AML policy
Absolut Bank’s anti-money laundering procedures are based on and are in compliance in all material respects with the relevant Russian legislation and are approved by the Central Bank of Russian Federation.
Absolut Bank has procedures and operative documents aimed at preventing money laundering and terrorist financing, including a general anti- money laundering policy and internal control procedures and rules on counteracting money laundering and financing of individuals and legal entities engaged in terrorist activities, as well as procedures for reporting any suspicious activities to the Federal Service for Financial Monitoring. These procedures aim to, among other things, minimise the risk to Absolut Bank of being used as a vehicle for money laundering or terrorist financing and protect Absolut Bank from the financial and reputation risks inherent in associations with money laundering or terrorist financing activities and ensure that banking services are provided only to bona fide clients.
Anti-money laundering procedures include ‘‘know-your-client’’ procedures that require clear identification of clients, verification of their identity and appraisal of the risk of their engaging in money laundering and/or terrorist financing. If the risk of particular clients engaging in money laundering and/or terrorist financing is determined to be significant based on profiling, the activities of such clients are monitored on a regular basis. Absolut Bank identifies transactions that must be monitored and reported pursuant to Russian anti-money laundering legislation. Such legislation requires Absolut Bank to monitor and report such transactions to the Federal Service for Financial Monitoring via the CBR.
Absolut Bank maintains a database containing information on all clients and transactions in which they engage that facilitates identification of unusual transactions. In addition, Absolut Bank verifies each client’s identify, legal status and authority to engage in particular transactions. Absolut Bank does not enter into business relationships with clients that refuse to provide sufficient identity and authority information. Absolut Bank pays particular attention to obtaining information about its bank counterparties and does not enter into banking relationships (including interbank lending and deposit taking and operating correspondent bank accounts) with shell banks.
Absolut Bank keeps all information obtained as a result of applying its anti-money laundering procedures confidential, except where it is required to report it to the Federal Service for Financial Monitoring.
Absolut Bank’s Financial Monitoring Department monitors client transactions and the activities of all of Absolut Bank’s departments for compliance with relevant Russian anti-money laundering legislation. Absolut Bank’s other departments notify the Financial Monitoring Department of suspicious transactions, using the criteria set out in Absolut Bank’s internal anti-money laundering regulations. The Financial Monitoring Department pays particular attention to transactions involving large sums or significant amounts of cash. If monitoring indicates that a client may be engaged in money-laundering or terrorist financing, the level of monitoring of such client is increased. Activities are analysed on an ongoing basis, which allows detection of money-laundering schemes. If necessary, the Financial Monitoring Department obtains additional information about a particular transaction’s purpose and/or suspends suspicious transactions.
Absolut Bank’s Financial Monitoring Department also provides education and training of personnel regarding Absolut Bank’s anti-money laundering procedures.
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