Exim Credit Bank Anti-Money Laundering (AML) Policy and Procedure

I. Introduction

Exim Credit Bank (ECB) is committed to maintaining the highest standards of integrity and compliance with all applicable anti-money laundering (AML) laws and regulations. This policy and procedure document outlines ECB's commitment to detecting and preventing money laundering and terrorist financing activities.

II. AML Policy

A. Purpose

The purpose of this AML policy is to:
- Establish clear guidelines and procedures to identify, detect, and report suspicious transactions.
- Comply with all relevant AML laws and regulations, including but not limited to the Bank Secrecy Act (BSA), the USA PATRIOT Act, and international AML standards.
- Provide ongoing AML training to employees.
-Ensure effective communication and cooperation with regulatory authorities.
-Prevent ECB from becoming a conduit for money laundering, terrorist financing, or other illicit activities.

B. Responsibilities

ECB's Board of Directors is ultimately responsible for ensuring that the bank has adequate AML policies and procedures in place and that it remains in compliance with AML laws and regulations.
The Chief Compliance Officer (CCO) is responsible for overseeing and implementing the AML program, including conducting risk assessments, developing policies and procedures, and reporting to the board.
All ECB employees are responsible for understanding and adhering to this AML policy, reporting suspicious activities, and participating in AML training programs.

C. Risk Assessment

ECB shall periodically assess the risks associated with its products, services, customers, and geographic locations. The risk assessment will help identify high-risk areas that require enhanced due diligence and monitoring.

III. AML Procedures

A. Customer Due Diligence (CDD)

ECB shall establish customer identification procedures to verify the identity of all customers and beneficial owners.
Enhanced due diligence (EDD) will be performed for higher-risk customers, including politically exposed persons (PEPs) and customers from high-risk jurisdictions.
Ongoing monitoring of customer accounts for suspicious activities will be conducted, and records will be maintained as required by law.

B. Reporting and Record Keeping

ECB shall maintain records of customer information, transactions, and suspicious activity reports (SARs) as required by law.
Employees must promptly report any suspicious transactions to the designated AML officer, who will investigate and, if necessary, file SARs with the appropriate authorities.

C. Employee Training

All employees shall receive AML training upon hiring and undergo regular refresher training to ensure awareness and compliance with AML policies and procedures.

D. Communication with Regulatory Authorities

ECB shall cooperate fully with regulatory authorities, including providing requested information and reports, and notifying them of any significant AML-related issues or developments.

E. Independent Review

ECB shall conduct regular independent reviews of its AML program to assess its effectiveness and identify areas for improvement.

IV. Conclusion

Exim Credit Bank is committed to maintaining a robust AML program to prevent money laundering and terrorist financing activities. This policy and procedure document will be reviewed and updated as necessary to ensure continued compliance with all applicable laws and regulations.