Compliance

Compliance

Our mission is to serve our clients as a trusted partner by providing responsible financial services that enable growth and economic progress.

Consistent with this goal, our Bank is committed to combating money laundering and leading the way in Responsible Finance – the conduct that is transparent, prudent, and dependable. Our bank carries out its activities in accordance with the requirements and norms of the applicable legislation, rules, codes, and standards.
We adhere to “zero tolerance” for non-compliance

Bank Compliance system

• AML/CTF

• Fraud

• Conflict of interest.

• Whistleblowing

• International Sanction regime

• Anti-bribery and Corruption

• Code of Conduct

• Correspondent Banking

The following key principles govern the bank’s approach to controlling compliance risk:

• Compliance with AML laws and regulations;

• Cooperation with and support of regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime;

• Serving customers and providing products and services consistent with Bank’s highest ethical standards and its commitment to responsible finance.

Bank’s Global Compliance Program

Bank has established a comprehensive Compliance Program to help protect both its clients and franchise from the risks of money laundering, terrorist financing, and other financial crimes. The foundation of this global program is the Bank Compliance Policy, which provides a globally consistent system of controls to identify and mitigate compliance risks and comply with laws and regulations.

The CCO reports directly to the Chief Executive Officer and his/her functions are:

Chief Compliance and Corporate Governance Officer

MLRO

International Sanction Regime Officer

Bank Secrecy Act (BSA) Officer

 

Governance and Enterprise-wide controls:

 

• Bank Secrecy Act (BSA) Officer: The Global AML Compliance Officer has been designated by the Bank’s Board of Directors as the BSA Officer responsible for overseeing the Bank AML Program, including apprising the Board of Directors and senior management of AML compliance initiatives, any significant compliance deficiencies, and the reporting of suspicious activity;

• Governance and Enterprise-wide controls: This control framework governs the overall program, including Global AML policies, processes, training, and testing.

Compliance Control Lifecycle

The key Program elements built on and guided by this foundation are executed throughout three phases of the Compliance Control Lifecycle: Prevention, Detection, and Reporting:

• Prevention: Building and adhering to a robust Know Your Customer (KYC) program that focuses on the creation and administration of globally consistent standards/policies, customer risk scoring, onboarding, and maintenance of customer data housed in an enterprise-wide repository.

• Detection: Transaction monitoring to identify unusual or suspicious transactions or patterns of activity, as well as robust Global AML Investigations to provide holistic reviews of both new and existing clients across various businesses and regions.

• Reporting: Active creation, tracking, and filing of Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs), and Currency Transaction Reports (CTRs), as required in many countries.

Compliance Program Execution

The risk management framework of the bank – including the AML Program – is based on three lines of defense:

• First Line of Defense (Business Management) - Each of the Businesses, including in-Business risk personnel, owns and manages the risks, including compliance risks, inherent in or arising from the Business, and is responsible for having controls in place to mitigate key risks, performing manager assessments of internal controls, and promoting a culture of compliance and control.

• Second Line of Defense (Independent Control Functions) - independent control functions, including Compliance and Risk, set standards according to which the Bank and its businesses are expected to be managed and oversee risks, including compliance with applicable laws, regulatory requirements, policies, procedures, and standards of ethical conduct. In addition, the independent control functions provide advice and training to businesses and establish tools, methodologies, processes, and oversight of controls used by the Businesses to foster a culture of compliance and control and to satisfy those standards. Chief Compliance Officers, support their respective Business by providing regulatory compliance expertise and guidance in an advisory capacity to Business Management. They are responsible for coordinating, monitoring, and, where appropriate, overseeing day-to-day compliance with the Global Compliance Program.

• Third Line of Defense (Internal Audit) - Internal Audit function independently reviews the activities of the first two lines of defense based on a risk-based audit plan and methodology approved by the Supervisory Board.

Our Continued Vigilance

• Our Bank is fully committed to remaining vigilant to prevent the use of its products and services by those who seek to abuse them. We continually seek to combat money laundering and terrorist financing through the prevention, detection, and reporting of unusual or suspicious behavior. We actively work to prevent terrorist organizations from accessing our financial services, readily assist regulators and law enforcement agencies in their efforts, and promptly respond to inquiries.

• We also continually evaluate the strength of our existing policies, procedures, and technologies, and update them, as necessary, to address the changing environment. We also train our staff to assure that they are well-versed in the evolving techniques that criminals use to infiltrate the system and are well-equipped to combat money laundering and other financial crimes.

• The fight against money laundering is a constant and evolving process. Here, we recognize that preventing money laundering and identifying possible terrorist financing activities involves constant diligence and the ability to keep pace with the sophisticated schemes employed by criminals. We acknowledge that we must constantly work to identify and understand the potential risks of money laundering and terrorist financing and implement appropriate processes to mitigate, and ultimately alleviate such risks.

Due Diligence

• Bank is a contributor and user of the Know Your Customer (“KYC”) information exchange platform SWIFT KYC Registry. The SWIFT KYC Registry is designed to increase transparency and enhance financial institutions’ capacity to maintain business relationships with key correspondents through a simple and centralized exchange of KYC information. Third-party banks and vendors conducting KYC due diligence, including the Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ), should first use this platform to collect information and documents. If additional information is required, please submit a request to the bank directly by emailing [email protected].

Partners:

More than 800 partners. Due in accordance with internal policies, all partners must be screened for sanctions before starting a relationship and evaluated according to the code of conduct. (Conflict of interest) Bank goes through internal and external audits (testing) periodically.

Compliance Systems:

Fico Tonbeller modules and World check- Compliance systems. Supported through leading firms such as Fico Tonbeller, Refinitiv ( World check), Deloitte, Bankers Almanac(Accuity), and KYC registry.