finansbank anti-money laundering / know your customer procedure

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$antalya 1. ?cra \,?udurlugunde?'? - Finansbank$

A-13-5 SALARY PAYMENT TRANSACTIONS OF MEMBERS OF UNITS OF INTERNATIONAL INSTITUTIONS RESIDING IN TURKEY OR MEMBERS OF EMBASSY OR CONSULATES In the establishment of permanent business relationships by the opening of accounts for members of units of international institutions residing in Turkey or members of embassy or consulates with the aim of paying their salaries through the bank, the following information of the real persons shall be obtained: Name and surname, Date and place of birth, Name of the mother and father and ID Number for Turkish citizens, Nationality, Work or residence address, Telephone number, fax number, and email address if attainable. The information pertaining to identity is verified in line with Section A-2-2. Verification can also be made by using identity sharing system database of Ministry of Internal Affairs on the condition that digital image is taken. As for verification of identification, the documents of identity as has been explained in Section A-2-2 and sample signatures are obtained within three months maximum beginning from the date of transaction. Verification of address is also conducted within this period. Reporting the names of the persons who will receive their salaries through the bank and detailed addresses of their institution is deemed adequate for address verification of the institution. Since, the ambassadors and the chargés d’ affaires are considered as PEP’s; related due diligence measures are applied prior to account opening. Simplified measures referred under this chapter are related to the other members (Turkish or foreign citizens) of the embassy or consulates such as mid-level staff members other than senior officials. A-13-6 IN THE EVENT THAT CUSTOMER IS A PUBLIC COMPANY WITH QUOTED SHARES IN STOCK EXCHANGE For the transactions of such companies, information that has been stated in the identification section shall be obtained for legal persons related to the company. This information does not have to be verified. A-13-7 TRANSACTIONS RELATED TO PENSION AGREEMENTS, PENSION PLANS AND LIFE INSURANCE AGREEMENTS In transactions carried out within the frame of pension agreements, pension plans which grant pension rights by making deductions in the salary or life insurance agreements where the total amount of premium paid in a year is TRY 2.000,- or below or in single premium accounts where the premium amount to be paid is TRY 5.000,- or below; the information listed in the “Identification of Real Persons” shall be obtained without regard to verification documents. In case of disbursements, verification documents shall also be obtained and verified. 34
A-13-8 TRANSACTIONS OF PRE-PAID CARDS Pre-paid cards are related to the Finansbank accounts of our customers. Identification is not obligatory for the below mentioned pre-paid cards which are followed on card number basis, do not have a name on them, effective when an amount is preloaded or loaded, and allow spending up to the limit of loading. Single use pre-paid cards in which the loaded amount does not exceed TRY 300,-, Reloadable pre-paid cards for which the total loaded limit does not exceed TRY 5.000,- (those cards that allow cash withdrawal or wire transfer to another account amounting to a total of more than TRY 2.000 in the same calendar year are excluded) in a calendar year. A-13-9 VERIFICATION OF ACCURACY OF TELEPHONE AND FAX NUMBERS AND E- MAIL ADDRESSES Telephone and fax numbers and e-mail addresses of customers obtained for identification purposes in the establishment of permanent business relationships are verified by contacting the relevant persons through these contact information on a risk based approach when necessary. A-14 REPORTING OF MONITORING AND EVALUATION RESULTS TO THE BOARD OF DIRECTORS VIA AUDIT COMMITTEE The results of the monitoring and evaluation activities carried out by AML Unit are reported to the Audit Committee every three months, which brings the report to the attention of the Board of Directors. B- MONITORING AND CONTROL ACTIVITIES Monitoring and control activities aim at prevention the risks mentioned in this document and continuous monitoring and control of the activities in order to ensure that they are being carried out in line with the Law and relevant regulations, communiqués, bank’s in-house policy and procedures. The deficiencies detected at the end of the controls carried out or the sake of compliance with the obligations brought about by the Law is reported to relevant units so that necessary measures are taken and the results are followed. It has to be ensured that the officer who conducts monitoring and control activities have access to in-house information sources. B-1 MONITORING AND CONTROL OF THE TRANSACTIONS OF HIGH RISK GROUP CUSTOMERS The high risk group customers stated in risk management chapter in detail is; Non-residents Residents in Offshore Regions and special purpose vehicles (SPVs) Persons Residing and Transactions Carried out in Countries Which Do Not Act in Accordance with the Recommendations of FATF PEP-Politically Exposed Persons Companies with Bearer Share 35
Page 1 and 2: DEFINITIONS Terrorist Financing Mon
Page 3 and 4: of P.E.P.s legal arrangement which
Page 5 and 6: A-13-4 COLLECTIVE CUSTOMER ACCEPTAN
Page 7 and 8: A-RISK MANAGEMENT ACTIVITIES The be
Page 9 and 10: * Finans_Base_Uyarı - should be co
Page 11 and 12: HIGH RISK GROUP CUSTOMERS Customers
Page 13 and 14: (a) Heads of State, heads of govern
Page 15 and 16: It is verified whether the owner of
Page 17 and 18: Transactions which will allow the c
Page 19 and 20: The authenticity of the declared ad
Page 21 and 22: Documents that shall be obtained fr
Page 23 and 24: Documents that shall be obtained fr
Page 25 and 26: A-2-7 IDENTIFICATION OF NON-RESIDEN
Page 27 and 28: Identification of authorized repres
Page 29 and 30: frame of monitoring and control act
Page 31 and 32: A-9 CORRESPONDENT BANKING RELATIONS
Page 33: A-13-2 IN THE EVENT THAT THE CUSTOM
Page 37 and 38: Controls conducted in the event tha
Page 39 and 40: B-6 CONTROL OF THE INFORMATION AND
Page 41 and 42: The reporting of a transaction with
Page 43 and 44: purpose of the transaction and the
Page 45 and 46: 3.29. There are no explanations reg
Page 47 and 48: customer, all of a sudden, pays bac
Page 49 and 50: name of legal persons of legal enti
Page 51 and 52: Extortion and robbery are methods a
Page 53 and 54: specified in full in section E. In
Page 55 and 56: C-1-3 TARGET GROUPS The following a
Page 57 and 58: Submits quarterly reports of regula
Page 59 and 60: Appendix 2 Messrs. SOLEMN DECLARATI
Page 61 and 62: indirectly involved in any criminal
Page 63 and 64: Appendix 3 Financial Institutions:
Page 65 and 66: C)Regulatory and Supervisory Admini
Page 67 and 68: D- INFORMATION ABOUT THE LEGAL PERS
Page 69 and 70: H- TYPE OF SUSPICIOUS TRANSACTION S

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