UNISTREAM’S Policy on Combating Money Laundering and Financing of Terrorism
For the purposes of combating money laundering and financing of terrorism, UNISTREAM Commercial Bank (hereinafter referred to as “the Bank”) has drawn up and implemented an internal control system to combat money laundering and financing of terrorism (“CML/FT System”).
The underlying principles of the CML/FT system are to stop the Bank and its staff becoming involved in unlawful actions connected with money laundering and to preclude the possibility of conducting operations connected with financing of terrorist activities.
The CML/FT System is organised in line with the requirements of Russian Federation law in the sphere of CML/FТ and the legislative and regulatory acts of the Central Bank of the Russian Federation, and takes account of the recommendations drawn up by international organisations: the Financial Action Task Force, the Basel Committee on Banking Supervision, the Wolfsberg Group, the Eurasian Group on Combating Money Laundering and Financing of Terrorism etc.
In compliance with the US Foreign Account Tax Compliance Act, the Bank is registered as a Participating Foreign Financial Institute with the US Internal Revenue Service and has been assigned individual identification number GIIN 2S1RNS.99999.SL.643
Following the Know Your Client principle, the Bank maintains a position of unconditional transparency in its business operations with clients throughout the period of service.
In accordance with Federal Law No.115-FZ dated 07.08.2001 on Countering Legalization (Laundering) of Proceeds of Crime and Financing of Terrorism, the Bank has set up a unit to counter money laundering and financing of terrorism.
The Bank’s activities in the sphere of CML/FT are regulated by its Internal Control Rules — a comprehensive document describing the full set of measures and procedures undertaken by the Bank for the purposes of CML/FT. Application of the CML/FT Internal Control Rules is ensured by a dedicated Bank officer — the responsible employee.
In the implementation of its CML/FT Internal Control Rules the Bank ensures:
- application of the procedures for managing money laundering and financing of terrorism risks;
- documentation of information on measures taken by the Bank for the purposes of CML/FT;
- confidentiality of information on measures taken by the Bank for the purposes of CML/FT;
- timely submission of information on CML/FT issues to the competent body (Russian Federal Monitoring Service).
The CML/FT System incorporates:
- Identification of clients, client representatives, beneficiaries and beneficial owners in accordance with the Regulations of the Bank of Russia No.499-П dated 15.10.2015 on Identification by Lending Organisations of Clients, Client Representatives, Beneficiaries and Beneficial Owners for the Purposes of Combating Money Laundering and Financing of Terrorism;
- Review and in-depth analysis of the client by applying the Know Your Client principle, including compliance with the standards of prudence and client due diligences;
- Identification of actual beneficial owners;
- Risk-based application of procedures for the management of client risk and the risk of using banking services;
- Analysis, monitoring and control of all client operations to identify operations giving rise to suspicions that they are being carried out for the purposes of money laundering or financing terrorism;
- Application of special control measures to certain categories of clients being accepted for service or already served by the Bank;
- Procedures to identify operations subject to mandatory control;
- Documentation and storage of information;
- Training of Bank staff in CML/FT issues, including an initial CML/FT briefing and annual scheduled and unscheduled training, taking due account of amendments to current CML/FT legislation.
When establishing correspondent relations, the Bank adheres to the following principles:
- It avoids correspondent relationships with banks incorporated in states and territories offering tax benefits and (or) not providing for the disclosure and submission of information when carrying out financial operations (offshore zones);
- It does not have correspondent accounts and does not maintain relationships with banks incorporated in states not participating in the system to prevent money laundering and financing of terrorism;
- It does not maintain relationships with non-resident banks which do not have permanent bodies of management in the states in which they are incorporated, and also does not have relationships with non-resident banks if it is known that their accounts are used by banks without permanent bodies of management in the territories in which they are incorporated.
The Bank continuously updates, modernizes and implements new anti-money laundering mechanisms and procedures designed to enhance the performance and effectiveness of its CML/FT system.