Policy of OJSC Belagroprombank and members of the bank holding company to prevent legalization of proceeds from crime, financing of terrorist activities and financing the proliferation of weapons of mass destruction

Chapter 1

GENERAL PROVISIONS

1. The policy of JSC Belagroprombank (hereinafter referred to as the Bank) and members of the bank holding company on the prevention of legalization of proceeds from crime, financing of terrorist activities and financing the proliferation of weapons of mass destruction (hereinafter referred to as the Policy) reflects the measures taken by the Bank and the participants of the bank holding company in accordance with:

the current legislation of the Republic of Belarus in the field of preventing legalization of proceeds from crime, financing of terrorist activities and financing the proliferation of weapons of mass destruction (hereinafter - AML / CFT);
normative legal acts of the National Bank, regulating the issues of financial monitoring;
the FATF Recommendations;
The General Directives on Anti-Money Laundering in the Private Banking Sector (Wolfsberg Principles);
local legal acts of the Bank.

2. Organization of the internal control system in the field of AML / CFT is aimed at achieving the following goals:

Prevention of intentional or unintentional involvement of the Bank and members of the bank holding company in the process of legalizing proceeds from crime, financing terrorist activities and financing the proliferation of weapons of mass destruction;
limitation (reduction) of risks associated with the danger of a financial transaction aimed at money laundering, terrorist financing and financing the proliferation of weapons of mass destruction (hereinafter - ML / FT).

When building a system of internal control in the area of AML / CFT, the Bank and the members of the bank holding company ensure:

compliance with the requirements established by the legislation of the Republic of Belarus for the subjects of the national AML / CFT system, taking into account the specifics of their activities, when developing measures in the field of AML / CFT;
information exchange of data in the field of AML / CFT and ML / FT risk management, including, if necessary, the provision of identification information about the client and his financial transactions to the participants of the bank holding company;
adequate protection of confidentiality and use of data obtained in the course of information exchange;
rendering mutual assistance in solving problems related to the operation of AML / CFT systems and (or) implementation of the rules of internal control in the field of AML / CFT.
Control over the activities of the members of the bank holding company is carried out in accordance with the local legal acts of the Bank.

3. The system of internal control in the area of AML / CFT is implemented in the following main areas:

identification and verification, in cases stipulated by law, of all clients of the Bank carrying out financial transactions, monitoring of their activities in the process of servicing;
identification, documentary recording of a financial transaction subject to special control, and transfer of relevant information to the financial monitoring body;
storage of information and documents (their copies) during the period established by the legislation of the Republic of Belarus.

4. The main principle of organizing the internal control system for AML / CFT is the participation of employees, as part of their job responsibilities, in the process of identifying customers and their representatives, questioning customers and identifying financial transactions subject to special control.

Chapter 2

MAIN DIRECTIONS

5. In order to manage the risks associated with ML / FT, the Bank implements extended internal control measures in the presence of a high degree of risk associated with ML / FT, and applies simplified internal control measures in the presence of a low degree of such risk.

The Bank conducts a self-assessment of its involvement in suspicious transactions related to ML / FT.

The Bank determines and assesses its own ML / TF risks, taking into account NRA , and takes measures to reduce them.

