Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Anti-Mney Laundering Plicy May 2016
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management TABLE OF CONTENTS 1. Backgrund... 3 2. Gals f the bank s anti-mney laundering wrk... 3 3. Descriptin f the bank s anti-mney laundering wrk... 3 3.1. Organisatin, rles and respnsibilities... 3 3.2. Gvernance cycle... 4 3.3. Schematic verview the bank s framewrk and respnsibilities anti-mney laundering... 5 Appendix 1 Definitins Appendix 2 Matrix f respnsibility
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management 1. Backgrund Pursuant t Sectins 2, 4 and 23 f the Mney Laundering Act f 15 April 2009, a financial institutin shall have satisfactry internal cntrl and cmmunicatin prcedures in place that ensure fulfilment f the bligatins under the Act. The bank s anti-mney laundering plicy shall be adpted by the Bard f Directrs. In additin, a persn frm management shall be appinted wh shall have special respnsibility fr the preventin f mney laundering. The bank shall implement necessary measures t ensure that the staff are familiar with the duties impsed n them by the regulatins. 2. Gals f the bank s anti-mney laundering wrk Sparebanken Vest shall at all times have a framewrk in place that prevents the bank frm being used fr mney laundering f the prceeds f crime r frm cntributing t terrrist financing. The wrk f uncvering mney laundering and terrrist financing shall be given high pririty. 3. Descriptin f the bank s anti-mney laundering wrk The bank s anti-mney laundering wrk is rganised in accrdance with the structure and framewrk described in this plicy. 3.1. Organisatin, rles and respnsibilities The bank has chsen t appint a persn respnsible fr the preventin f mney laundering and a persn with peratinal respnsibility fr the bank s anti-mney laundering wrk. The persn respnsible fr the preventin f mney laundering pursuant t Sectin 23 f the Mney Laundering Act f 15 April 2009 is the Directr f Risk Management. This persn has been assigned verall respnsibility fr the bank s anti-mney laundering wrk. This includes in particular updating the risk analysis and framewrk, as well as reprting t the bank s management and Bard f Directrs. These tasks are carried ut by Legal and Cmpliance. A specialist AML functin has been assigned peratinal respnsibility fr anti-mney laundering wrk. This functin shall attend t tasks that arise n an nging basis relating t the anti-mney laundering wrk, including supprt/prpsals fr the maintenance f prcedures, system supprt, reprting t the Natinal Authrity fr Investigatin and Prsecutin f Ecnmic and Envirnmental Crime (Økkrim), reprting t the persn respnsible fr the preventin f mney laundering, and training f staff.
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Day-t-day custmer due diligence and initial assessments are carried ut by custmer service staff. A mre detailed verview f rles and respnsibilities is set ut in a dedicated matrix f respnsibilities (Appendix 2). 3.2. Gvernance cycle Anti-mney laundering wrk is a cntinuus prcess, as illustrated by the gvernance cycle. Infrmatin t the management and Bard abut mney laundering shall be integrated in the bank s management reprt (LIS). Fig.1 Illustratin f the gvernance cycle fr the bank s anti-mney laundering wrk The key cmpnents f the bank s gvernance cycle are: Risk analysis (analysis f the risk f mney laundering and terrrist financing). The risk analysis frms the basis fr risk-based custmer and transactin due diligence and defines the bank s cntrl level fr anti-mney laundering. A risk calculatr < link > has been prepared that custmer advisers can use t determine the cntrl level. Framewrk and system fr the anti-mney laundering wrk Risk-based custmer and transactin due diligence (cntinuus measures t uncver and prevent attempts at mney laundering)
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Cntinuus reprting Updating f the risk analysis (based n evaluatins f experience, incidents bserved and cntrl measures carried ut) Reprting t the bank s senir management and Bard. The risk analysis, framewrk and systems are evaluated cntinuusly, and at least nce a year in cnnectin with ICAAP 1. Changes are implemented as necessary if custmer due diligence and ther factrs uncver changes in the risk situatin. Respnsibility fr cntinuus custmer due diligence and reprting rests with the custmer business areas. 3.3. Schematic verview the bank s framewrk and respnsibilities anti-mney laundering In additin t this plicy, the bank s framewrk cnsists f <link t each dcument>: The risk analysis Prcedures Establishing custmer relatinships RM the prcedure applies t custmer service staff wh establish new custmer relatinships with retail custmers (sectr cde 8500) Establishing custmer relatinships CM the prcedure applies t custmer service staff wh establish new custmer relatinships nt cvered by sectr cde 8500 1 Internal Capital Adequacy Assessment Prcess
