A to Z & Co. of qualified Company Secretaries is a recently set up professional firm. Tej, the Managing Partner wants to understand the criteria to be adopted by a professional as per KYC norms. Outline the key eleme

Suggested criteria to be adopted by Professional as KYC Norms Generally, the KYC policies incorporating the following four key elements: Client Acceptance Policy; Client Identification Procedures; Client Monitoring Mechanism; and Risk management. These are suggested measures, to be adopted by the professional while dealing with client and undertaken any assignment from a client/ prospective client. As a Code for good practice every professional should ensure that no fraud has been take place due to adoption of the poor KYC norms. It is the duty of the professional proper checking of documents will be done in order to complete the requirement of KYC Norms. Though, there is no settled manner for doing KYC by the professional, However the ICSI has prepared a policy on KYM, KYC norms, However, variation in the procedure for KYC of one time assignment and or for the regular client may be there. The Professionals should take extra care with the foreign client, to ensure that all the rules and regulations are followed, according to the specified procedures for dealing with the foreign clients. Proper implementation of KYC policies includes the following: Collation of Client information: information about the identify and business structure of the client helps in ensuring that the professional can freely exercise and deliver their professional services in the best suited way. Due Diligence of the Client: This helps in mitigation of various professional and legal risks associated with service provided to the client. Regularity of the KYC exercise: The effectiveness of the KYC policy relies on its regularity as it can ensure that the data earlier collated about the client remains updated. Identification of Regularity Risks: The KYC policy should be designed and updated regularly so as keep it aligned with the legal provisions applicable if any so as to avoid legal risks. Additional factors applicable for clients belonging to other countries: in case of clients belonging to other countries, the information to be collated might be in a different format as may be required in that country. The KYC policy shall be flexible enough to deal with such variations in input data. Confidentiality of Client Data: As part of KYC exercise the information provided by the clients may include sensitive data of the client which the client will be sharing in good faith. The policy shall contain appropriate measure to protect the client information thereby safeguarding the client as well as the firm (Against any possible action for unauthorized disclosure of client data.