STATEMENT ON THE OBSERVANCE OF ANTI-MONEY LAUNDERING AND COMBATING TERRORIST FINANCING REQUIREMENTS
The National Commercial Bank (NCB) is committed to participating in international efforts to combat money laundering and terrorist financing. To this extent NCB has developed a Bank-wide Anti-Money Laundering and Combating Terrorist Financing policy that is based upon the Saudi Arabian laws and regulations and, international best practices such as recommendations made by the Financial Action Task Force (FATF).
Our AML/CTF policy is the minimum standard that all operations of the Bank must follow. In addition, all overseas offices, branches, subsidiary companies or affiliates are required to comply with their local anti-money laundering and combating terrorist financing laws and regulations, which may be more stringent.
The key aspects of the Bank policy are set out below.
NCB is committed to the prevention of anti-money laundering and combating terrorist financing. We will endeavour to:
Establish effective and efficient internal communication lines for reporting suspicious or unusual customer activity, Compliance Division – The Anti-Money Laundering Department provides advice and training to support that.
Ensure that appropriate internal controls are in place and are operating effectively.
Document and disseminate local procedures and controls that supplement or interpret local laws, regulations or Bank Policy, adherence to these policies will be monitored at the Bank level.
Identify potential AML/CTF risks relevant to customers, products and channels.
Use a risk based approach and all reasonable steps to verify the identity of our customers, including the beneficial owners of corporate entities, and the principals behind Customers who are acting as agents and, monitor their business activities within the Bank.
Take all reasonable steps to ensure that ‘Know your Customer’ information is collected and kept up-to-date, and that identification information is updated when changes occur in any relationship.
Ensure that all relationships, individual or corporate customers and beneficial owners are regularly screened against appropriate international and local sanction lists.
Undertake the identification and risk assessment of Politically Exposed Persons (PEP’s).
Undertake On-going Due Diligence for all customers and Enhanced Due Diligence for High Risk customers.
Provide advice and management reports to Senior Managers regarding regulations and compliance with these regulations.
Manage regulatory inquiries and incidents in a timely manner.
Promptly report, to the concerned Authorities, on any customer activity where reasonable grounds exist to suspect that the activity may be linked to money laundering or terrorist financing.
Train appropriate staff on the requirements of the Bank AML/CTF policy and local laws and regulations.
Retain records of identification, transactions, training, compliance monitoring, and suspicious transaction reports, in line with the applicable Rules and Regulations.
Co-operate with any lawful request for information made by government agencies during their investigations into money laundering or terrorist financing to the extent permitted by law.
Support government agencies and international bodies in combating the use of the financial system for money laundering or terrorist financing.
Promote effective compliance within the Bank and the assurance of oversight and follow-up actions in the event of non-compliance.
Transaction Monitoring and Sanction Screening
NCB has a sophisticated transaction surveillance system in place designed to detect unusual or suspicious patterns of activity. Transaction alerts generated from this system are analysed and investigated within a reasonable period of time. Formal notifications to the concerned Authorities are made in line with local legal and regulatory requirements.
All customers are screened on a daily basis against international sanction lists and all potential matches are analysed and investigated and where appropriate reported to the concerned Authorities. In all countries in which NCB operate or have a relationship, NCB complies with these local laws and sanction lists.
Correspondent Banking Policy
The correspondent banking policy describes the risks associated with correspondent banking relationships and provides a framework of core requirements and procedures.
All correspondent banking relationships are subject to Enhanced Due Diligence inquiries and review.
NCB is required by law to adhere to Saudi regulations which require all Banks not to open accounts for or deal with shell banks, moreover Saudi regulations prohibit Saudi banks to provide anonymous accounts. Furthermore, NCB applies S311 of the USA Patriot Act and does not maintain or open accounts with Shell Banks or provide anonymous accounts.
If you have any questions or inquiries regarding The National Commercial Bank’s Anti-Money Laundering and Combating Terrorist Financing Programme, please contact:
Attention: Money Laundering Reporting Officer (MLRO), Compliance Division
|The National Commercial Bank, ||PO Box 3555, |
|Jeddah 21481, ||Kingdom of Saudi Arabia|