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The legal base on preventing money laundering has been developed in Ukraine in accordance with the FATF recommendations. The basic regulatory acts are the Anti-Money Laundering Law of Ukraine №1702-IV dated 14.10.2014 and the Resolution by the National Bank of Ukraine №189 dated 14.05.03 on Regulation of the Financial Monitoring by Banks with subsequent amendments.
In accordance with the FATF recommendations and in fulfillment of Ukraine’s legislative requirements, in 2003 the Bank developed and introduced its Internal Financial Monitoring Rules and Internal Financial Monitoring Implementation Program that are being updated in strict conformity with the national legislation and best international practice. These regulations stipulate the procedure for preventing involvement of the Bank in money laundering and other suspicious transactions. The AML and KYC policy and procedures of the Bank rest upon respective Ukrainian legislation in force, including ad hoc amendments to national laws and Central Bank’s resolutions in connection with changes in related international requirements (including FATF recommendations). The Bank’s AML policies and practices apply to all branches and subsidiaries. The adequacy of such policy and procedures to current legislation in force is audited and reviewed regularly.
Methodology of detecting money laundering has been developed and implemented under Internal Financial Monitoring Rules of the Bank. It stipulates that obligatory financial monitoring is applied to financial transactions equal or exceeding 150 thousand hryvnias or foreign currency equivalent, which have one or several of the signs defined. Internal Rules also stipulate filters for financial operations subject to internal financial monitoring.
The Bank has established a record retention procedure for each of its customers. Identification results are entered into the customer form that comprises comprehensive data on the client. Such details are verified and updated no less than once a year if risk of performing illegal operations by the client is estimated as high, at least once every two years if the risk is estimated by the Bank as Medium. For other customers the period for verification of information should not exceed three years.
The Bank neither opens nor keeps anonymous (numbered) accounts and conducts no financial or other activities with shell banks. The Bank also screens customers and transactions against lists of persons, entities and countries designated by the state, international and supranational competent authorities on an ongoing basis.
To ensure the successful implementation of its financial monitoring procedures, the Bank has developed a programme of employee training which is updated on an annual basis. The training includes studying international and Ukrainian relevant regulations, the Basel committee anti-money laundering recommendations, the Bank’s internal regulations, policies and procedures, as well as practical training.
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