The past year, one of the persistent complaints I have received from members of the public is the cruel mistreatment of low-income people who have to interface with financial houses over proof of address request. The commercial banks have been singled out for sadistic insensitivity. I have written so much on this envelope ugliness that I truly do not think I have the mental energy to continue on this subject.
Its ugliness has disgusted me to the core of my psyche, simply because of its asinine nature, and if I had to cite evidence of Guyana being a shithole country, it is the demand by financial houses for a post office stamp on an envelope as the only criterion as proof of address. The post office corporation has joined the stupidity. To post a parcel, you must produce a post office stamp on an envelope as proof of address.
What is revolting is that the demand is not backed by law. Last week I had a deluge of lamentations on this damning edict by the commercial banks for an envelope with a post office stamp. Most of the victims were low income people who have not received a mail through the post office for years. Two victims were young UG students who had no envelope whatsoever to show the particular bank, simply because they have not received correspondence through the post office, because UG now has an online system.
Months ago, I spoke to seniors at the Bank of Guyana and the Financial Intelligence Unit (FIU) at the Ministry of Finance about this envelope insanity. Mr. Langevine, head of the FIU, told me the anti-money laundering act has no stipulation about an envelope, and further advised me that the Bank of Guyana is the place that interfaces with financial houses about adherence to the law.
I contacted the relevant personnel from the central bank and they all said that the Bank of Guyana’s guidelines to financial houses do not mention envelope requirement and the bank has accordingly advised the commercial banks.
I did a column on what Mr. Langevine and the Bank of Guyana told me. But officials at the central bank lied to me. Two managers from two prominent commercial banks informed me that their institutions never received any written material whatsoever on the envelope request from the Bank of Guyana and they will continue to stick with that criterion as proof of address.
Because of what happened last week, I spoke again with Mr. Langevine and seniors at the central bank. Here is what I received from the central bank. It is their guidelines to financial houses in keeping with the anti-money laundering Act. I reproduce it in full;
“4.2.2 Verification of KYC Details
The onus is on the financial institution to verify the customer’s
identity and to be satisfied that a prospective customer is who he
claims to be prior to establishing a business relationship.
Satisfactory evidence of identity according to Regulation 2 (2) (b)
shall be determined by the FIU and includes among others:
(i) the production of an official or identifying document, one of which
shall be a national identification card or passport;
(ii) proof of address.
For a document to be considered adequate as evidence of proof of address
it must be a document issued or obtained from an independent and
reliable source. The proof of address must be of such a nature that it
would eliminate as reasonably practicable, any suspicion of
counterfeiting or being obtained illicitly. The document obtained should
be current, i.e. issued within the last 6 to 8 months.
Where doubt exists, the name and permanent address and
employment/business details of a customer should be verified by an
independent source, other than those provided by the customer, as per
the following examples:
(a) a current utility bill for the customer’s place of residence or
business. In some cases where the customer is considered low-risk, a bank
statement from another bank may be used, but it is strongly recommended
to guard against forgeries that only originals should be accepted;
(b) independent confirmation of national identifications with the
relevant government authorities.”
As you can see, there is nothing here that stipulates that an envelope with a post office stamp must be produced by the customer. Please note these words once again “For a document to be considered adequate as evidence of proof of address, it must be a document issued or obtained from an independent and reliable source.” A police clearance and a TIN certificate from the GRA meet this standard. They constitute legal proof of address. The commercial banks do not accept them. Why not? Because we are a shithole country.
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