Within AFC, our Anti-Money Laundering (AML) function helps us to prevent and tackle money laundering, and to combat the financing of terrorism. This includes measures for:
- meeting regulations governing identification (authentication), recording, and archiving;
- detecting suspicious transactions and processing internal suspicious activity alerts;
- developing, updating and delivering internal policies, procedures and controls; and
- defining requirements for the implementation of fund transfers regulation.
Policies are valid for the whole bank and are implemented at the front line of our business. They are continually monitored and must be updated at least once a year. Similarly, we examine our AML strategy and objectives on an ongoing basis to ensure that it reflects the regulatory requirements of a diverse global financial services provider.
Know Your Customer
We want to create a secure environment to win new clients and business—to the benefit of our business divisions and the Bank as a whole. It is critical that we understand who we are dealing with in every transaction. This begins with robust client on-boarding processes and “know your customer” procedures. We are currently reviewing these procedures and agreed to:
- suspend the on-boarding of new clients and the introduction of new products to existing clients in locations that we deem to be high risk, until we are completely sure the record is clear;
- increase the number of high risk countries from 30 to 113, and the number of high risk sectors from eight to ten;
- reduce the review cycles of high, medium and low-risk clients (e.g. medium risk clients are now reviewed every two years); and
- ensure that we only begin business with new clients after we have completed all know-your-customer and on-boarding procedures.