AML

JSB 'UKRGASBANK' fully complies with the requirements of the Ukrainian legislation in force, Basel Committee on Banking Supervision standards, Anti-Money Laundering recommendations of the Financial Action Task Force (FATF), the Wolfsberg Principles and other international rules and standards designated Anti-Money Laundering (AML) and Counter the Financing of Terrorism and Proliferation of Weapons of Mass Destruction (hereinafter — AML/CFT).

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» (with amendments and supplements), “On Banks and Banking”, regulatory and legal acts of the National Bank of Ukraine, JSB 'UKRGASBANK' has established an in-house AML/CFT system. The bank has appointed Compliance Officer responsible for financial monitoring at the bank — Ms. Nataliia Vasylets, Deputy Chairman of the Board. The Compliance Officer is in charge of the AML/CFT system at the bank. To ensure the implementation of initial financial monitoring functions by the Bank, a separate unit for prevention legalization (laundering) of the proceeds from crime/financing of terrorism – Financial Monitoring Department was established, it is supervised by the Compliance Officer.

The bank’s internal AML/CFT system is approved with the following key policies in force:

Rules of Financial Monitoring of JSB 'UKRGASBANK' approved by the Board, resolution No.66 dated 15.10.2015. 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.
Customer Identification, Verification and KYC Program of JSB 'UKRGASBANK' approved by the Board, resolution No.66 dated 15.10.2015 (with amendments and supplements approved by minutes of the Board No. 70 dated 12.11.2015 and by minutes of the Board No.16 dated 31.03.2016). The Program is based on "Know Your Customer" policy and includes the procedure for identification, verification and analysis of customers while establishing relations as well as in the process of providing services to them. In accordance with the requirements of the Ukrainian legislation in force the bank performs identification and verification of the customers in case of: (і) opening accounts in the Bank (except banks registered in Ukraine); (іі) establishing business relations (enter with bank into loan agreements, safe custody and safe deposit box rental agreements etc.); (ііі) conducting a financial transaction subject to financial monitoring; (іv) suspicions that a transaction carried out by them may be related to money laundering or terrorism financing or financing of proliferation of weapons of mass destruction and suspicions that such customers or its transactions/activity/source of funds are related to legalization (laundering) of the Proceeds from Crime or other socially dangerous act stipulated as a crime by Code of Criminal Procedure of Ukraine or subject for international sanctions; (v) carrying out remittances (including international) without opening an account in an amount that equals or exceeds UAH 15,000.00 or its equivalent in foreign currency, banking metals, other assets, units of value but which is less UAH 150,000.00 or its equivalent in foreign currency, banking metals, other assets, units of value (vi) conducting a one-time transaction without establishing business relations in the amount that equals or exceeds UAH 150,000.00 or its equivalent in foreign currency, banking metals, other assets, units of value; (vii) raising funds by the bank under the terms and conditions of a subordinated debt; (viii) entering into agreements for conducting professional activity on securities market (stock market) (except banks registered in Ukraine). Bank also identifies and verifies persons authorized to act on behalf of the above customers (customer’s representatives).
The Program also defines procedures of obtaining information and/or documents in order to determine the Ultimate Beneficial Owner (Controller) of the customer, beneficiary under financial transaction and measures of analysis of customer, which, particularly include: (i) customer’s financial condition assessment procedures based on relevant financial criteria; (ii) procedures to determine whether a customer or person who is authorized to act on its behalf is politically exposed person or associated/related to politically exposed person in the course of its identification/verification and as well as in the process of providing services to them; procedures to obtain senior management approval for establishing/continuing for existing relationships with such persons; (iii) procedures and criteria of customer reputation assessment; (iv) clarification/additional clarification of customer information procedures including the nature of its activity and financial condition; procedures of the above-mentioned measures implementation; (v) procedures of customer financial performance assessment including quarterly analysis of its financial operations.
Training and Advance Training Program for JSB 'UKRGASBANK' Employees regarding financial monitoring approved by the Board, resolution No.66 dated 15.10.2015. The Program determines procedures and appropriate measures associated to training and advance training of employees on issues of prevention and counteraction to legalization (laundering) of proceeds from crime/terrorist financing in the course of its engagement and employment. The Program includes key tasks and determines elements of the process training and advance training of employees on financial monitoring, type of instruction and knowledge assessment of employees on financial monitoring.
JSB 'UKRGASBANK' Financial Monitoring Program for Money Transfers via International Payment Systems (including Using Electronic Payment Means) approved by the Board, resolution No.66 dated 15.10.2015. The Program covers money transfers sent/received by individuals to/from outside of Ukraine via international payment systems whether payer/receiver uses current bank account or not. The Program defines the main principles for interactions of the employees of bank’s divisions within its competence on prevention and counteraction to legalization (laundering) of proceeds from crime/terrorist financing in the course of remittances using international payment systems.
JSB 'UKRGASBANK' Financial Monitoring Program by Businesses in the Process of Customer Servicing [settlement and cash operations, deposits and loans, foreign currency transactions, transactions with securities] approved by the Board, resolution No.66 dated 15.10.2015. The Program has been developed for the following businesses: settlement and cash operations, deposits and loans, foreign currency transactions and transactions with securities. The aim of the Program is (i) to appoint responsible employees and/or divisions (different in every Business) that will be in charge of timely analysis in order to detect and report to the compliance officer those financial transactions that might be subject to financial monitoring or if it is reasonable to suspect that such transactions are related to legalization (laundering) or aimed at the terrorism financing ; (ii) criteria of financial transactions taking into account specific features of financial monitoring depending on businesses subject to obligatory financial monitoring and/or internal financial monitoring and/or might be related to legalization (laundering) or aimed at the terrorism financing; (iii) peculiarities of analysis and client risk monitoring including performance of risk financial operations subject to financial monitoring with the purpose of detection financial transactions that might be subject to financial monitoring and aimed at the terrorism financing or weapons of mass destruction considering bank’s businesses in the process of customer servicing which includes subsequent monitoring of financial operations procedures.
JSB 'UKRGASBANK' Compliance Risk Management Program of Financial Monitoring approved by the Board, resolution No.56 dated 27.10.2016. The program has been developed in order to detect, manage and mitigate risks of using bank services for legalization of the proceeds from crime/terrorism financing. The program includes: (і) the procedure for assessing/reassessing customer risks for legalization of the proceeds from crime/terrorism financing, (іі) customer risk monitoring; (iii) decision-making on rejection to establish (maintain) business relations (including via termination the business relations) with the customer in case of its unacceptably high risk assignment after assessing/reassessing customer risks for legalization of the proceeds from crime/terrorism financing; (iv) assessing the risk of using bank services for legalization of the proceeds from crime/terrorism financing; (v) monitoring the risk of legalization of the proceeds from crime/terrorism financing; (vi) taking prevention measures; (vii) the procedure for training of Bank’s Employees on implementation of the Compliance Risk Management Program of Financial Monitoring.