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Cntinuus fllw-up RM the prcedure applies t custmer service staff wh are t prvide cntinuus fllw-up f retail custmers (sectr cde 8500) Cntinuus fllw-up CM the prcedure applies t custmer service staff wh are t prvide cntinuus fllw-up f new custmer relatinships nt cvered by sectr cde 8500 Cntinuus fllw-up f peratinal anti-mney laundering respnsibility the prcedure applies t the persn with peratinal respnsibility fr anti-mney laundering wrk and describes, amng ther things, duties relating t maintenance f the risk analysis and AML Risk (autmatic, risk-based custmer fllw-up) Investigatin and reprting f suspicius transactins. The prcedure applies t staff wh are in cntact with custmers. Investigatin and reprting f suspicius transactins persn with peratinal respnsibility fr anti-mney laundering. The prcedure applies t the persn with peratinal respnsibility fr the anti-mney laundering wrk. Retentin and filing f identity dcuments. The prcedure applies t staff wh are in cntact with custmers and wh check identity dcuments when pening a custmer accunt. Training f staff. The prcedure applies t staff wh are in cntact with custmers. Risk calculatr descriptin. The prcedure applies t staff wh are in cntact with custmers and wh establish new custmer relatinships (all sectr cdes), r wh are t recnsider the risk f mney laundering. Valid ID dcuments RM. A checklist fr what ID dcuments are valid and which custmer relatinships they can qualify fr.
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Appendix 1 Definitins: Custmer relatinship A custmer relatinship is an agreement cncerning the bank s prvisin f services t a physical r legal persn. The services typically include agreements n accunts, lans, securities accunts etc. Plitically expsed persn (PEP) A plitically expsed persn is a physical persn wh either hlds r has previusly held a high public ffice in Nrway r abrad. It may als refer t a clse family member/emplyee. Beneficial wners A beneficial wner is a physical persn wh directly r indirectly wns r cntrls a cmpany (custmer). The persn must wn r cntrl at least 25% f the cmpany/enterprise. Terrrist financing Terrrist financing includes all transactins linked t acts f terrrism, including financing, sliciting, planning r recruiting peple fr such acts. It includes making mney, ther assets r banking services available t physical r legal persns wh carry ut acts f terrrism r wh wn/cntrl smene wh carries ut such acts. Transactin In this cntext, a transactin means any frm f transfer, mediatin, exchange r placement f assets. Typical examples include dmestic and freign payment transfers, depsits t and withdrawals frm accunts, purchase/sale f banker s drafts, repayment f debt etc.
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Appendix 2 Matrix f respnsibility Duties Custmer service staff RM / CM AML functin Establishing custmer relatinships, including checking identity dcuments and sending dcuments fr filing Cntrl and fllw-up f existing custmers Legal and Cmpliance Investigating suspicius transactins and reprting t the persn with peratinal respnsibility fr anti-mney laundering Receiving ntificatins f suspicius transactins frm custmer service staff and external parties Investigating suspicius transactins, perfrming thrugh reviews and cnsidering reprting t Økkrim Electrnic mnitring f transactins Reprting t Økkrim and the persn respnsible fr the preventin f mney laundering Answering questins relating t prcedures Training staff
Date f latest apprval: 03.05.2016 Respnsible fr dcument: Kirsten Gulbrandsen Respnsible department: Risk Management Revising the risk analysis Updating the risk calculatr based n the revised risk analysis Updating the framewrk and prcedures based n the revised risk analysis in acc. with respnsibilities stipulated in the matrix. Reprting t management and Bard