Anti-Money Laundering (AML) Policy
Overview
Lebanese Swiss Bank S.A.L. is committed to preventing and detecting money laundering and terrorist financing activities through the implementation of this Anti-Money Laundering (AML) policy.
Risk Indicators
The bank identifies several risk indicators related to:
Customers
- Unusual patterns of deposit operations: Transactions that deviate from normal client behavior
- Multiple accounts under a single name or multiple names with large inter-account transfers: Suspicious activity involving multiple accounts
- Power of attorney given to non-professional individuals without justification: Unexplained delegation of power
- Business relationships conducted through false names, numbered accounts, or front institutions/companies: Suspected use of fake identities or shell companies
Economic Right Owner
- Uncertainty about the identity of the economic right owner: Difficulty in determining the true beneficial owner
- Financial status of the client not justifying the operation’s value: Transactions that do not align with the client’s financial situation
Other Risk Indicators
- Large cash transactions or foreign exchange operations: Suspicious activity involving large cash transfers or currency exchange
- Unusual account movements, such as large deposits without justification: Transactions that lack a clear explanation
- Operations aimed at transferring sizeable amounts abroad without justification: Suspicious international transactions
- Replacement of large cash funds with electronic transfers or bank checks: Conversion of cash to digital forms
Monitoring and Prevention
To monitor these risk indicators, the bank will use AML Reporter software to generate reports on accounts and operations that may raise concerns. The bank will also take measures to prevent the misuse of technological developments for money laundering or terrorist financing purposes.
Suspicious Behavior
This policy emphasizes that suspicious behavior is not a characteristic of individuals but rather a consideration of many factors. It requires the assessment of various indicators, not any single factor, to determine whether an activity may be related to money laundering or terrorist financing.
Importance of AML Policy
This AML policy is essential for Lebanese Swiss Bank S.A.L. to maintain its commitment to preventing and detecting financial crimes, ensuring the integrity of its operations, and maintaining a safe and secure banking environment for its customers.