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    • AML & CFT
      • 1. Introduction:

        To combat money-laundering and terrorism financing, Tejarat Bank, has used all its efforts to enforce Anti-Money Laundering Act, approved on January 22, 2008 by the Islamic Consultative Assembly (Iranian Parliament) and its relative amendment approved in 2019; Tejarat Bank plans to act accordingly and develop its “Anti-Money Laundering and Counter-terrorism Financing Policies” alongside the existing set of rules issued by Iran Central Bank, Financial Intelligence Unit of the Supreme Council on Anti-Money Laundering in the Ministry of Economic Affairs and Finance (IRFIU), the last recommendations of the Financial Action Task Force (FATF) and the Standards of Basel Committee on Banking Supervision and Wolfsburg Group.

      • 2. Goals and scope of the policies:

        By implementation of these policies, Tejarat bank, in various levels and sections, is able to implement the instructions on combating money laundering and preventing terrorism financing according to the national regulations and international standards.
        Implementation of the policies defined in this document is mandatory for all local and cross border branches and all headquarters of the bank. And also observing the terms of this Policy is binding to all cross border branches in countries that are lacking law and regulations to combat money laundering and terrorist financing or their laws are not adequate or sufficient according to the standards and regulations of the Islamic Republic of Iran.

      • 3. Customers Identification Policies:

        In accordance to the executive by-law of the supplementary article 14 of the Anti-Money Laundering Act, approved by the Cabinet on 21.07.2009, Tejarat Bank is required to determine the risk level of customers and based on it,
        arrange Customer Due Deligence (CDD) methods in three levels: Simplified, Basic and Enhanced Due Diligence. The Risk Management Department is obliged to determine the risk variables of customers with the cooperation of related sections.
        At present, based on the average of risk-based indicators and criteria, Tejarat Bank ranks its customers based on money laundering and terrorism financing risks (ML/TF risks) and goes through CDD process as following.

      • 3.1. Providing initial identity and economic documents

        In this section, all natural and legal customers of Tejarat Bank provide the complete information of themselves and of all natural and legal identities connected to them (including lawyers, shareholders’ signatories, beneficiaries, beneficial owners …) based on the documents specified in the executive by-law of AML Act and in proportion with their risk level and specified CDD procedure. All the documents provided by the customers, should be in accordance with CDD rules and international standards.

      • 3.2. Verifying obtained documents and Identifying the level of activity

        The information received from the natural and legal customers should be matched with the obtained documents and then be verified by the competent authorities.
        The databases used for verification of the information obtained from the customers are as following:
        National Code Database for Iranian natural entities,
        National ID Number Database for Iranian legal entities,
        Iranian National Tax Administration Database for Economic Code,
        Specific ID Number Database for foreign natural and legal entities,
        ZIP Code Database of the Islamic Republic of Iran Post Office,
        Official Gazette Database,
        Nahab System for issuance of Electronic Banking ID (Shahab Code)
        After implementing this part, customer’s level of activity is determined according to the “instructions for determining customer’s scope of activity in the credit institutes”
        Note: In accordance to the trainings and regulations presented to the branch staff, negligence in full identification of customers that imposes risk of reputation for the bank is subjected to disciplinary violations and violators would be treated in accordance with disciplinary regulations.

      • 3.3. Accepting customers

        In the next step, based on customers ML/TF risk, Tejarat bank decides to accept/refuse the customers and ask for the identity and economic documents.
        Note1: Tejarat Bank is free to accept or refuse the customers at this stage.
        Note2: Providing service to walk-in customers (customers that have no permanent relationship with the bank) is only possible if and if customer’s identification process is done through obtaining valid documents and it is approved that ML/TF risk is imposed to Tejarat Bank.
        The bank can obtain initial identity and economic documents commensurate with the risk level (low, intermediate and high risk) and with the approval of the Central Bank and confirmation of Tejarat Board of Directors.
        As much as possible, CDD procedures should be prepared and imparted for the following categories:
        • Non-political Iranian natural persons
        • Political Iranian natural persons
        • Non-political foreign natural persons
        • Non-political foreign natural persons
        • Legal Iranian persons
        • Legal foreign persons
        Organization and Procedures Division, Anti-Money Laundering and Terrorism Financing Department and Risk Management Department of the bank are required to make the necessary arrangements to periodically update the CDD procedure based on the customers’ risk level and obtain the Central Bank approval accordingly. These updates should occur at least once a year.
        Currently, the rating model of customers’ ML risk is based on general risk of customers (Risk Based Approach-RBA) that includes both assessing ML risk and also analyzing customers’ competence. It monitors the general risk of customers by rating them at the time of opening an account and later on.
        In this model, the following customers are classified in high-risk category”
        • politicalyl imposed persons,
        • charities-based organizations,
        • foreign exchange dealers,
        • nonfinancial businesses such as dealers of gold, jewelries and precious stones, housing and car dealers and so on,
        • customers applying to open trust accounts
        • Customers who don’t visit the branch in person
        • Incompetent customers
        • Investment and Pension Funds,
        • Applicants of joint accounts,
        • Applicants for safe boxes
        Note3: All Tejarat Bank branches are required to receive Shahab code before opening accounts for natural /legal Iranian and foreign customers.

