The Bank of Moscow (hereinafter referred to as the "Bank") is one of the largest universal commercial banks in the Russian Federation according to key indicators such as assets, capital, retail client deposits, etc.
The Bank offers a wide range of banking services, including loans, securities market transactions, deposits, payments and account services, foreign exchange operations, foreign trade operations, management of cash assets, transactions involving precious metals, depository and other services.
The Bank has developed internal rules and recommendations on anti-money laundering and countering the financing of terrorism (hereinafter referred to as "AML / CFT"), which must be respected by all the Bank’s structural units, including branches and offices within the Russian Federation and abroad, provided it does not contradict the law of the State in which they are located.
The main goals and objectives of the Bank’s Policy on AML / CFT are:
- Ensure the Bank’s compliance with all applicable laws and regulations in the field of activities to counter money laundering and the financing of terrorism, as well as international standards for global adherence to international sanctions.
- Ensure client identification, also in relation to the client’s representatives and the verification and identification of their beneficiaries, in order to implement the KYC (Know Your Customer) principle.
- Implement due management of risks arising in connection with the laundering of proceeds from criminal activities and financing of terrorism, without risking the violation of the global sanctions regime.
- Regular monitoring of the implementation of these objectives.
- Protection of the Bank’s business reputation, and that of its clients.
- Application of KYC guidelines as a key principle to the implementation of the Bank’s operations.
Minimum standards applicable to the Bank include:
- The Financial Control Department and the compliance office are responsible for ensuring the proper implementation of the Bank’s AML / CFT policies and procedures, the Bank’s compliance with the applicable legislation, regulations, rules and the adoption of best practices and standards in this area.
- Develop and implement a risk-based approach, including risk assessment and management in the field of AML / CFT risks and violations of global sanctions.
- Develop and apply the Know Your Customer approach based on the definition of risk, customer identification and due diligence, including increased screening of clients carrying a high level of risk of connection with money laundering or terrorism financing.
- Internal procedures for the transfer of information regarding transfer of funds subject to mandatory control, and anticipation of suspicious transactions.
- Storage of information within the required timeframe.
- Training of all staff concerned with the provisions of applicable laws and internal regulations regarding AML / CFT.
- Maintaining effective interaction between departments and employees, presence of internal control procedures, monitoring and reporting to ensure full understanding and implementation by Bank staff of the rules and procedures for AML / CFT.
In order to prevent the use of the Bank’s products and services in operations connected with money laundering or the financing of terrorism, as well as to comply with the global sanctions regime, all Bank employees shall observe the above standards.