In order to counteract money laundering and financing of terrorism (hereinafter — AML/CFT), Ak Bars Bank (hereinafter — the Bank), has established an Internal Control Program with the following principles and objectives:

Prevent proceeds from criminal activities from penetrating the Bank;
Minimize risks related to money laundering and financing of terrorism;
Ensure the independence of the special Officer in charge of the Internal Control Program;
Participation of the following persons and organizations in the detection of transactions subject to mandatory control and transactions wherein there exists suspicion of money laundering or financing of terrorism, irrespective of their positions within their area of competence:

Employees in charge of the AML/CFT Program and implementation of internal controls of AML/CFT activities;
Bank departments involved in banking and other activities;
Legal Department; Security Department; Department of Internal Control.

AML/CFT Internal Control Regulations were developed by the Bank with the following objectives:

Ensure Bank’s compliance with the requirements of Russian legislation in the field of AML/CFT;
Maintain an effective system of AML/CFT Internal Controls at the Bank at a level sufficient to manage the risk of money laundering and financing of terrorism;
Avoid involvement of the Bank, its directors and employees in activities related to money laundering and financing of terrorism.

AML/CFT Internal Control measures aim to:

Avoid involvement of the Bank in the implementation of the money laundering and financing of terrorism;
Guarantee all Bank’s employees’ compliance in following the requirements of Internal Control Regulations:

Participation of all Bank’s employees in AML/CFT internal control activities, regardless of their positions;
Compliance with banking secrecy and confidentiality of information accessed while executing AML/CFT internal controls;
Prevent Bank’s employees from participating in activities related to money laundering and financing of terrorism;
Prevent clients and other persons from gaining information related to the Bank’s AML/CFT internal control measures, except in the following cases: suspension of transactions, denial of clients’ requests related to transactions, denial of requests to open a bank account (place a deposit), notifications regarding clients’ obligations to provide documents as required by the Federal Law № 115-FZ;
Preserve confidentiality of AML/CFT internal policies and procedures.

Guarantee completeness and timeliness of information provided to the authorities as required by the Federal Law № 115-FZ.
Apply effective risk assessment and risk management procedures to enable prevention of money laundering and financing of terrorism.

General Principles Applied To Bank’s Activities

In order to avoid engaging in transactions related to money laundering and financing of terrorism, and management of associated risk, the Bank:

applies approaches set out in the Internal Control Regulations for the development and improvement of AML/CFT internal controls;
develops its own AML/CFT internal control procedures compliant with Russian law and Internal Control Regulations while following AML/CFT best practices used at the Bank;
takes measures to reduce risks associated with involvement in money laundering and financing of terrorism;
co-ordinates its own efforts while developing AML/CFT internal control measures;
ensures participation of all the Bank’s employees, regardless of position, in detecting transactions subject to mandatory control, and transactions involving money or property associated with money laundering and financing of terrorism;
ensures that the Bank’s employees respect confidentiality of information obtained while working at the Bank, including information about Bank’s clients, their operations, accounts and deposits;
establishes each employee’s personal responsibility for their actions;
provides strategic and procedural guidance and support, centralized management and monitoring of execution of the Bank’s AML/CFT requirements;
guarantees non-participation of the Bank’s employees in activities related to money laundering and financing of terrorism;
prohibits informing clients and other parties about AML/CFT measures taken by the Bank;
provides a centralized (at the location of the Bank headquarters) method of reporting to an authorized body via a local office of the Bank of Russia (the National Bank of the Republic of Tatarstan).

AML/CFT internal control is a part of the Bank’s Internal Controls Program executed by its employees and departments on a regular basis.

A responsible Internal Control Officer ensures the Bank employees’ compliance with Internal Control Regulations. He/she holds a management position and possesses experience and credentials sufficient to make independent decisions while performing his/her professional duties.

Bank’s Responsibilities Relating To AML/CFT Internal Control Regulations

The Bank’s responsibilities related to AML/CFT Internal Control Regulations are as follows:

to identify customers, their representatives and beneficiaries, except as set out in paragraphs 1.1 and 1.2 of Article 7 of Federal Law №115-FZ;
to keep information about clients and beneficiaries up-to-date;
to conduct research on its clients and their operations;
to document and submit the information required by the Federal law №115-FZ to the authorized body;
to suspend client operations for the duration established by the Federal Law №115-FZ (except for transferring funds to the client’s account), if at least one of its members is an organization or an individual having an existing indicator of involvement in extremist activity or terrorism, or a legal entity directly or indirectly owned or controlled by such organizations or persons, or a person or entity acting on behalf of or at the direction of such organizations or persons;
to take measures to avoid relations with non-resident banks registered on territories that are not governed by permanent regulatory bodies whose accounts may be used by other banks.
AML/CFT Internal Control Regulations prohibit the Bank:
to open accounts (deposits) for anonymous owners, that is, without such individuals or legal persons presenting identification documents necessary for opening accounts (deposits);
to open accounts (deposits) for individuals without their presence or the presence of their authorized representatives;
to build and maintain relations with non-resident banks registered on territories that are not governed by permanent regulatory bodies;
to open a bank account (deposit) for a client unable to present necessary identification documents for either the client or the client’s representative as stipulated by the Federal Law №115-FZ and Internal Control Regulations, and supporting information that must be documented as stipulated by the Federal Law №115-FZ and Internal Control Regulations;
to advise clients and other persons about the forms, techniques and methods utilized by the Bank’s AML/CFT internal control;
to prevent information regarding AML/CFT control reaching clients and others, except: to inform clients about suspension of a transaction, denial of a client’s requests related to a transaction, denial of a request to open a new bank account (deposit), or notifications regarding clients’ obligations to provide documents as specified by the Federal law №115-FZ.

AML/CFT internal control is a part of the Bank's Internal Controls Pprogram executed by its employees and departments on a regular basis.

A responsible Internal Control Officer ensures the Bank employees' compliance with Internal Control Regulations. He/she holds a management position and possesses experience and credentials sufficient to make independent decisions while performing his/her professional duties.