      • 4. Establishing Correspondent Banking Relations:

        For full identification of correspondents, the Compliance Committee of Tejarat Bank collects sufficient information for establishing correspondent banking relations with foreign banks based on a risk-based approach. The following cases are among the information that should be collected and reviewed:
        • Geographical risk of the bank, its local and cross border branches and subsidiaries.
        • Reviewing the bank’s structure, management status and its guidelines and procedures for combating money laundering and terrorism financing applied in its local and cross border branches and subsidiaries.
        • Composition of bank’s customers regarding their activity and structure.
        • Products and services that are offered by the bank to the clients and its corresponding banks.
        • Examining the presence of politically imposed persons in the composition of managers, shareholders and persons affiliated with the bank.
        • How to identify, control and provide services to political figures as the customers of the bank.
        • Possible sanctions imposed to the bank in the previous years.
        • The procedures defined by the bank for opening accounts and providing services to customers and high-risk accounts including fictitious accounts, trust accounts, joint accounts, investment and pension funds accounts, customers who don’t visit branches in person, non-resident customers, payable corresponding accounts.
        • How to monitor wants persons and those who are listed in international and regional sanctions in financial and non-financial massages between the two banks.
        • Procedures and policies for combating money laundering and terrorism financing that are developed and communicated by the bank.
        • Quality of laws and regulations of the bank’s country of origin regarding cooperation with the corresponding banks to provide additional information if necessary.
        Note: According to the executive By-Law of AML Act, establishing corresponding relations with shell banks is forbidden.
        The results of the studies done by the Compliance Committee and Anti-Money Laundering and Terrorism Financing Department will be announced to the Corresponding Banks’ Selection Committee. Establishing corresponding relations will be possible within the framework of the criteria set forth in the “Tejarat Bank instructions for establishing and maintaining corresponding relations”.
        If the used indicators for verifying the corresponding bank do not provide suitable results, or if the documents obtained from that bank do not indicate the status of the bank in a proper manner, the Compliance Committee and Anti-Money Laundering and Terrorism Financing Department should meet the bank applying for corresponding relations in the place of the bank. This meeting must take place before establishment of corresponding relations or within a reasonable period of time thereafter for completing the procedure of the identification of the said bank

      • 5. Monitoring Suspicious Operations and Reporting the Cases:

        5.1. In Tejarat Bank all suspicious transactions and banking operations, physical or electronic, are monitored based on Anti-Money laundering Act and its executive by-law, Counter-Terrorism Act of the Central Bank of the Islamic Republic of Iran, the amendment to AML Act and also the instruction of Identification of suspicious transactions and reporting practices, and then all suspicious operations and transactions are reported to the Financial Intelligence Unit of the Supreme Council on Anti-Money Laundering in the Ministry of Economic Affairs and Finance (IRFIU) accordingly.
        Note1: submission of Reports on suspicious transactions and banking operations are confidential and no accusation is attributed to the customers and has no consequences for the bank staff.
        Note2: In case of failure to report suspicious transactions or activities, violators would be treated in accordance with disciplinary regulations because of the reputation risk imposed to the bank
        5.2. Tejarat Bank’s AML software should be able to monitor suspicious transactions according to the obligations of the Central Bank. This software operates automatically and generates needed reports based on the specified rules and variable parameters chosen by the clients. In addition to the 11 Rules of the Central Bank, yet Tejarat Bank has set up some internal rules for its AML software including reports for the accounts of people under 18, accounts of foreigners with more than 5 billion Rials yearly threshold, gambling accounts and accounts with more than
        40 billion Rials remaining balance Tejarat Bank
        5.3. International transactions through SWIFT network are based on transparency of transactions and their traceability.In all transactions issued through SWIFT network, according to the nature of transaction, Tejarat Bank monitors the origin of funds, banks (the involved banks in the transportation company’s transaction), type of goods and…. None of the involved parties of the issued transactions of Tejarat Bank should be listed in national and international sanctions. In order to monitor all these, Tejarat Bank should use suitable systems
        5.4. In massage numbers MT2020 and reimbursing MT202, MT205 and reimbursing MT205, if the obtained information from the corresponding bank is imperfect, while rejecting the massage, the issue should be reported to Financial Intelligence Unit of the Supreme Council on Anti-Money Laundering in the Ministry of Economic Affairs and Finance

