|US Patriot Act||Wolfsberg Questionnaire||W8E-Bene|
JSB 'UKRGASBANK' fully complies with the requirements of the Ukrainian legislation in force, Basel Committee on Banking Supervision standards, other international rules and standards designated to combat money laundering and terrorism financing.
In line with the requirements of the Law of Ukraine “On Prevention of and Counteraction to Legalization (Laundering) of the Proceeds from Crime, Financing of Terrorism and Proliferation of Weapons of Mass Destruction” (as amended), “On Banks and Banking”, regulatory and legal acts of the National Bank of Ukraine, JSB 'UKRGASBANK' has established an in-house system on Anti-Money Laundering/Combating the Financing of Terrorism (hereinafter — AML/CFT). A special unit, Financial Monitoring Department, was set up to organize and coordinate AML/CFT system at the bank. The bank has appointed a designated compliance officer responsible for financial monitoring at the bank — Ms Nataliia Vasylets, Deputy Chairman of the Board. The compliance officer heads the AML/CFT system at the bank.
The bank’s internal AML/CFT system is governed by the following key policies:
- JSB 'UKRGASBANK' Rules of Internal Financial Monitoring approved by Board resolution No.38 dated 04.06.2015. The rules determine organizational structure of the financial monitoring system at the bank, parameters and procedures for registration of financial transactions subject to financial monitoring; procedures and terms of reporting financial transactions subject to financial monitoring to the State Financial Monitoring Service of Ukraine; secure confidentiality of information concerning financial monitoring.
- JSB 'UKRGASBANK' Customer Identification and KYC Program approved by Board resolution No.38 dated 04.06.2015. The program is based on "Know Your Customer" policy and includes the procedure for identification of customers in the course of establishing relations as well as in the process of providing services to them. According to the requirements of the Ukrainian legislation in force the bank shall obligatorily identify customers in case of: (і) establishing business relations; (іі) suspicions that a transaction may be connected with money laundering or terrorism financing; (ііі) conducting a financial transaction subject to financial monitoring; (iv) conducting a one-time transaction with cash for the amount above UAH 150,000 or its equivalent in a foreign currency without opening an account. The bank also identifies persons authorized to act on behalf of the above customers.
- Training and Advance Training Program for JSB 'UKRGASBANK' Employees approved by Board resolution No.24 dated 22.05.2014. The Program governs training of JSB 'UKRGASBANK' employees on prevention of and counteraction to legalization (laundering) of the proceeds from crime, financing of terrorism in the course of engagement and employment.
- JSB 'UKRGASBANK' Financial Monitoring Program for Money Transfers via Payment Systems approved by Board resolution No.38 dated 04.06.2015. The program establishes financial monitoring procedure for money transfers of individuals via payment systems. The program covers money transfers made from or received in Ukraine via payment systems whether a payer/receiver uses current and/or card accounts or not.
- JSB 'UKRGASBANK' Financial Monitoring Program for Money Transfers via Payment Systems Using Electronic Payment Means approved by Board resolution No.38 dated 04.06.2015. The Program covers all financial transactions carried out by customers of the bank using electronic payment means of payment systems that may be conducted by the bank based on a respective license of the National Bank of Ukraine or licenses issued by other authorized state agencies according to the requirements of the legislation of Ukraine in force. The purpose of the program is to comply, as a primary financial monitoring entity, with the requirements of the effective legislation of Ukraine on prevention of money laundering/combatting the financing of terrorism concerning financial monitoring of bank customers’ money transfers made via payment systems using their electronic payment means.
- JSB 'UKRGASBANK' Financial Monitoring Program for Money Transfers via Golden Crown Money Transfer System approved by Board resolution No.30 dated 23.04.2015. The program establishes financial monitoring procedure for money transfers of individuals via Golden Crown Money Transfer System and covers outgoing/incoming money transfers made from or received in Ukraine via Golden Crown Money Transfer System whether a payer/receiver uses accounts or not.
- JSB 'UKRGASBANK' Financial Monitoring Program by Businesses in the Process of Providing Services to Customers approved by Board resolution No.38 dated 04.06.2015. The program has been developed for the following businesses: settlements and transactions with cash, deposits and loans, transactions with securities. The program establishes the procedure for detecting financial transactions subject to financial monitoring, the procedure for reporting transactions subject to financial monitoring to the compliance officer.
- JSB 'UKRGASBANK' Money Laundering and Terrorism Financing Risk Assessment and Management Program approved by Board resolution No.38 dated 04.06.2015. The program has been developed in order to control, manage and mitigate risks of using bank services for money laundering/terrorism financing. The program includes: (і) the procedure for assessing customer risks, (іі) algorithms and procedures for assessing the risk of using bank services for money laundering/terrorism financing, (ііі) measures to mitigate the risk of money laundering/terrorism financing, (iv) the procedure for holding practical trainings with bank employees on implementation of the risk assessment program.
Internal AML/CFT policies of JSB 'UKRGASBANK' are checked by the National Bank of Ukraine (regulator) in the framework of its standard inspections that are conducted no less than once in two years. The last inspection was conducted in the second quarter of 2014. In addition, internal audit of the bank annually checks operation of the financial monitoring system.
The bank (і) does not open and maintain anonymous (numbered) accounts, (іі) does not establish business relations with customers in case of suspicions that a person is not acting on his/her own behalf (ііі) does not establish correspondent relations with foreign financial institutions that do not take appropriate measures to prevent legalization (laundering) proceeds from crime and with shell banks (that have no physical presence in the country in which they are incorporated and licensed).
According to the Ukrainian legislation in force, internal AML/CFT policies are documents with limited access and therefore copies of the documents may not be provided to you. However, let us assure you that all AML/CFT documents have been properly drawn up and are in line with the requirements of the local legislation in force.