Financial Crime World

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Policy Document

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Introduction

This comprehensive policy document outlines the measures taken by Banco de la Nación Argentina to prevent and control money laundering and terrorist financing risks within the bank. The policies and procedures outlined in this document demonstrate the bank’s commitment to adhering to international standards for AML/CFT compliance, protecting its customers’ rights, and upholding the bank’s reputation as a trustworthy financial institution.

Key Policies and Procedures

1. Appointment of a Compliance Officer

  • The bank will appoint a Compliance Officer responsible for ensuring compliance with AML/CFT laws and regulations.
  • The Compliance Officer will be responsible for implementing internal policies and procedures related to AML/CFT.

2. Training Policy

  • The bank will develop a triennial Training Plan to train all personnel on regulatory standards, policies, and procedures related to AML/CFT.
  • The training plan will ensure that all staff members are aware of their roles and responsibilities in preventing and controlling money laundering and terrorist financing risks.

3. Document Preservation Policy

  • Documents submitted by customers will be analyzed, safeguarded, and made available upon request from relevant authorities to support investigations.
  • The bank will maintain accurate records of all customer transactions and financial activities.

4. AML/CFT Prevention System Review

  • The bank will conduct a comprehensive assessment of its Prevention System every two years to review its quality and efficiency.
  • The review will identify areas for improvement and provide recommendations for enhancing the Prevention System.

5. Trustworthiness of Directors, Employees, and Collaborators Policy

  • Adequate preselection, onboarding, and monitoring systems will be implemented for all staff members.
  • The bank will conduct thorough background checks on all new hires to ensure their trustworthiness.

6. Customer Assistance Policies

  • Specific controls will be strengthened for customers conducting activities related to Cooperatives and Mutuals (authorization by INAES is required).
  • National, provincial, and municipal bodies, autarchic entities, and other public legal persons will also have specific controls in place.

7. Risk Mitigation Policy

  • The bank will implement measures to mitigate risks effectively.
  • Preventive measures appropriate to the nature of identified risks will be applied.

8. Cash Transactions Policy

  • Strengthened controls on cash transactions volumes and frequencies will be implemented.
  • The bank will analyze potential controversy between account holder profiles and transaction methods/amounts.

Emphasis on Customer Rights

The document also emphasizes the importance of:

  1. Informed consent from customers regarding the collection, processing, and storage of their personal data.
  2. Privacy and confidentiality in all dealings with customers.
  3. Transparency and fairness in all aspects of banking operations.

By adhering to these principles, Banco de la Nación Argentina demonstrates its commitment to protecting its customers’ rights and upholding the bank’s reputation as a trustworthy financial institution.