      • 6. Trainings:

        6.1. All Tejarat Bank personnel that are related to these policies should be provided with relative training courses. These courses include:
        • Anti-money laundering and Counter-terrorism financing
        • How to identify clients
        • Identifying suspicious transactions
        • Analyzing suspicious transactions
        6.2. According to their assigned duties, AML officers in the branches and the headquarters are obliged to assist in preparing educational contents, being helpful and responsive to the relative staff and also try to identify and introduce capable teachers in the AML field.
        6.3. Tejarat Bank management and staff are obliged to fulfill the duties mentioned in the AML and CTF Act and the relative amendment and if knowingly and intentionally, they refuse to do their duties in order to facilitate the crimes subject to above-mentioned Acts, they would be treated according to disciplinary regulations.

      • 7. Non-person and Electronic Transactions”

        Based on the guideline of “Anti-Money Laundering Compliance in the field of Electronic Banking and Payment Systems”, all Tejarat Bank’s branches are required to observe the rules and principles of Combating Money Laundering for clients who tend to use non-person and electronic transactions.

      • 8. New Services

        According to the By-law of Anti-Money Laundering Act, approved by the Cabinet, it is necessary for Information Technology Division, Organization and Procedures Division and Market Planning and Product Development Department to make essential arrangements with Anti-Money Laundering and Terrorism Financing Department before presenting any new products and services.

      • 9. Preparing Reports for Cash Deposits Higher Than Designated Thresholds:

        According to the instructions of "How report about cash deposits more than designated thresholds” issued by the Central Bank of the Islamic Republic of Iran, all Tejarat Bank local and cross border branches obliged to report customers’ requests for depositing cash amounts more than designated thresholds to the Anti-Money Laundering and Terrorism Financing Department. After collecting all received reports, AML department will prepare a report to Financial Intelligence Unit (FIU) and Anti-Money Laundering Department of the Central Bank of the Islamic Republic of Iran on daily basis.

      • 10. Transparency of Banking Transactions

        According to “The instructions on Transparency of Banking Transactions”, all Tejarat Bank branches are obliged to obtain positive documents for transactions above the designated thresholds (two billion Rials for natural persons and ten billion Rials for legal entities). The bank inspectors are responsible for the supervision of this process.

      • 11. Keeping the Documents:

        (after implementation of the required infrastructure), Tejarat Bank should keep the electronic form of all the documents obtained according to these policies, based on the guideline of "Regulations and procedures for keeping commercial papers, documents and bank offices" issued by the Central Bank of the Islamic Republic of Iran. In case of failure, violators would be treated in accordance with disciplinary regulations.

      • 12. Requirements:

        The Anti-Money Laundering and Terrorism Financing Department is responsible for recommending appropriate procedures for the implementation of AML and CTF policies; Afterwards, Organization and Procedures Division will review the recommendations and present them to the Board of Directors for approval.
        The Anti-Money Laundering and Terrorism Financing Department is required to comply with Anti-Money Laundering instruction. In addition to observing the said instruction, the branches are obliged to consider all the trainings and relative instructions and also provide accurate and on-time reports of suspicious transactions and operations.
        12.1. AML officers in different parts of the bank:
        In branches: deputy of the branch in the local (Rial) section
        In foreign currency and international banking branches: the head and deputy of accounting section
        In Branches Affaires Division: the head of accounting section
        12.2. The responsibility of violating the instructions will be on the violators and the will be referred to disciplinary committee.

      • 13. Verification and Updating the Policies:

        This Policy is approved by the Bank’s Board of Directors on 07.12.2021. Policies are updated whenever necessary in Tejarat Bank, but this period should not be taken more than 2 years.