BTN Customer Due Diligence (CDD) & Kyc Policy

PT Bank Tabungan Negara (Persero) Tbk (“BTN”) implements a comprehensive Customer Due Diligence (CDD) framework as part of its Anti-Money Laundering (AML), Countering the Financing of Terrorism (CTF), and Counter Proliferation Financing of Weapons of Mass Destruction (CPF) programs. These procedures are governed through internal policies, including:

• KK.6-B – AML/CTF & PFWMD Implementation Procedures;

• PT.6-B.1 – AML/CTF & PFWMD Operational Guidelines; and

• PT.9-I.1 – Customer Information File (CIF) Management Procedures.

Customer Due Diligence (CDD)

BTN conducts comprehensive CDD at the commencement of a business relationship through identification, verification, and monitoring to ensure that transactions align with the profile, characteristics, and/or transaction patterns of Prospective Customers, Customers, or Walk-in Customers (WIC). The scope includes:

• Identification by requesting customer information and supporting documents to understand the customer profile;

• Verification of the accuracy and consistency of information and documents provided by Prospective Customers;

• Monitoring of transactions that deviate from the customer profile;

• Risk profiling (low/medium/high) for ML/TF/CPF risks relating to Customers, countries or geographic areas, products, services, transactions, or distribution channels; and

• Enhanced Due Diligence (EDD) for Prospective Customers, WIC, or Customers classified as high risk, including Politically Exposed Persons (PEPs), to assess potential money laundering and terrorism financing risks.

If CDD or EDD identifies indications of suspicious financial transactions, BTN submits a suspicious transaction report to PPATK.

Non-Face-to-Face CDD (Digital Onboarding)

BTN implements non–face-to-face onboarding procedures in accordance with KK.6-B Chapter III Section 1.1.33–1.1.34, including:

• Use of BTN-owned or approved third-party electronic applications (software/hardware);

• Identity verification using at least three authentication factors, such as:

1. Biometric (facial recognition, fingerprint, iris/retina);
2. Possession factors (e-KTP + OTP, digital signature, or equivalent); and
3. Knowledge factors (password, PIN, or confidential credentials).

• Certification/validation of uploaded documents; and

• Independent contact with the customer when necessary.

These methods ensure that digital onboarding maintains security and assurance equivalent to face-to-face verification.

Terrorist Financing Screening

BTN screens customer information against official terrorist designation lists issued by:

• PPATK (SIPENDAR); and

• OJK (SIGAP).

Screening is conducted during onboarding and throughout the business relationship.

Politically Exposed Persons (PEPs) & Senior Management Approval

BTN maintains formal and detailed policies regarding PEPs:

• PEP Identification
  Identification is performed for Prospective Customers, existing Customers, WIC, and beneficial owners.

• Enhanced Due Diligence (EDD)
  BTN applies EDD to all PEPs, including:

1. Obtaining information on source of wealth and source of funds;
2. Additional verification procedures;
3. More intensive transaction monitoring; and
4. Annual review of PEP status at least once per year.

• Senior Management Approval
  Business relationships with PEPs or other high-risk customers, including foreign nationals from high-risk jurisdictions (FATF high-risk and call-for-action countries), may only be established upon approval from:

1. Branch Manager;
2. Deputy Branch Manager; and
3. Sub-Branch Head.

Record Keeping

BTN retains all CDD/EDD and AML–CTF–CPF documentation, including:

• Identity documents and account opening forms;

• Beneficial owner information;

• Verification results and data updates;

• Analysis records and decisions related to suspicious transactions; and

• Evidence of reporting submitted to PPATK/OJK/Law Enforcement Authorities.

Documents are retained for a minimum of five (5) years, in accordance with POJK No. 8 of 2023. Retention is calculated from the termination of the business relationship or completion of the transaction with the Customer or WIC.

Annual Independent Assessment of Monitoring Procedures

BTN conducts an independent assessment annually, covering:

• AML/CTF/CPF thematic audits;

• Branch visits and surprise reviews;

• Evaluation of control effectiveness, compliance, and competency checks;

• Assessment of data quality and CDD/EDD documentation; and

• Review of monitoring and reporting implementation.

Assessment results inform the refinement of policies, systems, and reinforcement of compliance governance.