Evrofinance Mosnarbank statement on compliance with anti-money laundering requirements
As part of its business approach as a transparent and socially responsible corporate, Evrofinance Mosnarbank (the Bank) is firmly committed to participating in international efforts to combat money laundering, the funding of terrorism and other acts punishable by law.
Evrofinance Mosnarbank, located in Moscow, Russia, is supervised by the Central Bank of the Russian Federation ( www.cbr.ru/eng/), and in terms of money laundering by the Federal Financial Monitoring Service ( www.fedsfm.ru/en).
Russia has enacted laws and rules designed to implement the anti-money laundering standards set by the Financial Action Task Force (FATF, www.fatf-gafi.org). In July 2013 Russia took over the presidency at FATF. Federal Financial Monitoring Service is also a member of the Euro-Asian Group inside of FATF and adheres to its supervisory standards, guidelines and recommended best practices.
Evrofinance Mosnarbank adheres to the highest AML standards. The Bank enacted Policy on AML, the Internal Regulations on AML and a number of Programs for Monitoring, which were issued in compliance with Russian rules and international standards regarding the prevention of money laundering and financing of terrorism, are in place. The Internal Regulations are generally based on the Wolfsberg principles and the UN Convention against Corruption dated 31/10/2003. The Bank shares its standard Wolfsberg Questionnaire designed in compliance with the Wolfsberg principles regarding the prevention of money laundering, financing of terrorism and other acts punishable by law. With a note to FATF Recommendation adopted in February 2012 FATF Recommendation adopted in February 2012, the Bank continuously updates its monitoring systems. In the course of internal assessment of monitoring efficiency Evrofinance Mosnarbank refers to the Methodology for assessing technical compliance with the FATF recommendations and the effectiveness of AML/CTF systems.
Inside, banking secrecy.
Evrofinance Mosnarbank implemented best international practice to prevent illegal usage of inside information. In compliance with 224-FZ Federal Law of the Russian Federation the Bank adopted:
- list of inside information,
- the Rule for Access to Inside Information and the Regulation of Inside Information Privacy.
Due to the requirements of the Federal Commission for Finance Market (former Russian state supervisory authority, which is currently taken over by the Central Bank of Russia) Evrofinance Mosnarbank approved the List of Actions List of Actions aimed to prevent illegal usage of inside information.
The bank had appointed a Responsible officer – Comptroller obliged to constantly monitor financial transactions in order to prevent illegal usage of inside information and misconduct. The Responsible officer reports directly to the Supervisory Board on a quarterly basis. His reports are subject to be approved by the Supervisory Board.
Evrofinance Mosnarbank pays much of attention to banking secrecy and data security. Further to Russian Law 152-FZ dated 27.07.2006 On Personal Data the Bank adopted the Policy for Personal Data.
USA PATRIOT ACT Certification.
Pursuant to the USA PATRIOT Act and final rules issued by the U.S. Department of the Treasury, a U.S. bank or a U.S. broker-dealer in securities is required to obtain certain information from any foreign bank that maintains a correspondent account with it.
A reference to Evrofinance Mosnarbank certificate of conformity with the USA PATRIOT ACT is available for your records www.evrofinance.ru/files/upa.pdf. For more information or should you require a hard copy of the certificate please contact firstname.lastname@example.org.
Financial Account Tax Compliance Act (FATCA).
The Foreign Account Tax Compliance Act (FATCA) is a United States statute that requires US persons, including individuals who live outside the US, to report to Internal Revenue Service (IRS) their financial accounts held outside of the US, and requires foreign financial institutions to report to IRS about their US clients. FATCA is a cross-border regulation binding upon all institutions worldwide. A foreign financial institution may comply with FATCA regulation either (1) directly reporting to IRS, or (2) through so called IGA inter government agreements concluded between IRS and respective country authority, thus reporting through its national supervisory body.
Evrofinance Mosnarbank is compliant with the Foreign Account Tax Compliance Act (FATCA) and successfully registered with the U.S. Internal Revenue Service as a Participating Foreign Financial Institution (PFFI). Evrofinance Mosnarbank received the following Global Intermediary Identification Number (GIIN): SQJBUR.99999.SL.643.
“Banks Against Money Laundering”.
Evrofinance Mosnarbank jointed to the Declaration of few Russian banks group known as “Banks Against Money Laundering” and eagerly promotes its principles.
Anti-Money Laundering in Progress.
With regard to AML Evrofinance Mosnarbank adopted tailored programs, which provide the following:
Appointment of an Anti-Money Laundering Officer
The bank set up an Internal Service for Financial Monitoring and appointed an AML Officer who is responsible for regularly reporting to President of the Bank.
The bank applies a strict Know Your Customer and Know Your Correspondent (KYC) approach in its customer due diligence and correspondent banking procedures. The customers are ranked according to the risk AML degree. We update KYC procedures on a regular basis though at least once a year.
AML trainings are conducted on an ongoing basis for all staff when recruited and at regular intervals thereafter within the framework of the respective bank’s training program. The AML training are complemented by remote programs to maintain a high level of awareness with regard to the warning signs of money laundering, terrorist financing and criminal activities among all members of staff.
Risk classification of customers
The bank maintains a risk ranking of its customers in order to assess the risks of money laundering, terrorist financing and criminal activities and applies due diligence and monitoring procedures accordingly. Those Customers, considered as high or medium risk AML degree, are paid closer attention as to the profile and transactions. The bank is free to terminate relationships or refuse to conduct a particular transaction deemed to be of high AML risk at banks’ own discretion.
The bank has no business with shell banks, is not involved in anonymous accounts. We are strictly committed to follow all the requirements for blocking suspicious funds, relevant document filing and archiving.
Customer data, transaction and account monitoring
In order to detect potentially suspicious activities, the bank uses an IT-based monitoring system, implemented in customer and operation units, and applies consistent standards for data and transaction monitoring. The bank adheres to national and international sanction lists and embargoes.
Suspicious activity reporting
Any suspicious transaction is to be reported by a customer manager or cashier directly to a Responsible AML Officer. The AML Officer investigating the deal may request any additional information and respectively forward the report to the Federal Financial Monitoring Service and the bank management.
Evrofinance Mosnarbank annually audits adequacy of all anti-money laundering procedures.
Representative offices at Beijing (China) and Caracas (Venezuela) completely conforms local legislation and the above Head Office rules.