Internal AML/CFT policies of JSB 'UKRGASBANK' are checked by the regulator (the National Bank of Ukraine) in the framework of its planned inspections that are conducted not less than once in three years. The last inspection was conducted in the third quarter of 2014.

According to Section 6 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» (with amendments and supplements) internal audit of the bank annually checks compliance with Ukrainian law in the field of prevention of legalization of the proceeds from crime/ financing of terrorism (including the adequacy of steps taken by the bank in respect of managing the risk of legalization of the proceeds from crime/financing of terrorism).

Last updated on 15.10.2015 Internal AML/CFT policies of JSB 'UKRGASBANK' reflects legislative amendments to the Regulation on Financial Monitoring by Banks approved by Resolution of the Board of the National Bank of Ukraine No.417 dated 26.06.2015.

Further be advised that, the bank (і) does not open and maintain anonymous (numbered) accounts; (ii) does not establish correspondent relations with shell banks and with non-resident banks that maintain correspondent relations with shell banks; (iii) does not establish business relations (does not carry out foreign exchange financial transactions, financial transactions with precious metals, cash transactions with for the legal entities or individuals in case of suspicions that the person is not acting on his/her own behalf or they are added into the List of persons related to commitment of terrorist activity or persons to whom international sanction were applied approved by the order of the State Financial Monitoring Service of Ukraine No.183 dated 07.10.2010 (with amendments and supplements) or in other cases stipulated by Ukrainian legislation in force; (iv) does not provide customer services based on the technological decisions that enable operations or/and services without the client’s presence and not ensured by the information protection means on removable storage devices (technical innovations).

According to the Ukrainian legislation in effect, 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 approved and are in line with the requirements of Ukrainian legislation in force.

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