Declaration regarding AML, CFT and KYC within Swedbank Group
The battle against money laundering (AML) and terrorist financing (CFT) is an ongoing and continous process. Since criminals require financial service in order to launder the proceeds of and fund their criminal activities, financial institutions must be able to identify and understand the potential risks of money laundering and terrorist financing within the institution and implement appropriate administrative processes, to preven or at least minimize, such risks. Proper Know-Your-Customer (KYC) practices are central and the knowledge of the customer provides a basis for understanding the general activities in which a customer usually would be expected to engage. Furthermore this gives the institution a possible opportunity to detect unusual and suspicious activities and to determine whether a specific customer is included on different listings of terrorists and/or sanctions. Appropriate procedures must be in place within financial institutions to assist governments in their efforts to identify terrorist funds.
In light of our changing environment, it is of great importance that financial institutions continually evaluate the strength and relevance of their existing policies, procedures and employee training programs and, if necessary, update them to address these changes.
Money laundering and terrorism not only harm the public as a whole but can also damage the stability and reputation of the financial sectors. It is obviously in the financial industry's and society's best interests that that financial institutions take all reasonable measures to prevent money laundering and terrorist financing.
Our Anti-Money Laundering and Anti-Terrorist Financing Philosophy
It is of great importance that financial institutions act to combat the risks of money laundering and assist governments in the identification of potential terrorist funding activities. Below follow some of the things we do within Swedbank Group.
- Swedbank has adopted an Anti-Money Laundering and Anti-Terrorist Financing Policy that requires Swedbank's head office, foreign branches and subsidiaries worldwide to develop and implement effective programs to comply with applicable laws. Swedbank's Group Policy is appropriately applied throughout the company and is overseen by Swedbank's Head of Group Staff within Group Executive Committee and the group-level staff dedicated to the duty of combating money laundering;
- We have a Group Anti-Money Laundering Officer and a team dedicated to the duty of overseeing Swedbank's global policies, practices and procedures with regard to preventing money laundering and the financing of terrorist activities. Furthermore, we have Anti-Money Laundering Reporting Officers within the different business units that report to the Group Anti-Money Laundering Officer as well as to national Financial Intelligence Units (FIU);
- We have established implementation of appropriate controls, regulations and compliance procedures;
- We use independent compliance, audit, risk management and legal functions to provide guidance and to be of assistance as well as to evaluate and ensure that our units and businesses comply with applicable money laundering and terrorist financing laws, rules and regulations;
- We have established procedures and routines regarding Know-Your-Customer and Customer due diligence which, for example, comprise identifying the customer and verifying the customer's identity on the basis of documents, data or information obtained from a reliable and independent source (such as public records) and, where applicable, the beneficial owner. Furthermore Swedbank pays special attention;
- in understanding the ownership and control structure of our customers,
- in obtaining information on the purpose and intended nature of business relationship, and
- in monitoring business relationship including scrutiny of transactions to ensure consistency of transactions with obtained information about purpose and intended nature of business relationship;
If a customer's reasons for a transaction/activity are not clear or understandable Swedbank takes measures in order to prevent money laundering or terrorist financing.
We rely on those closest to our customers - local branch managers, relationship managers and customer service personnel - to understand fully with whom we are doing business and to ensure that the business we conduct on behalf of our customers i legitimate;
- We have developed and continue to update policies and procedures that meet or exceed applicable legal and regulatory requirements, and continuously train employees in them;
- We have established processes, to assist governments in identifying relevant information with regard to suspected terrorist and money-laundering entities or individuals identified by government agencies (e.g. EU's and OFAC's sanction list).
Furthermore we fully co-operate with law enforcement and regulatory agencies to the extent that is possible in regard to applicable regulation.
- We have developed procedures that assist in the monotoring of transactions for the purpose of identifying possible suspicious activity;
- We recognize that preventing money laundering and identifying possible terrorist financing activities is an ongoing process that involves constant diligence and the ability to keep pace with the ever more sophisticated schemes employed by criminals;
- We have established employee training programs to educate and assist employees in the ways of preventing anti-money laundering and anti-terrorist financing transactions;
- The regulations within Swedbank do not allow conducting business with banks without physical presence in a country (shell banks);
- Swedbank does not allow direct use of correspondent accounts by third parties (payable through account) to transact business on their own behalf; and
- Swedbank does not allow anonymous accounts.
Swedbank continuously updates its policies and procedures, systems and technology, and we are training our staff to assure that we are well-equipped to combat money laundering and other financial crimes and assist governments in the war on terrorism. All this is done in accordance with national legislation and international recognized standards and regulations. We are fully committed to remaining constantly alert to prevent the use of our products and services by those who would abuse them.
For general information regarding Swedbank, its business, ownership, Board of Directors, management etc. please see/visit: Link/file
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