This is a good read.
Who’s minding the store at RCBC:
The Remittance Dept at HQ is concerned basically with the paperwork and routing the flows to the various branches. They can in no way be considered as approving the transactions. How could they understand who the customers are and what those remittances represent? However, Feb 5 morning must have stirred some excitement in the Dept when they saw 4 remittances in $ millions. They most probably picked up the phone to pre-advise the branch about the huge remittances.
The responsibility for understanding the transaction falls on the front-office officials. They are the ones who know the customers and who has intimate knowledge of the accounts. They are the ones who process the transactions and apply the proceeds. That responsibility falls squarely on the Branch Manager. That does not mean that on Feb 5 morning when they look at the remittance forms they knew it was money laundering. However, put the facts together, the Branch Manager could not have arrived at any other conclusion other than that something was not correct. The facts were :
The 4 US$ accounts have been dormant for 1 year.
The a/cs were opened at the same time, similarly dormant, and now re-activated at the same time.
The funds came from the same remitter.
The remitter is a central bank (there is unlikely and Filipino has any dealings with a central bank at the individual level)
The sums are extremely huge.
At this stage, the Branch Manager should have suspended the transactions and reported up the line for further instructions.
Q1 – Did HO Inward Remittance Dept call the branch, and if so, what was the Branch Manager’s response?
Q2 — Did Branch manager call up HO? If so, who was called, and what was the response?
The Great Bangladesh Central Bank Heist | The Society of Honor by Joe America
What basically the author says is if the BM implemented the KYC policy properly, in a regular business/banking day scenario, the transfer could have been prevented. But we know this is not the case with RCBC as we have heard in the news.


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