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Anti Money Laundering Policy Statement

BMCE Bank International Plc (the Bank) has established and continues to maintain its Financial Crime Prevention Policy which is designed to ensure that all its business lines are in compliance with all applicable laws, rules and regulations related to anti-money laundering [“AML”] anti-terrorist financing initiatives [“CTF”] and all other forms of financial or economic crime.

The Bank recognizes the fact that money laundering and terrorist financing is a major threat to the international financial services community. The United Kingdom has passed legislation designed to prevent money laundering and terrorist financing. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for UK firms, including offences and penalties for failing to comply.

The following are the main elements of the policy: Internal Controls and Communication of Policies:

The Bank has instituted internal systems and controls which comply fully with all applicable anti-money laundering laws and regulations. Senior management will undertake money laundering risk assessment of the Bank’s services and customer base and apply the appropriate policies and procedures to manage the risk.

Money Laundering Reporting Officer:

The appointment of a Money Laundering Reporting Officer, of sufficient seniority who has responsibility for oversight of the Bank’s compliance with the relevant legislation, rules and regulations industry guidance. The MLRO has the oversight of all aspects of the Bank’s AML/CFT activities, policies and procedures and is the focal point for all activity within the Bank relating to anti-money laundering.

Risk Based Approach:

The Money Laundering Regulations 2007 to 2017 allow the Bank to adopt a carefully calibrated risk-based approach to money laundering/ terrorist financing by assessing where the risks of money laundering may arise in the Bank and allowing the Bank's senior management to decide how they will address and manage those risks. The Bank carries out such an exercise or a review annually to establish and maintain an updated Risk Based Approach towards assessing and managing the money laundering and terrorist financing risks to the Bank.

Customer Due diligence:

Before establishing business relationship with any prospective customer, appropriate customer due diligence (CDD) is required to be undertaken and recorded. The CDD/KYC process comprises: 1) the identification and verification of identity of the customer (and, where different, beneficial owner) and any other relevant parties; 2) additional and appropriate Know Your Customer (KYC) information, applying a risk based approach; 3) obtain basic background information about the customer identified as PEP i.e. customer’s business and source of income, extensive research will also be carried out accessing available press pronouncements to gauge the credentials of the PEPs; 4) enhanced due diligence will be carried out for higher-risk customers, knowledge of the customer will be updated on a regular basis in our internal system which will enable our AML software tool automatically make necessary changes for performing accurate customer activity/transaction monitoring exercise against expectations; 5) identification of ultimate beneficial owner of all companies with which the bank conducts business and the beneficial ownership of all funds or other assets that are handled by the bank;

Financial Sanctions and Ongoing Screening:

The Bank endeavours to take reasonable steps to ensure that it is not breaching EU, UK and UN financial sanctions. We recognize the fact that financial sanctions regimes change in the light of national and international political developments and names are therefore added (and removed from) the HM Treasury sanctions list maintained in their website, hence we have put in place systems and controls in respect of ongoing screening of our customer base against sanctions list. We ensure that our client base is screened automatically following direct notification of such changes from HM Treasury. In addition to that Bank also implemented automated periodic checking against up-to-date sanctions list.

Identification of Suspicious Transactions/ Activity:

It is a requirement that our Systems and Controls ensure that appropriate scrutiny and monitoring of transactions, account activity of customers is undertaken in order to identify unusual and potentially suspicious activity.

Reporting of Suspicious Transaction:

We have procedures in place whereby every transactions and activities which are believed to be suspicious are reported to Money Laundering Reporting Officer where the suspicion will be validated, and decision will be made as to whether a report should be made to NCA (National Crime Agency).

Record Keeping:

Records are required to be maintained and ongoing KYC/CDD procedures have been followed. Records are required to be maintained for 5 years after the relationship has ended.

Politically Exposed Person:

The Bank have systems and controls in place to identify PEPs as part of client take on and thereafter on an ongoing basis (e.g. account review, information received during the continuing relationship). For such accounts it is a requirement to identify the source of wealth and source of funds. All relationships involving PEPs are subject to approval by the senior management. The accounts concerned will be kept under close review by AML/KYC Analysis. Any suspicion that accounts are being used to launder the proceeds of crime or to assist the financing of terrorism will be reported to the MLRO.

Counterparties:

The Bank maintains procedures in relation to the relationships with the counterparties including banks in line with the UK JMLSG (Joint Money Laundering Steering Group Guidance) Guidance for the Financial Sector. Where necessary, this comprises enhanced due diligence (EDD) by obtaining information on a counterparty or client's ownership and management, noting any PEP involvement in the operation of the counterparty or client, obtaining information to fully understand the nature of its business, verifying the standard of anti-money laundering and terrorist financing controls as well as measures designed to prevent relationships being maintained, directly or indirectly, with shell banks.

Awareness and Training:

Ongoing annual training provided to all existing staff members to ensure that they understand Bank’s approach to money laundering deterrence.

Disciplinary Procedures:

Failure to abide by the policies and procedures set by the Bank to prevent money laundering will be treated as a disciplinary issue. Any deliberate breach will be viewed a gross misconduct. This could lead to termination of employment and could also in criminal prosecution for the member of staff concerned.