Preventing Money Laundering and Terrorism Financing: [Bank Name]’s New Group-Wide Policy

[Date]

To strengthen its anti-money laundering (AML) and counter-terrorism financing (CTF) measures, [Bank Name], a leading financial institution, has implemented a group-wide policy aimed at preventing the misuse of its systems and structures for illegal activities.

The new policy requires all group entities and subsidiaries to share information in compliance with relevant laws and regulations. This exchange of information is facilitated by the Anti-Money Laundering Compliance Office (AMLCO), which oversees and coordinates the process under the supervision of the bank’s AMLCO.

Measures to Prevent Complex Structures

The policy outlines measures to ensure that complex structures and non-transparent activities within the bank’s own structure are avoided.
The bank will conduct a risk assessment to identify potential issues and ensure that any structures set up comply with EU and international standards on tax transparency, AML/CTF, and other relevant regulations.

Senior Management Oversight

The policy requires senior management to have a clear understanding of the nature, purpose, and risks associated with complex structures. It also ensures that internal control functions are engaged in a timely manner. All opaque or unnecessarily complex structures must be approved by senior management.

Capital Requirements for ML/TF Risks

The bank has implemented measures to calculate capital requirements emanating from ML/TF risks as part of its Internal Capital Adequacy Assessment Process (ICAAP).
This includes scenarios drafted for money laundering, terrorist financing, and sanctions risk, as well as historical data and existing mitigating measures considered to calculate expected losses.

Roles and Responsibilities

The policy outlines the roles and responsibilities within the bank, including:

Board of Directors
Audit Committee
Executive Committee
Compliance Division
Risk Management Division
Internal Audit Division

Each entity is responsible for ensuring that the policy is effectively implemented and monitored.

Implementation Procedures

Written, well-documented, and detailed procedures for the monitoring of the policy
Training for all relevant staff to mitigate compliance risks

Commitment to AML/CTF

“We are committed to preventing money laundering and terrorism financing and protecting our customers’ assets,” said [Bank Representative]. “This new policy demonstrates our commitment to maintaining a robust AML/CTF framework that is in line with international standards.”

The bank has already begun implementing the new policy, which will be periodically assessed and reviewed by internal audit and risk management divisions.