Creditwest Bank Ltd is committed to support all efforts at local and international level to fight against money laundering, the financing of terrorism and other related offences and to adhering and comply to all legislative framework on this matter.

Through continuous monitoring and control as per our Bank’s policies and procedures, we aim to protect both our bank and customers from potential risks and to comply with the applicable laws and regulations.

Money laundering can be described as engagement in activities aimed at disguising or concealing the origin of funds generated through criminal activities and arranging for their entry into the economic system under a seemingly legitimate label.

Terror financing refers to those acts having the objective of providing funds for terrorism activities through financial institute, with full knowledge and awareness of such a result.

Financial institutions may be used at any point in money laundering related process. Even unintentional involvement in any criminal activity may weaken an institution’s public reputation. In order to minimize the chances of this happening our Bank has adopted as its main policy the following:

The primary principles of our bank are;

• Complying with all requirements of applicable laws and regulations,
• Co-operating with law enforcement and regulatory agencies at local and international level,
• Doing business as per ethical norms.

Customer risk assessment is made. Accordingly, the TRNC residents, employees and personal savings account holders are considered at low-risk group. The identity and addresses of such individuals are verified while going through this verification process.

Operations of non-residents are considered at a higher risk level. Furthermore, the citizens of the countries which are listed by such organizations as FATF, the U.S. Treasury Department and the MASAK as having a high risk of engaging in money laundering and terrorist financing activities are evaluated in the highest risk category. For such individuals additional detailed analyses are carried out.

The new customers are also evaluated subject to various further criteria such as profession category, financial data and assets.

Existing customers’ accounts and the market situation are being followed closely. If deemed necessary, our Bank has taken various measures, including but not limited to, reporting suspicious transactions.

In terms of Services / Transactions risk, all electronic transfers and non-face to face transfers through alternative distribution channels (Monaygram, internet, ATM, etc.) are considered as transactions with a high-risk group. Additional detailed evaluations are pursued for this type of service and transactions.

Our Bank endeavors to work in line with the FATF standards in the name of fighting against money laundering, terrorist financing, and other financial offences.

Creditwest Bank adheres to and develops policies safeguarding against money laundering to comply with all applicable laws, regulations and rulings in the countries in which it does business.

Amongst the elements of this program are the following;

• Adopting written policies and procedures,
• Assigning a compliance officer responsible for implementing anti-money laundering (AML ) policies and procedures,
• Having an internal review and control process to test the robustness of policies and procedures,
• Monitoring and reporting on customer activities and transactions as per the AML legislations and regulations,
• Training of employees on AML.
• Following the innovations and developments as regards the applicable laws and regulations

Policies and procedures summarized as follows:

• Customer Acceptance Policy: We do not accept as customers the following categories of individuals or legal entities and also refuse to provide them with any kind of banking service; Customers who want to open anonymous accounts or accounts using fictitious names, those who refuse to provide the required information and documentation, those with business that make it impossible to verify the legitimacy of their activities or the source of funds. Furthermore, no account may be opened or maintained for individuals or entities who are included in lists prepared by international institutions and organizations that show them as money-launderers and supporters of terrorism financing. Lastly, no relation is established with or a banking related service provided to potential customers who have a negative record in the bank’s internal intelligence system for money-laundering, financing of terrorism, and financial crimes related thereto.
• Know Your Customer (KYC) Procedures: Accurate and sufficient information about customers are maintained and their transactions are monitored. Besides, compatibility of the customers’ income with their stated occupation and assets is monitored.
• Opening account: Official ID and address documents are required prior to opening any bank account. The accounts are opened for real names. When credit facilities are provided, black list records are checked.
• Record Keeping: Records and evidence of identification and transactions are kept for at least 12 years.
• Suspicious Activity Reporting: All suspicious transactions and activities are reported to the relevant authorities. Cash transactions in excess of the cash money limit, as well as in whose name and account they were made, are reported without having regard to whether or not they are found to be suspicious.
• Correspondence Banking: When establishing accounts for correspondents, sufficient care are taken for identifying the institution, nature of its business, and for obtaining other relevant data such as institutions’ AML and KYC policies and procedures. We do not maintain any relationship with shell banks.
• Cooperation with Authorities at Local and International Level: Where applicable, cooperation with law enforcement and regulatory authorities is essential.
• Politically Exposed Person(PEP’s): For providing a banking service to the politically exposed people at home and abroad (including, but not limited to, high ranking public officials such as heads of government or of state, high level politicians, judicial or military personnel, heads of public bodies and high ranking political party representatives), the approval of a high ranking official is sought and steps are taken to identify the source of the funds and assets.
• Training: Training activities are carried out in order to improve the knowledge of all employees, including the high ranking Bank officers, of the Creditwest Bank products and to increase awareness of their legal obligations as regards money laundering or terrorist financing .

Sample criteria for suspicious transactions

• Provision of inadequate, misleading, inaccurate, incomplete and contradictory information or documents
• Suspecting a tampering or forgery in the documentation
• Customer demonstration of inconsistent behavior in his relationships with other people and staff
• Discrepancy between the type of business, financial condition and operations
• Detection of relationships with third parties considered risky.
• Customer’s conviction.
• Doing transactions without legal or economic purpose
• Use of non- ordinary payment methods
• Doing transactions with people on the forefront of politics
• Attempts to evade identification, storage of records process and the notification procedures
• Ignoring the Bank’s commissions, charges or interest rates and behaving in a hurry and anxious for the immediate completion of the transactions
• Receiving large sums at one time without satisfactory explanation from risky jurisdictions or cross-border centers

The above-mentioned is the nature of guidance only. When a suspicious transaction takes place in another shape or style, our staff shall still make their independent assessment of the matter and if necessary contact the Bank Regulatory Compliance Unit for further guidance.