Measures designed to counteract legalization of illicit gains
Reorganization of Vnesheconombank into a state corporation in June 2007 in accordance with Federal Law ‘On Bank for Development’ predetermined the Bank’s new goals and functions.
Today, Vnesheconombank is aiming to enhance competitiveness of the Russian economy, ensure its diversification and promote investment activities, remaining an active member of the global banking community.
In this context, the global banking community’s task of counteracting legalization of illicit gains and terrorism financing applies fully to Vnesheconombank’s activity.
Vnesheconombank has developed a system designed to counteract money laundering and has applied it since 2002. Underlying the System are the requirements of Federal Law ‘On Counteracting Legalization of Illicit Gains (Money Laundering) and Terrorism Financing’, recommendations by the Central Bank of the Russian Federation and global financial institutions, as well as the experience of western and leading Russian banks. The System embraces all the areas of the Bank’s current activities and its customer base notable for its transparency, which minimizes the risk of Vnesheconombank being used for money laundering or terrorism financing.
The System to counteract money laundering is designed to protect Vnesheconombank from illicit gains, manage risks of legalizing illicit gains (money laundering) and financing terrorism in order to minimize it, and as well as ensure independence of a designated official and participation of employees in carrying out relevant measures.
Central to the System are Internal Control Provisions intended to counteract legalization of illicit gains (money laundering) and terrorism financing.
The Compliance and Financial Monitoring Department ensures operation of the System.
A Designated Officer responsible for implementing AML/CTF Internal Control Rules and acting as Money-Laundering Reporting Officer has been appointed.
The programs elaborated define the functions and methods of interaction between Vnesheconombank’s divisions and employees in order to counteract legalization of illicit gains and terrorism financing.
The programs include procedures which would enable Vnesheconombank under applicable legislation to identify customers, customers’ representatives, beneficiaries and beneficial owners, assess customers’ risks, as well as risks of using Vnesheconombank’s services in order to legalize (launder) illicit gains and finance terrorism, and timely detect customers’ transactions that are subject to mandatory control, as well as spot unusual transactions, document and store information about customers and their transactions, as well as take measures to counteract legalization of illicit gains and terrorism financing.
All the employees of Vnesheconombank, who effect or support banking operations and other transactions, irrespective of their positions and within their competence, are to participate in implementing Internal Control Provisions in order to counteract legalization of illicit gains (money laundering) and terrorism financing and maintain due vigilance with respect to any unusual transactions, paying special attention to factors influencing the customers’ risk assessment and to customers’ operations that involve high risks.
Vnesheconombank’s and its subsidiaries’ employees undergo trainings on a regular basis devoted to applying the Russian Law on Counteracting the Legalization of Illegal Gains and Terrorism Financing (Money Laundering).
Vnesheconombank develops program «Know your customer» which include:
- Special requirements for opening personal/business/correspondent bank accounts:
- For opening of personal account Vnesheconombank requires documents for identification of an applicant’s personality, address and taxpayer identification number.
- For opening of business account Vnesheconombank requires constitutive documents and documents where an applicant’s name, registration number, permanent and current mailing address, taxpayer identification number appear. When opening business accounts Vnesheconombank pays special attention to the information on the applicant’s senior management and the owners (in case of privately held institutions), expected account activity and other publicly available information.
- For opening of correspondent bank account Vnesheconombank requires constitutive documents and documents where applicant’s name, registration number, permanent and current mailing address, taxpayer identification number, banking licence, list of authorised signatures appear and also information on senior management, the owners (in case of privately held institutions), expected account activity and other publicly available information.
- Vnesheconombank also requests information on correspondent bank’s KYC policies and AML procedures.
- In case of necessity Vnesheconombank requires other additional information for opening and maintaining of personal/business/correspondent bank accounts.
- Identification of transaction profile before opening accounts (volume and main type of transactions).
- Special rules for detecting suspicious transactions (policy of monitoring large volume transactions). Once an unusual activity is detected we make our internal investigation of the reasons of such activity and then if necessary take measures set by Russian AML legislation.
- Monitoring our customer’s accounts.