6. The Bank, within the framework of the implementation of the Policy, as well as in order to reduce the ML / TF risks:

conducts identification and verification of participants in a financial transaction in accordance with the legislation of the Republic of Belarus and records information in an electronic database of customer profiles with the possibility of prompt access to it by authorized employees of the Bank;
identifies from the Bank's clients and their beneficial owners foreign public officials, officials of public international organizations, persons holding positions included in the list of government positions of the Republic of Belarus determined by the President of the Republic of Belarus, members of their families and persons close to them (hereinafter - PEP), as well as organizations, the beneficial owners of which are these persons;
concludes with foreign public officials, organizations, beneficial owners, which they are, contracts for the implementation of financial transactions in writing after receiving the written permission of an authorized person of the Bank, and if the client has acquired the appropriate status and (or) the beneficial owner of the organization has become a foreign public official by a person after the conclusion of the contract, then the continuation (extension) of this contract is carried out with the written permission of the corresponding authorized person;
monitors the financial transactions of PEPs, as well as organizations, the beneficial owners of which are these persons, in the manner determined by the Internal Control Rules at JSC Belagroprombank for the prevention of legalization of proceeds from crime, financing of terrorist activities and financing the proliferation of weapons of mass destruction (hereinafter - Rules);
identifies and registers financial transactions subject to special control in a special form and submits it in the form of an electronic document to the financial monitoring body;
freezes funds owned or owned by a person included in the list of organizations and individuals involved in terrorist activities, formed by the authorized body of the Republic of Belarus (hereinafter - the List);
blocks a financial transaction if a person included in the List is a participant in this financial transaction or beneficiary of it;
upon identification of a financial transaction that meets the criteria that may be grounds for suspending or refusing to carry out a financial transaction, refusing to connect to the remote banking system, terminating or suspending the provision of services through this system, suspends until the responsible official of the Bank makes a decision on the implementation of the financial an operation or a refusal to carry it out;
when carrying out financial transactions related to money (bank) transfers on behalf of the sender (payer) for an amount equal to or exceeding 100 basic units, ensures at any stage of their implementation the receipt, transfer, and storage of information about the sender (payer) in order stipulated by the legislation of the Republic of Belarus;
applies extended internal control measures for identification if a participant in a financial transaction is registered, has a place of residence or location in a state (territory) that (which) does not participate in international cooperation in the field of AML / CFT or does not comply with the FATF recommendations, and if financial transactions are carried out using a bank account registered in such a state (territory);
does not open bank accounts for anonymous owners (without the person opening the account submitting documents necessary for identification), as well as for owners using fictitious names (pseudonyms);
takes measures to prevent the establishment of relations with non-resident banks, whose accounts are used by banks that do not have permanent management bodies in the territories of the states in which they are registered and are not members of a banking group (bank holding company);
does not establish or maintain relations with non-resident banks that do not have permanent management bodies in the territories of the states in which they are registered and are not members of a banking group (bank holding company);
promptly develops measures to mitigate risks in the event of an increase in the ML / TF risk ;
regularly trains the Bank's employees on AML / CFT issues in accordance with the Training Program for employees of JSC Belagroprombank on preventing money laundering, financing terrorist activities and financing the proliferation of weapons of mass destruction (hereinafter - the Training Program).

Chapter 3

ORGANIZATION OF THE INTERNAL CONTROL SYSTEM

7. As part of ensuring the basic principle of organizing the internal control system for AML / CFT, the Bank organizes a multi-level internal control system, the elements of which are:

the person responsible for the implementation of the Rules;
a special structural unit - the Financial Monitoring Department, which includes specialists in charge of financial monitoring issues;
persons responsible for organizing and coordinating internal control;
responsible officials;
Bank employees performing financial transactions on current (settlement) bank or other customer accounts and (or) customer service, identifying suspicious financial transactions, conducting customer identification.

8. The person responsible for the implementation of the Rules is the Deputy Chairman of the Management Board of the Bank, who directs the activities of the Financial Monitoring Department.

9. As part of the implementation of the Policy, the Financial Monitoring Department performs the following main functions:

development and methodological support of the Bank's local legal acts on AML / CFT;
coordination of the organization of the internal control system for AML / CFT in the Bank;
development of procedures for managing risks related to ML / TF;
prompt communication to structural divisions of regulatory legal acts, letters and clarifications on AML / CFT issues;
submitting proposals to the Bank's management to improve and increase the efficiency of the internal control system for AML / CFT;
participation in the process of introducing new banking products and services;
organization and participation in training of the Bank's employees, including testing of knowledge, in accordance with the Training Program;
advising the Bank's employees on AML / CFT issues;
assessing the adequacy of the system of criteria established in the Bank for identifying and signs of suspicious financial transactions;
preparation and submission to the Bank's Supervisory Board of a report on the results of the implementation of the Rules, recommended measures to improve the internal AML / CFT control system at least once a year;
interaction with the Financial Monitoring Department of the State Control Committee, the National Bank, the Association of Belarusian Banks on AML / CFT issues.

9-1. Participants of the bank holding company develop internal control rules in the area of AML / CFT, appoint persons responsible for their implementation, manage ML / FT risks taking into account the requirements determined by state bodies exercising control over the activities of members of the bank holding company in terms of their compliance with AML / FT.

Chapter 4

FINAL PROVISIONS

11. Information about customers received by the Bank and members of the bank holding company during identification, as well as information about financial transactions of customers, are confidential information.

Information about clients and their operations can be provided only in cases stipulated by the legislation of the Republic of Belarus.

12. The bank and members of the bank holding company shall store:

information and documents (their copies) obtained as a result of identification of clients and their representatives, not less than five years after the termination of agreements on financial transactions in writing, in the absence of such agreements - not less than five years from the date of financial transactions;
copies of special forms and documents (their copies), which are the basis for financial transactions - at least five years from the date of financial transactions.

13. In the event of a change in the current legislation, the Policy is applied in the part that does not contradict the current legislation, until the corresponding changes and additions are made to it.