Policy of JSC "MB Bank"

In the field of combating legalization (laundering) of proceeds from crime, financing of terrorism, extremist activity and financing the proliferation of weapons of mass destruction

The implementation of measures for fighting against legalization of criminal proceeds and financing of terrorism is an important aspect in the activities of JSC "MB Bank" (hereinafter - the Bank). Given the threat posed to the entire world community by terrorist and related organizations, the Bank has developed and put into operation the internal control organization program to counter the legalization (laundering) of proceeds from crime, the financing of terrorism, extremist activity and the financing of the proliferation of weapons of mass destruction (hereinafter - AML/CFT/EA/CFPW). The AML/CFT/EA/CFPWMD system in the Bank is based on the principle of participation of all Bank employees, regardless of their position, within their competence, in the work aimed at preventing transactions that are directly or indirectly related to legalization (laundering) of the proceeds of crime, as well as excluding the possibility of conducting transactions related to the financing of terrorist or extremist activities and the financing of the proliferation of weapons of mass destruction. One of the main tools used to ensure the effective functioning of the AML/CFT/EA/CFPWMD system at the Bank is high-quality training of personnel on AML/CFT/EA/CFPWMD issues.

To correspondent banks and counterparties of JSC “MB Bank

The Bank informs that pursuant to the requirements of Federal Law No. 115-FZ and regulatory legal acts in the field of AML/CFT/EA/CFPWMD, as well as in accordance with the recommendations of the Financial Action Task Force (FATF), the Bank is fully implementing a set of measures aimed at AML/CFT/EA/CFPWMD.

Functioning of the system on AML/CFT/EA/FPWMD is regulated by “Internal Control Rules on AML/CFT/EA/FPW in JSC “MB Bank” (hereinafter referred to as “the Rules”). The implementation of the Rules is carried out taking into account a risk-based approach, risk management of legalization of proceeds from crime, financing of terrorism, extremist activity and financing the proliferation of weapons of mass destruction aimed at minimizing it.

The main objectives of the AML/CFT/EA/CFPWMD Policy are: preventing the use of the Bank as a tool for laundering (legalization) of proceeds from crime, financing terrorism or extremist activity or financing the proliferation of weapons of mass destruction, protecting the business reputation of the Bank and its clients, ensuring prevention of potential risks associated with laundering (legalization) of proceeds from crime, financing terrorism, extremist activity and financing the proliferation of weapons of mass destruction.

In order to organize the internal control system, the Bank established an AML/CFT/EA/CFPWMD unit and appointed a Responsible employee - a special official responsible for the implementation of the Rules.

The Bank takes all possible and necessary measures to prevent transactions that can directly or indirectly be related to the legalization (laundering) of proceeds from crime, as well as to exclude the possibility of conducting transactions related to the financing of terrorist or extremist activities and the financing of the proliferation of weapons of mass destruction.

The Bank targets at maintaining a high business reputation and minimizing the risks associated with implication of it in doubtful financial schemes orchestrated by unscrupulous customers. In this regard, the Bank fully applies the "Know Your Customer" policy, approaches the selection and formation of the customer base with reasonable care, carefully studies their potential clients, interests and areas of their activities and seeks to establish relationships, based on transparency and understanding of the business and operations of clients, monitoring and analysis of the activities of organizations and individuals who are already clients of the Bank are also carried out. The "Know Your Customer" policy involves not only collecting, analyzing, and processing information about the customer when they first contact the Bank, but also keeping the information up to date, in connection with which the Bank ensures regular updating of previously received information about the customers. Relevance assessment and sufficiency of existing methods and monitoring procedures are conducted continually, concurrently with emergence and proliferation of new techniques of money laundering, amendments to the legislation and dissemination of international practice.

The Bank does not open or maintain accounts (deposits) for anonymous owners, that is, without providing the opening account (deposit) by an individual or a legal entity, a foreign structure without forming a legal entity with documents and information necessary for its identification, and also does not open or maintain accounts (deposits) for owners using fictitious names (pseudonyms).

The Bank does not establish or maintain correspondent relations with non-resident banks that do not have permanent governing bodies in the territories of the states in which they are registered.

The Bank does not enter into bank deposit agreements with the execution of documents certifying the bearer deposit.

The Bank refuses to accept clients for service, including when concluding a bank account (deposit) agreement with the clients, in case of failure to provide documents and information necessary to identify the clients, the client's representative, beneficial owners and beneficiaries, except for the cases to which the requirements for identification set by Federal Law No. 115-FZ are not spread.