As criminals may use financial services in order to launder the proceeds of and fund their criminal activities, 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, as a bank, we are required to detect unusual and suspicious activities and to determine whether a specific customer is included on different listings of sanctions.

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 whole society but can also damage the stability and reputation of the financial institutions. It is obviously in the financial industries’ and society's best interests that financial institutions take all reasonable measures to prevent money laundering and terrorist financing.

In order to ensure an effective establishment and implementation of a company culture opposing money-laundering and terrorism financing Swedbank has, among other, the following procedures in place:

• Swedbank has adopted a Policy on prevention of money laundering and countering terrorist financing that requires all parts of the Swedbank Group to develop and implement effective programs to comply with applicable laws.

• Customer due diligence (CDD), comprise of, inter alia, identifying the customer and verifying the customer’s identity on the basis of documents, data or information obtained from reliable and independent sources, and where applicable, the beneficial owner, understanding the ownership and control structure of our customers, obtaining information on the purpose and intended nature of the business relationship and ongoing follow-up on the business relationships verifying the customer’s identity, also in relation to non-face-to-face business relationships, on the basis of documents.

• The Group performs daily screening of the customer base against financial sanctions and PEP lists. All international payments are also screened in real time in regard to financial sanctions.

• Senior management signs off PEP customers and other relevant high risk customers.

Swedbank is also a member of the SWIFT’s Know Your Customer Registry (KYC Registry) and we would be grateful if you could use the KYC Registry to gather due diligence information and data on our Bank. If you have further questions please contact