Anti-Money Laundering and Terrorism Financing Policy

The Central Bank of Russia is the regulatory authority for credit institutions in the Russian Federation, which is a member country of FATF/GAFI. The AML activity of Russian banks is regulated and performed in accordance with the following major regulatory documents and a number of other Central Bank instructions and regulations:

Federal Law No. 115-FZ dated August 7, 2001 «Anti Money Laundering and Terrorism Financing Prevention»;

Regulations of the Bank of Russia No. 499-P dd. October 15, 2015 «On identification by credit institutions of customers, representatives of the client, beneficiaries and beneficial owners, in order to counteract the legalization (laundering) of proceeds from crime and the financing of terrorism»;

Letter of the Bank of Russia No 375-P dd. March 2, 2012 «On Requirements for Internal Control Rules in Credit Institution with the Purpose of Countering the Legalization of Earnings Received in an Illegal Way (Money Laundering) and Terrorism Financing».

The Bank follows a policy of strict compliance with all existing regulatory requirements and regulations. It has established a special Financial Monitoring Division responsible for internal controls for AML and terrorism financing prevention and developed internal «Regulations for internal control procedures for anti-money laundering and terrorism financing prevention».

The Bank's responsibilities related to AML / CFT Internal Control Regulations are as follows:

to identify customers, their representatives and beneficiaries, except as set out in paragraphs 1.1 and 1.2 of Article 7 of Federal Law № 115-FZ;

to keep information about clients and beneficiaries up-to-date;

to conduct research on its clients and their operations;

to document and submit the information required by the Federal law № 115-FZ to the authorized body;

to suspend client operations for the duration established by the Federal Law № 115-FZ (except for transferring funds to the client's account), if at least one of its members is an organization or an individual having an existing indicator of involvement in extremist activity or terrorism, or a legal entity directly or indirectly owned or controlled by such organizations or persons, or a person or entity acting on behalf of or at the direction of such organizations or persons;

to take measures to avoid relations with non-resident banks registered on territories that are not governed by permanent regulatory bodies whose accounts may be used by other banks.

AML / CFT Internal Control Regulations prohibit the Bank:

to open accounts (deposits) for anonymous owners, that is, without such individuals or legal persons presenting identification documents necessary for opening accounts (deposits);

to open accounts (deposits) for individuals without their presence or the presence of their authorized representatives;

to build and maintain relations with non-resident banks registered on territories that are not governed by permanent regulatory bodies;

to open a bank account (deposit) for a client unable to present necessary identification documents for either the client or the client's representative as stipulated by the Federal Law № 115-FZ and Internal Control Regulations, and supporting information that must be documented as stipulated by the Federal Law № 115-FZ and Internal Control Regulations;

to advise clients and other persons about the forms, techniques and methods utilized by the Bank's AML / CFT internal control;

to prevent information regarding AML / CFT control reaching clients and others, except: to inform clients about suspension of a transaction, denial of a client's requests related to a transaction, denial of a request to open a new bank account (deposit), or notifications regarding clients' obligations to provide documents as specified by the Federal law № 115-FZ.

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