Policy of International Moscow Bank in the Area of Money Laundering and Terrorism Financing Prevention

The policy of International Moscow Bank in the area of prevention of money laundering1 and terrorism financing prevention is aimed at:

• inadmissibility of utilization of the Bank as an instrument of money laundering and terrorism financing;
• protection of business reputation of the Bank and of its customers.

To this purpose the Bank:

• implements control measures and procedures provided for by the Federal Law # 115-ФЗ dated August 7th, 2001 г. # 115-ФЗ and also by the requirements of the Bank of Russia;
• takes into account recommendations of the leading international financial institutions and of the Bank’s shareholders;<
• provides for participation of all the Bank’s staff in the effort of money laundering and terrorism financing prevention;
• unifies approaches to organization of control in its branches, representative offices and subsidiaries.

The Banks in its fight against money laundering and terrorism financing takes into account the experience accumulated by foreign financial institutions and leading Russian credit organizations. The Bank is guided by the following:

• identification of all customers and other persons served by the Bank;
• assessment of customer from the point of view of money laundering and terrorism financing risk;
• investigation of transactions arousing suspicions of being related to money laundering or terrorism financing;
• blocking transactions with participation of persons figuring on terrorist lists;
• refusal to open account of process transaction in case of lack of documents or submission of unauthentic documents; also in case of information indicative of participation of potential customer in terrorist activities;
• refusal to open bearer accounts;
• establishing of contractual relations only with financial institutions which themselves take actions to counter money laundering and terrorism financing;
• refusal to establish contractual relations with “shell banks” having no physical presence at the address of their registration and to process transactions with participation of such banks;
• timely reporting to the Federal Service for Financial Monitoring (Russian FIU);
• systematic training of staff of the Bank in the domain of money laundering and terrorism financing prevention.

The President of UniCredit Dank has appointed a Special Officer responsible for ensuring:

• functioning in the Bank of the system of money laundering and terrorism financing prevention;
• coordination of efforts of the Bank’s units and control after observance by them of internal rules and procedures in this area;
• forwarding of reports to the Federal Service for Financial Monitoring.

¹ In Russian legislation money laundering implies actions directed at giving legitimate appearance to possession, utilisation and disposal of moneys and other property obtained as a result of crimes such as illegal drug trafficking, racket, prostitution, financial fraud etc. Russian legislation does not consider as crimes giving rise to money laundering:
- non-repatriation of export proceeds;
- custom fees evasion;
- tax evasion by natural persons;
- tax evasion by companies.