The data on measures taken by the bank to prevent legalization (laundering) of the incomes obtained in criminal way or terrorism funding.
In order to counteract and prevent the legalization of the criminally obtained incomes PJSC “MTB BANK”
- has organized special subdivision, the Administration on control the fulfillment of the regulatory requirements, the main task of which is development of the methodology, control over the fulfillment and analysis of the results of the financial monitoring;
- according to the legislation of Ukraine envisaging the activity on prevention and counteraction of the criminally obtained incomes legalization the internal standard documents have been developed and approved by the Board of Directors of the Bank. These documents determine the structure of the internal system of the financial monitoring of the bank, the process of its implementation and the procedures of identification and studying the customers of the bank, employees training on the issues of prevention of the legalization of the criminally obtained incomes, storage of the documents containing the information on financial monitoring;
- the established Rules and Programs are obligatory for performance by all the subsidiaries and subdivisions of the bank providing the process of financial monitoring by all the directions of the bank activity.
- Under the approved Rules and Regulations of the financial monitoring the bank doesn’t keep business relations (including correspondent ones) with financial institutions not represented in any country (shell banks), financial institutions and persons registered in the countries not implementing the legislation envisaging counteractions to the legalization of the criminally obtained incomes and terrorism funding. The Bank doesn’t keep anonymous or number accounts.
- Identification of the customers and conclusion of the contractual relations with the counterparties is performed according to the requirements of the legislation of Ukraine with consideration of the risks of transactions related to the legalization of the criminally obtained incomes.
- The structure of the internal bank financial monitoring system envisages the presence of the person responsible for the financial monitoring in each subdivision (central office)
- The bank uses the software allowing to automate the monitoring of the accounts and transactions subjected to financial monitoring. The system also allows to provide the participation of all the employees of the bank involved in the maintaining of the customers’ transactions and urgent information of the responsible persons on the transactions subjected to monitoring which in their turn have the possibility to analyze such transactions and in the case of necessity to send the information about them to the authorized bodies.
- The bank uses the software allowing to automate the monitoring of the accounts and transactions of the customers for their conformity with the financial monitoring criteria and relation to the funding of the terroristic activity.
The bank employees are informed with the provisions of the legislation and internal documents of the bank establishing the process of counteracting and preventing the criminally obtained incomes as well as with their responsibilities to perform financial monitoring within their competence and bear responsibility for failure to fulfill them.