Finansbank aims to set an example as a leading bank.
Finansbank Anti-Money Laundering / Know Your Customer Policy and Procedure
Finansbank Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy and Procedure underlines the general principles followed by Finansbank A.Ş. (Finansbank, or the Bank) for establishing adequate procedures of customer identification, reporting, record keeping and internal control in order to prevent operations related to laundering the proceeds of crime or financing of terrorism. Finansbank's branches located out of Turkey are also required to comply with the applicable money laundering and anti-terrorism legislation of the country they operate in.
Finansbank is regulated mainly by the Turkish supervisory authority, the BDDK (BRSA-Banking Regulation and Supervision Agency) , which ensures that banks in Turkey comply with the Banking Law and the related legislation and that they have adequate business procedures, control measures and auditing systems. Money laundering and anti-terrorism issues are specifically regulated in Turkish Financial System by the MASAK (FCIB-Financial Crimes Investigation Board of TURKEY) . MASAK ensures that banks comply with the anti-money laundering and anti-terrorism legislation, including the Know Your Customer (KYC) rules.
Finansbank's AML Unit is a part of the Compliance Department reporting to the Audit Committee of the Board of Directors and it is in charge of the Bank's internal procedures to prevent money laundering and financing of terrorism. It also handles the reporting of suspicious transactions to the MASAK.
Bank's internal procedures are accessible to all employees via the IT system.
AML / KYC Policy Statements
Finansbank conducts its business in conformity with high ethical standards and adheres to all related laws and regulations. While it is accepted that Finansbank may not always be able to determine whether a transaction originates from or is part of, any unlawful activity, the Bank will conduct its business in compliance with the following general principles:
Prior to transact any type of business, Bank will determine and document the true identity of customers, and it will obtain information about the purpose and the intended nature of the business. Bank will obtain and document any additional information, commensurate with the assessment of the money laundering risk with a risk-sensitive approach.
Finansbank will clarify whether the customer is acting on behalf of another natural person or legal entity as trustee, nominee or professional intermediary. In such cases, Bank will obtain satisfactory evidence about the identity of any intermediaries and of the persons upon whose behalf they are acting, as well as the nature of the trust arrangements in place.
KYC procedures will always be complied with, when customers open accounts and establish a new business relationship. The Bank's AML and KYC procedures will be conducted on a risk-based approach, and anonymous accounts will not be established.
Finansbank has electronic systems in place whereby the Bank, on an ongoing basis, controls all persons, firms and organisations mentioned in international alert lists like EU terrorism lists and US OFAC list.
Bank will obtain sufficient information about correspondent bank to avoid any kind of relationship with "shell-banks."
By use of publicly available sources of information, Bank will determine the reputation of correspondent institutions, including whether they have been subject to money laundering or terrorist financing investigations or other regulatory actions.
Bank will periodically assess the respondent institutions' anti-money laundering and terrorist financing controls.
Finansbank will implement and maintain measures for handling suspicious transactions. Bank will not ignore indications that a customer's money originated from unlawful activities or other money laundering activities, and it will report all identified instances of suspicious activities to the relevant authorities.
Bank will avoid providing support or assistance to parties seeking to deceive law enforcement authorities through the provision of false, altered, incomplete or missing information.
The reporting of suspicious transactions/activities will comply with the laws and regulations of the respective jurisdiction. Accordingly, all personnel will be diligent in monitoring for any unusual or suspicious transactions/activities basing on the relevant criteria applicable in the jurisdiction where the Bank operates.
All employees of Finansbank who come directly or indirectly into contact with customers will be trained to deal with and respond to transactions that raise a suspicion of money laundering or the financing of terrorism.
Monitoring of suspicious transactions about AML and KYC issues will be enhanced by a powerful software tool which is to be implemented at the first half of 2009.
Records of all documents obtained for the purpose of identification and all transaction data as well as other documents -related to money laundering topics in accordance with the statutory duties imposed on credit institutions by the applicable AML laws and regulations- will be kept for at least 8 years.
Finansbank's employees will be trained about the prevention of money laundering so that they can implement immediate and appropriate measures for identifying customers and handling suspicious transactions.
Training on anti-money laundering will be provided to all employees who work directly with customers and to those employees in essential auxiliary functions that may be exposed to money laundering and terrorist financing threats. These trainings will be conducted initially upon commencement of employment and later on regularly on a 12-months-basis. In addition, these staff will be informed on an ongoing basis about new methods and techniques of money laundering.
Adequacy of the AML Policy and compliance with this Policy will be checked periodically, and internal controls and audits will be continuously improved based on the outcomes of these checks.
Bank will cooperate fully with law enforcement and regulatory authorities in executing their duties under all applicable laws.
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