AML & CFT Policies and Procedures

• Document name: Anti-Money Laundering and Counter-Terrorist Financing Guide.
• Document number: P-COM-18 · Version: 04 · Date of issue: 18/08/2024.
• Prepared by the Compliance Department, reviewed by Quality Management, and studied by the Policies and Procedures Committee.
• Approved by the Sharia Supervisory Board, adopted and circulated by the Chief Executive Officer.

1. Laws and definitions — the legislation governing AML/CFT, the approved compliance policies and procedures, and the definitions used.
2. Basic principles of anti-money laundering and counter-terrorist financing.
3. Risk assessment — internal factors (notably the bank's size) and external factors, new products, practices and delivery channels, new technologies, and the requirement to assess before launch.
4. Responsibilities within the AML/CTF programme — the Board of Directors, executive management, the Reporting Officer, and the operations monitoring officer in branches.
5. The programme at the bank — compliance arrangements and customer due diligence, politically exposed persons, exchange and internal transfer companies, monitoring incoming and outgoing transfers in branches and in the verification unit, transfers between customers, new accounts, the power-of-attorney register, cheques, monitoring operations conducted through modern technology, internal reporting and reporting to the Authority, record keeping, continuous training, and an independent audit function.
6. Relationship with the Authority — responding accurately and confidentially to its requests, electronic correspondence, and providing contact details for the Reporting Officer.
7. Conclusion.

• Legislative Decree 33 of 2005 as amended by Legislative Decree 27 of 2011 and Legislative Decree 46 of 2013, on combating money laundering and terrorist financing.
• The System for Monitoring Banking and Financial Operations, issued by Decision 19 of 2019 of the management committee of the AML/CTF Authority, effective 1 April 2019, and its amendments.
• Legislative Decree 30 of 2010 on banking secrecy.
• The recommendations of the Financial Action Task Force (FATF).

The guide is reviewed and updated whenever necessary, when the bank's money-laundering and terrorist-financing risks change materially, or when the governing decisions and laws are substantially amended. A copy is placed on the bank's website and circulated to all employees for application.