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Bank’s Anti-Money Laundering and Combating Financing of Terrorism Policy

Introduction

As part of our commitment to maintaining high standards of integrity and transparency, [Bank Name] has implemented a robust anti-money laundering (AML) and combating the financing of terrorism (CFT) policy. This policy aims to prevent the use of our financial services for illegal activities and ensure compliance with relevant French and European regulations.

Policy Objectives

To identify and know our customers, ensuring that adequate records are kept and preserved.
To provide training for relevant employees to enable them to understand and fulfill their obligations under the French legislation and other local requirements.
To recognize and report suspicious transactions to the AML-CFT Officer, who will determine whether a report is to be made to the authorities.
To ensure that all necessary controls and communications are in place and operating effectively to prevent money laundering.

Reporting of Suspicious Transactions and Freezing of Assets

We have implemented procedures for reporting suspicious transactions to the Financial Intelligence Unit (FIU) and freezing assets as required by French regulation.

Regular Internal and External Audit

To ensure compliance with this policy, we conduct regular internal audits and external audits by regulatory bodies to assess our AML-CFT controls and procedures.

Procedures for Training of Employees on AML-CFT Requirements and Procedures

All employees having potential contact with customers or processing transactions on behalf of customers are required to undertake AML-CFT training on a frequency adapted to the needs of the latter (at least once a year).
Resources and materials are easily accessible and made available to all relevant staff.

Mandatory Regulatory Reporting for Regulators and Financial Intelligence Units

We ensure that all necessary reports are submitted to regulatory bodies and FIUs in a timely manner, as required by French regulation.

Sanctions

Failure to comply with AML-CFT obligations may result in criminal or disciplinary sanctions, including imprisonment, fines, and penalties. We take these risks seriously and ensure that all employees understand the importance of compliance with this policy.

Monitoring of Transactions

We have implemented procedures to monitor customers’ transactions.
Generate reports on a frequent basis.
Review any transactions that do not fit within a customer’s transaction profile.

Suspicious Activity Reporting

Any staff identifying an account, activity, or transaction deemed suspicious must report it to the AML-CFT Officer and Branch Manager through a written Suspicious Transaction Report (STR).
The AML-CFT Officer will then report the transaction to the FIU.

Maintaining and Updating Information

We maintain information relating to customers during five years following the carrying out of the transaction or business relationship, as required by French regulation.

Responsibility

Each and every individual in [Bank Name] is responsible for enforcing and respecting this policy. The Anti-Money Laundering Head at the Head Office is the day-to-day custodian of the policy and controls amendments to it.

Contact Information

For any questions or concerns about our AML-CFT policy, please contact our Anti-Money Laundering Compliance Officer at [email address] or [phone number].