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.
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.
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.
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.
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.
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.
All employees shall receive AML training upon hiring and undergo regular refresher training to ensure awareness and compliance with AML policies and procedures.
ECB shall cooperate fully with regulatory authorities, including providing requested information and reports, and notifying them of any significant AML-related issues or developments.
ECB shall conduct regular independent reviews of its AML program to assess its effectiveness and identify areas for improvement.
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.