BANCO NACIONAL ULTRAMARINO, S.A. Anti-Money Laundering and Combating the Financing of Terrorism Disclosure Statement 1. Institutional Information Name: Banco Nacional Ultramarino, S.A. (BNU) Head Office Address: Avenida Almeida Ribeiro, No. 22, Macau (China) Place of incorporation: Macau (China) SWIFT BIC Code: BNULMOMX Legal status: Company limited by shares Shareholders: o Caixa Geral de Depósitos, S.A., Portugal (99.425%) o Caixa Participações SGPS, S.A., Portugal (0.2%) o Parbanca, S.G.P.S., S.A., Portugal (0.375%) Regulator: Monetary Authority of Macau (AMCM) External Auditor: Deloitte Touche Tohmatsu Limited AML/CFT contact: Head of Compliance Office address: Av. Almeida Ribeiro 22, Macau Email address: compliance@bnu.com.mo 2. Relevant International and Local Framework International Framework: 40 Recommendations of FAFT, developed in 1990, revised in 1996, 2003, 2004 and 2012 that provide counter-measures against money laundering and terrorist financing; United Nations (UN) Instruments and Resolutions.
Local Framework: Law No. 3/2017 on Prevention and Suppression of the Crime of Money Laundering; Law No. 3/2017 on Prevention and Suppression of Crimes of Terrorism; Administrative Regulation No. 17/2017 on Preventative Measures for the Crimes of Money Laundering and Financing of Terrorism; Law No. 6/2016 on the Legal Framework for Freezing of Assets; AML/CFT Guidelines issued by the Monetary Authority of Macau (AMCM). 3. Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Measures in BNU BNU has implemented policies, procedures and controls to ensure that it complies with AML/CFT obligations established in International legal instruments, local legislation (laws and regulations issued by Macau SAR) and regulatory obligations (guidelines issued by AMCM). BNU has adopted an AML/CFT program that reasonably identifies, mitigates and manages the risk of money laundering and terrorism financing according to the legislation. This program has been approved by the Board of Directors of BNU. Being Macau SAR a member of the Asia/Pacific Group on Anti-Money Laundering (APG) and associate member of Financial Action Task Force on Money Laundering (FAFT), BNU adheres to and applies the following policies and procedures: Know Your Customer (KYC)/ Customer Due Diligence (CDD): BNU has policies and procedures in place to comply with the obligation to identify and perform due diligence on customers. This includes an IT solution on filtering (to identify watchlist and proscribed lists) and an IT solution to classify customer s risk profile based on ML/TF risk.
Politically Exposed Persons (PEPs): BNU exercises enhanced due diligence on customers or beneficial owners who are PEPs. Anonymous and numbered accounts: BNU does not provide customers with anonymous or numbered accounts. Record Keeping: Records relating to customer identification and records of transactions (original documents, copies, references or any other durable support systems) are retained for the period defined in Macau law, even if the business relationship has already ended. Monitoring of Suspicious Activities: Screening of customer s transactions is carried out by an IT solution through a risk-based approach and also by the employees of the bank. Reports of Suspicious Transactions: BNU is required to report any suspicious customer activities or transactions to Financial Intelligence Office (GIF). Internal policies and procedures are in place to ensure compliance with the applicable legislation and regulatory requirements. Employee Training Program: Through an ongoing employee training programme, staff members are adequately trained in AML/CFT laws and regulations and relevant measures and procedures, including detection and reporting process for suspicious activities. Employee due diligence: BNU has processes that provide reasonable assurance of the identity, honesty and integrity of prospective and existing employees. Independent audit and compliance function: Internal audit and compliance department conduct tests to reasonably assure the operations are in compliance with internal
policies procedures, including those applicable to AML. The annual audit programs are approved by the Board of Directors. Compliance Officer: BNU has an AML/CFT Compliance Officer to oversee its AML/ CFT policies, practices and procedures. Correspondent Banks: When establishing or maintaining correspondent banking relationship, BNU performs compliance risk classification and conducts due diligence procedures using risk-based approach that include the following understanding the nature of the correspondent s business, its license to operate, the quality of its management, ownership and effective control, its AML policies, external oversight and prudential supervision including its AML/CFT regime. Additionally, ongoing due diligence of correspondent accounts is performed on a regular basis or when circumstances change. All correspondent banking relationships are approved by the Executive Committee. Shell Banks: BNU does not conduct business with shell banks. Payable-through accounts: BNU does not provide payable through accounts. Filtering against watch lists and proscribed lists (including sanctions lists): BNU has an IT solution to filter account openings, customers and transactions against UN, EU and OFAC proscribed lists. Sanctions Policy: BNU has implemented a set of policies and procedures to ensure that the bank does not establish or maintain a business relationship, or process operations to/for the benefit of sanctioned persons, entities or countries. BNU collaborates actively with the supervisory authorities on the enforcement of its sanctions policy.
4. Wolfsberg AML Questionnaire BNU follows the principles contained in Wolfsberg AML Questionnaire on AML/CTF. The Wolfsberg AML Questionnaire for BNU is available in www.bnu.com.mo. 5. USA Patriot Act Certificate Under the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA Patriot Act) Act 2001, BNU may be required from time to time to provide Certification Regarding Accounts for foreign banks. The USA Patriot Act Certificate is available in www.bnu.com.mo.