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Anti-money laundering

Policy of JSC “MB Bank”

on Anti-Money Laundering and Combating the Financing of Terrorism and Financing Proliferation of weapons of mass destruction

 

Being aware of the importance and recognizing special significance of the policy, being practiced along the whole civilized world, in the field of anti-money laundering, and simultaneously identifying explicit threat constituted before the entire world community and emanating from terroristic organizations and other associated with them companies, JSC “MB Bank” (hereinafter referred to as “the Bank”) has developed and implemented internal system of control over anti-money laundering and combating the financing of terrorism and financing proliferation of weapons of mass destruction (hereinafter  AML/ CFT/ FPWMD, elaborated on the basis of the principle of involvement of all employees of the Bank, independently of a position held and within their competence, in the activities aimed at prevention of transactions and deals that are, either expressly or by implication, associated with money laundering, and also exclusion of the possibility to conduct transactions pertaining to financing of terrorist activity.

The current system of AML/ CFT/ FPWMD of JSC “MB Bank” operates according to requirements of the Federal Law No. 115-FZ of 07.08.2001 “On Combatting Legalization (Money Laundering) of the Proceeds of Crime and Financing of Terrorism” (hereinafter - Federal Law No. 115-FZ) and recommendations of the Bank of Russia on AML/ CFT/ FPWMD. The Bank also employs the international experience, including recommendations elaborated in this area by the following international organizations - the team for development of financial activities designated for anti-money laundering (Financial Action Task Force - FATF), Basel Committee of Banking Supervision and Wolfsberg Group.

To correspondent banks and counter parties of JSC “MB Bank

JSC “MB Bank” informs that in order to fulfill requirements of Federal Law No. 115-FZ and regulations in the field of AML/ CFT as well as in accordance with recommendations of the Bank of Russia, implements measures on AML/CFT/ FPWMD.

Functioning of the system on AML/CFT/ FPWMD is regulated by “Internal Control Rules on AML/CFT in JSC “MB Bank””(hereinafter referred to as “the Rules”). One of the principles of organization of such system consists in realization of the risk-oriented approach directed at management of risk associated with money laundering and financing of terrorism. Primary objectives of the system on AML/CFT/ FPWMD are: prevention of use of the Bank as a tool for money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction, protection of business reputation of the Bank and its clients, ensuring prevention of possible risks related to AML/CFT/ FPWMD.

For the purpose of organization of the internal control system in the Bank and Branch employees responsible for implementation of the Rules are appointed.

The Bank implements all appropriate and  necessary measures on prevention of transactions and deals that are, either expressly or by implication, associated with money laundering, as well as on liquidation of possibility to execute transactions related to financing of terrorist activity.

The Bank targets at maintaining a high business reputation and minimizing the risks associated with implication of the Bank in doubtful financial schemes orchestrated by unscrupulous customers. In view of this the bank fully applies the “Know Your Customer” policy.  The Bank with utmost circumspection and due diligence decides upon formation of its clientèle, carefully examines potential customers, their interests and areas of business activity, and also aims at establishment of business relations, characterized by transparency, complete comprehension of business activity and clients’ operations, monitoring and analysis of activity of organizations and persons who are already clients of the Bank are being carried out as well. Relevance assessment and sufficiency of existing methods and monitoring procedures is conducted continually, concurrently with emergence and proliferation of new techniques of money laundering, amendments to the legislation and dissemination of international practice.

The Bank does not open accounts (deposits) on anonymous owners, that is without granting by the individual or legal entity, a foreign structure without creation of the legal entity of the documents necessary for its identification of opening the account (deposit), and also does not open and operate accounts (deposits) on the owners using assumed names (pseudonyms);

The Bank does not establish and maintain relations with non-resident banks, not having permanent management bodies on the territories of the countries of their registration.

The Bank does not conclude a bank account (deposit) agreement with the customer in case of non-submission by the customer, the customer’s representative of documents, needed for identification of the customer, the customer’s representative, beneficial owners and beneficiary in the cases, provided for by the Federal Law No. 115-FZ.

 

  • AML-related documents applied in JSC "MB Bank"
  • If the Bank refuses to execute your instructions or conclude a bank account agreement with you
    • If the Bank refuses to execute your instructions or conclude a bank account/deposit agreement with you, you have the right (please consider information related to the reasons of refusal received from the Bank) to submit documents and (or) information which would prove that the refusal has no grounds.

      The Bank is obliged to check through the documents and information provided by the Client and inform him of elimination of reasons for the previous refusal within ten days from the moment of their submission or confirm that the Client's documents and information are not enough for elimination of reasons of the previous refusal.

      If the Bank insists on the fact that it is still impossible to remove the reasons of the previous refusal by means of the documents and information provided by the Client, the latter is entitled to apply to Inter-Insitutional Commission of the Central Bank of Russia (Documents and information you refer to shall be submitted to Inter-Insitutional Commission of the Central Bank of Russia in accordance with the Bank of Russia's Instruction No 4760-У of 30.03.2018).