AML/CTF control measures
Anelik Bank CJSC (hereinafter The Bank) is committed to the highest standards of anti-money laundering and combating terrorism financing (hereinafter AML/CTF) compliance.
The Bank has established AML/CTF Program (hereinafter The Program), which main aims are:
· prevention of the use of the Bank as a tool for money laundering and terrorist financing,
· protection of the business reputation of the Bank and its customers,
· assurance that risks concerning money laundering and terrorist financing are properly mitigated.
The Program is based on 26.05.2008 Republic of Armenia law on “Combating money laundering and terrorist financing”, “Regulation on minimum requirements to reporting entities in the field of preventing money laundering and terrorism financing” of Central Bank of Republic of Armenia, other relative laws and legal acts.
The bank has appointed AML Officer who is responsible for development and implementation of appropriate AML/CTF programs and procedures. The AML Officer has the right to make final decision on recognizing a transaction or business relationship as suspicious, on suspending, refusing, or terminating a transaction or business relationship, and on freezing the property of terrorism‐related persons.
The Program includes but is not limited to:
· compliance with the risk based approach,
· establishment of risks in relation to customers, countries, geographical areas, products, services, transactions,
· customer due diligence, “know your customer” policies (including the requirement to identification of beneficial owners and the power of attorney),
· enhanced due diligence on customers assessed as high risk,
· embargo policies,
· client screening,
· monitoring of transactions,
· identification of suspicious activities ,
· submission of reports on mandatory and suspicious transactions to the Central Bank of RA,
· training of employees in the field of AML/CTF practices and controls,
· retention of records of identification and due diligence,
· the Bank does not open anonymous accounts or accounts in fictitious names,
· the Bank does not open accounts with only numeric, alphabetic, or other conventional symbolic expression,
· the Bank does not service bearer securities,
· blocking operations involving persons on the list of terrorists,
· blocking operations if the client fails to provide the necessary documents or if there is information about the involvement/ potential involvement of the client in terrorist activities.