AK BARS Bank’s Anti-Money Laundering Policy

For realization of measures against money laundering and terrorist financing AK BARS Bank implements info-cognitive activity aimed at detecting possible crimes, records the information and sends it to the respective authorized body for taking a decision on delivery of facts to law bodies.

The Bank:

• traces attempts of money laundering in the process of banking operations;
• identifies clients;
• records and submits data about suspicious operations with monetary funds or any other assets, as well as about the persons involved in such operations to the authorized bodies.

In addition, the Bank actually ensures proper functioning of the specialized criminal record system: accumulates, systematizes, identifies data about operations, transactions and persons mentioned in the law, stores collected information on a confidential basis and delivers it to the authorized bodies by their request.

For realization of the regulations stipulated by the Federal Law dd. August 7, 2001 # 115-FZ „On Counteracting Legalization (Laundering) of Proceeds from Criminal Activity and Terrorist Financing“ and further recommendations of the Bank of Russia dd. November 11, 2001 # 137-Т and dd. July 13, 2005 # 99-Т AK BARS Bank worked out „Rules of Internal Control against Legalization (Laundering) of Proceeds from Criminal Activity and Terrorist Financing“, which contain programs of implementing of internal control on counteracting money laundering; criteria of risk assessment, including risk assessment by geographical character and types of business; criteria of detecting of unusual transactions and their character.

Methods used by the bank when detecting „suspicious“ organizations, operations or transactions for decreasing/liquidating of risk of clients’ involvement in money laundering include:

• analysis of documents describing the company — a potential customer, as well as character, turnover and efficiency of his business and, namely, facts which give rise to doubts about its legal capacity, economic efficiency and business reputation;
• analysis of false data reported by the customer: establishment of the company, its management bodies and membership of these bodies, size of the registered and paid-in capital, number and membership of shareholders; circumstances relating to the economic activity of the company, namely: increase of receivables with overdue payments, increase of payables to budget bodies and due to banks, which are sometimes followed by accumulating of funds for further theft and legalization; significant account turnover which does not correspond to the size of business; sudden and unreasonable repayment of suspicious and overdue loans; system breach of normative requirements on documentation keeping and accounts, undue balance sheet recorded in auditor’s reports;
• analysis of the client’s location, his relations with the person who has been suspected in his involvement in extremist and terrorist actions, or his relations with the person directly or indirectly controlled by persons who are identified as persons connected with extremist and terrorist activities;
• analysis of the client’s desire to open an anonymous account; his unreasonable haste when being identified; his actions via an intermediary;
• analysis of the client’s transactions with less/more price than the contract fair price;
• analysis of the reliability of banks initiating the establishment of correspondent relations by terms of equity, share capital, international and national credit ratings;
• analysis of documents identifying a private customer (passport details, data on his permanent work, source of his revenues and paid taxes, his powers, if banking operations are conducted by power of attorney issued by a third person, etc.)

For realizing measures on detecting, keeping and delivery of information for counteracting the specific crimes the Bank worked out the respective programs on detecting and fixation of possible criminal actions, including programs of information fixation, specified in Article 7 of the Federal Law „On Counteracting Legalization (Laundering) of Proceeds from Criminal Activity“, and the „customer due diligence measures“ program.

Due to the dynamic development of the modern business the Bank regularly updates data received as a result of clients’ identification, no less than once a year if the Bank regards the risk connected with money laundering as high, and no less than once during 3 years in other cases.

The procedures of the compulsory control include:

• complete identification of counterparts under the transaction or operation („Know Your Customer“ policy), especially under the transaction connected with high risks;
• detecting and fixation of the „suspicious“ transaction or operation and delivering of this information to the government body accountable for counteracting „money laundering“.

For compliance with the Central Bank’s requirements on observing confidentiality on the client and his transactions the Bank applies facilities and measures of protecting any banking information.