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COMPLIANCE PROCEDURES FOR BANKS IN TURKEY: A LOOK INTO THE COMBATING FINANCE OF TERROR AND MONEY LAUNDERING FRAMEWORK
Turkish Bank A.Ş has implemented a comprehensive compliance program to prevent money laundering and combat finance of terror, in line with regulatory requirements. The bank’s policies and practices are applied across all branches and financial subsidiaries.
Compliance Program Components
The written institutional policy and procedures under the scope of the compliance program include:
- Designating a Compliance Officer (MLRO): Designating a chief anti-money laundering officer (MLRO) and establishing a compliance unit responsible for coordinating and overseeing the anti-money laundering framework.
- Client Identification: Identifying clients, proxies, and beneficial owners, as well as detecting suspicious transactions.
- Risk Assessment: Conducting risk assessments of customers considering geographic risk, business/activity risk, product and service risk, and flagging high-risk clients.
- Enhanced Due Diligence: Implementing enhanced due diligence and requiring senior management approvals for high-risk groups of clients and politically exposed persons (PEPs).
- Sanction Screening: Screening client names and transactions against sanction and embargo lists provided by domestic and international authorities.
Additional Measures
The bank also prohibits direct or indirect accounts/relationships with shell banks, and bans providing financial services to companies engaged in business activities related to anti-personnel mines, cluster bombs, nuclear weapons, biological and chemical weapons, depleted uranium ammunitions.
Monitoring and Control Activities
Turkish Bank A.Ş conducts monitoring and controlling activities to detect unusual and potentially suspicious transactions, and reports such activities to the Financial Investigation Board of Turkey (MASAK). The bank also keeps records and documents for at least ten years and reviews client information on a risk-based approach.
Staff Training
The bank’s compliance program includes yearly planned training activities for staff, covering topics such as:
- Laundering proceeds of crime and terrorist financing
- Legislation regarding prevention of money laundering and terrorist financing
- Risk areas
- Institutional policy and procedures
Regulatory Compliance
Turkish Bank A.Ş is required to submit its institutional policies and amendments to MASAK within thirty days of amendment, and notify related staff by taking their signatures. The bank’s compliance program is regularly controlled by internal or independent external auditors, as well as public auditors authorized by MASAK for inspection of the bank’s anti-money laundering policies and practices.
Contact Information
For further information on the bank’s money laundering prevention measures, please contact a.cakir@turkishbank.com.