be valid for a single instance only.
Step 1: Branch user to select option – “EDD by Branch” for capturing EDD details.

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Step 2: In case EDD is satisfactory and online debit transaction facility is to be enabled for the
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account, branch user should select following options:

EDD Done - Yes
Whether eligible for debit transaction through IBS/ MBS/ UPI/ IMPS after EDD – Yes
04

Page 7 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

Step 3: In case EDD is done but online debit transaction facility is not to be enabled for the
account due to unsatisfactory report, branch user should select following options:
EDD Done - Yes
Whether eligible for debit transaction through IBS/ MBS/ UPI/ IMPS after EDD – No

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Step 4: Record thus added may be verified using function V-Verify. Likewise, other functions
I-Inquire, D-Delete and X-Cancel may be used as and when required.
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Page 8 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

PROCESS FOR WHITELISTING THE ACCOUNT BY CIRCLE USER THROUGH MENU

EXMFRM
For whitelisting the account in CBS, menu option “EXMFRM” to be used by ZC user at Circle
Office.
Step 1: Option – “Whitelisting by CO” must be selected by ZC user at Circle Office for capturing
the details of the account to be whitelisted. It is to be noted the option Whitelisting by CO is
accessible at circle level only.

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Step 2: User to select function Add to add the record and other required details.
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Page 9 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only
 पंजाब नेशनल बैंक
जमा धन लेन-दे न ननगरानी प्रकोष्ठ, धोखाधड़ी जोखखम प्रबंधन प्रभाग, प्रधान कार्ाालर्
PUNJAB NATIONAL BANK
CREDIT TRANSACTIONS MONITORING CELL, FRMD, HEAD OFFICE

Step 3: Record added may be verified using function V-Verify. Likewise, other functions I-
Inquire, D-Delete and X-Cancel may be used as and when required.

:33
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5
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Page 10 of 10
FRMD Cir. No. 25/2024, Monitoring of Credit Transactions in Current & Savings Accounts
Confidential- Strictly for internal circulation only