Commercial Aspects of Managing Customer Relationships: A Critical Look

In today’s fast-paced business environment, managing customer relationships is crucial for success. However, it’s equally important to ensure that these relationships are not used for nefarious purposes such as money laundering or terrorism financing.

Policy Objectives

The primary objective of our policy is to prevent the use of our products and services for money laundering, terrorism financing, or tax fraud purposes. We aim to maintain a reputation that is free from any association with illegal activities and ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.

Policy Scales

Our policy includes specific requirements for:

• Identifying customers through Know Your Customer (KYC) norms
• Classifying customer accounts based on AML-CTF risk assessments
• Conducting additional due diligence for high-risk customers
• Implementing internal controls to prevent money laundering risks
• Reporting suspicious transactions and freezing assets

Policy Application

All branches of our bank are required to implement policies and procedures that comply with European and French legislation, including:

• Identifying and knowing customers
• Maintaining adequate records
• Providing training for employees
• Recognizing and reporting suspicious transactions
• Ensuring all necessary controls and communications are in place

Sanctions

Failure to comply with AML-CTF regulations can result in severe sanctions, including:

• Disciplinary actions by the competent authorities
• Criminal penalties, such as a EUR 15,000 fine or one-year imprisonment for ignoring anti-money laundering obligations
• Up to five years imprisonment for money laundering, as defined by the Penal Code

Monitoring of Transactions

We have procedures in place to monitor customer transactions, including:

• Generating reports on a frequent basis
• Reviewing any transaction that does not fit within a customer’s profile
• Determining whether it gives rise to any suspicion of money laundering

Suspicious Activity Reporting

Any staff member who identifies an account, activity, or transaction that is suspicious must report it in writing to our Anti-Money Laundering Compliance Officer and branch manager. The officer will then report the transaction to the Financial Intelligence Unit (TRACFIN).

Maintaining and Updating Information

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

Staff Training

All employees who have potential contact with customers or process transactions on behalf of customers are required to undertake anti-money laundering training on a regular basis. This ensures that our staff is equipped to identify and report suspicious activity.

Conclusion

Managing customer relationships requires not only building strong relationships but also ensuring that these relationships are free from illegal activities. By implementing robust policies and procedures, we can prevent money laundering and terrorism financing while maintaining a reputation for integrity and compliance.