Financial Crime World

Title: Caixa Geral de Depósitos, SA (CGD) in Timor-Leste: Fortifying Anti-Money Laundering and Counter-Terrorism Financing Measures

The East Timor Branch of Portugal’s Caixa Geral de Depósitos Reaffirms Commitment to Financial Crimes Combat

CGD, a Portuguese public limited company with a presence in Timor-Leste, has reiterated its dedication to preventing financial crimes, particularly money laundering and terrorist financing. As a controlled entity under the Bank of Portugal, CGD’s East Timor branch, also known as BNU Timor, is subject to both Portuguese and East Timorese regulatory frameworks.

Institutional Information

  1. Location: Avenida Presidente Nicolau Lobato, 12/13, Díli, Timor-Leste
  2. Regulatory Bodies:
  3. Credit Institution Code: 02
  4. External Auditors: Deloitte & Associados, SROC SA

Relevant International and National Frameworks

  1. FATF/GAFI Guidelines: Following the 40 recommendations of the Financial Action Task Force on Money Laundering and Terrorist Financing (FATF/GAFI).
  2. European Council and Parliament Directives: European Council and Parliament Directive 2005/60/CE and Commission Directive 2006/70/CE.
  3. Timorese Laws: Public Instruction no. 2/2004 and Law no. 17/2011.

AML/CTF Measures in International Operations

Branches and majority-owned subsidiaries outside Portugal adopt domestic laws’ equivalent measures to ensure compliance, addressing identification, due diligence, correspondent banking, record-keeping, and training.

Anti-Money Laundering and Counter-Terrorism Financing Measures in BNU Timor

  1. Customer Due Diligence/KYC: Identification, verification, and ongoing monitoring of CGD clients’ identities.
  2. Enhanced Due Diligence for PEPs: stricter identification, verification, and ongoing monitoring for politically exposed persons.
  3. No anonymous or numbered accounts: Each account is assigned a unique client identification number.
  4. Record keeping: Maintaining customer transaction records for a minimum of seven years.
  5. Monitoring of suspicious activities: Regular review of transactions and client behavior for inconsistencies.
  6. Suspicious transactions reporting: Reporting suspicious customer activities or transactions to the Financial Intelligence Unit of the Central Bank of Timor-Leste.
  7. Training: Ongoing AML/CTF training for employees.
  8. Independent audits and compliance reviews.
  9. Correspondent banks: Due diligence is performed on correspondent banks.
  10. Dealings with shell banks and payable-through accounts: Prohibited.
  11. Filtering of payments: Against watch lists and prohibited lists.

Adherence to Global Standards: Wolfsberg AML Questionnaire

BNU Timor follows the principles outlined in the Wolfsberg Anti-Money Laundering Questionnaire to combat money laundering and terrorist financing. The Questionnaire is publicly accessible on the bank’s website (www.bnu.tl).

Compliance with United States Regulations: USA Patriot Act Certificate

BNU Timor complies with regulations under the United States’ Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA Patriot Act) Act 2001. The USA Patriot Act Certificate can be found on CGD’s website (www.cgd.pt).