AML/CTF AND SANCTIONS COMPLIANCE STATEMENT
SNB is committed to participating in international efforts to combat money laundering and terrorist financing. Towards this end, SNB has developed a Bank-wide Anti-Money Laundering and Combating Terrorist Financing Policy that is based upon the Saudi Arabian laws and regulations, and compliant with international best practices such as recommendations made by the Financial Action Task Force (FATF). This policy was approved by SNB Board of Directors.
The SNB AML/CTF policy is the minimum standard that all operations of the Bank, overseas offices, branches, subsidiaries and associates must follow. In addition to this, all overseas offices, branches, subsidiaries and associates are required to comply with their local anti-money laundering and combating terrorist financing laws and regulations, which may be more stringent. Further to AML/CTF policy, detailed desk-top processes and procedures have been defined and placed to cover the Investigations, Reporting, Sanctions, Advisory and AML/CTF Monitoring.
The AML/CTF Compliance Program has been approved by SNB Board of Directors. All AML/CTF related issues are escalated to Group Chief Compliance Officer and subsequently forthwith referred to the Compliance Committee. The Compliance Committee would then elevate these issues up to the Audit Committee (Board Committee). All issues are raised in writing to the Compliance Committee who meets quarterly while ad-hoc meetings can be called for whenever deemed necessary.
Anti-Money Laundering & Counter Terrorist Financing Division (AML/CTF Division)
The SAMA Anti-Money Laundering and Terrorist Financing Guidelines requires that all Banks within Saudi Arabia must establish a dedicated Unit to combat money laundering and terrorist financing. SNB is in full compliance with this directive guidelines that is dedicated AML/CTF Division has been established with a Senior Bank Officer made primarily responsible for this Division.
The AML/CTF Division is responsible for and principally tasked with the monitoring, investigation and reporting of suspicious or unusual transactions to the relevant Authorities. The AML/CTF Division is manned by specialized human resources committed to address any and all relevant questions and issues pertaining, among others, to AML/CTF Investigations, Sanctions, AML/CTF Efficiency and AML/CTF Monitoring.
Anti-Bribery and Corruption
SNB has a robust anti-corruption measures and practices to protect the reputation and the interests of all stakeholders. The monitoring of these crimes has been imbedded within SNB Monitoring System and covers all of our customers. In addition, a process is in place for all employees to raise their suspicions through a STR or through our Whistleblowing when this type of activity is suspected.
Internal Audit Function
SNB established a central and independent G roup Internal Audit (GIA) that reports directly to the Audit Committee of the Board of Directors. GIA conducts assessments of banking areas including overseas branches to evaluate the effectiveness of risk management, control and governance processes. This include reviews of internal policies and procedures to ensure that defined operational procedures are being adhered to. The GIA uses a Risk-Based Approach to schedule audit reviews to ensure that high-risk areas are tested more frequently. The GIA Audit Plan is approved annually by the Audit Committee after obtaining input from Senior Management. The results of the reviews are reported to Management and the Audit Committee with detailed recommendations for improvements that are tracked to ensure full resolution. As part of the approved Audit Plan, Compliance and AML are reviewed periodically.
SNB assesses AML/CTF and Sanctions risk exposure and ensures that the risk is not outside SNB's own risk tolerance. The risk assessment evaluates each risk category independently and in concert, including geographic locations, relationships (customers), products/services and delivery channels. Accordingly, the result of the risk assessment will assist in determining the level and type of controlling measures that should be adopted to mitigate the risk. SNB's risk assessment methodology will be subject to update as needed.
SNB uses a Risk Based Approach (RBA) and undertakes all reasonable steps to verify the identity of our customers, including the beneficial owners of corporate entities, the principals behind customers who are acting as agents and the monitoring of their business activities. SNB has a defined customer risk assessment methodology for AML/CTF and Sanctions. All SNB relationships are risk-ranked based on FATF recommendations and the SAMA rules using a number of financial and non-financial factors/criteria that categorize them into three (3) distinct bands: Low, Medium and High. All "High Risk" relationships are closely monitored, approved by the CEO/Senior Management and Compliance at inception or when a relationship becomes "High Risk". A corresponding periodic review is also undertaken to ascertain the propriety of maintaining these business relationship(s).
Know Your Customer (KYC), Due Diligence and Enhanced Due Diligence
SNB takes all required steps to ensure that 'Know Your Customer' information is collected, kept up-to-date and identification information is updated when changes occur in any relationship. SNB has processes for the identification of customers on whose behalf it maintains, operates accounts or conducts transactions. Once establishing a relationship, all customers must complete fully an Account On-Boarding pack at one of SNB's Branches through the Customer Services Representative, then to be validated and approved by the Branch Manager/Customer Service Manager or through the Online Channels using independent authentication sources. These On-Boarding documents are then reviewed by a centralized KYC function to ensure that all required information and documents have been met. A consistent process is applied to all customers using standard system generated On-Boarding forms. Moreover, ad-hoc reviews are conducted when "unusual" activity is detected.
All documentation requirements follow the SAMA Rules of Opening Bank Accounts and the Anti-Money Laundering and Terrorist Financing Guidelines. For more information please visit: www.sama.gov.sa .
SNB undertakes Enhanced Due Diligence (EDD) on high-risk customers and transactions that have been identified to pose a heightened risk of illicit activity. The SNB AML/CTF Policy has defined the following objectives while conducting EDD:
- To obtain more information/documentation regarding the source(s) of funds and the client's nature of business;
- To obtain information regarding the client's assets and transactions;
- To ensure a proper understanding of the client's activities;
- To ensure that the account is used for the same purpose defined by the client while opening the account;
- To obtain additional documents or information to identify the customer; and
- To undertake customer site visits.
Politically Exposed Person (PEP)
SNB has a defined policy covering relationships with Politically Exposed Persons (PEP's), their family members and close associates. According to the SAMA Anti-Money Laundering and Terrorist Financing Guidelines " Individuals who are entrusted with prominent public functions domestically or in a foreign country, or who occupy senior management positions or positions in an international organization, or who occupy senior management positions or positions in an international organization, for example, heads of state or of government, senior public or government senior politicians, judicial or military officials, senior executives of state-owned corporations, high-ranking political party officials, or employees of regional and international organizations. In addition, business relationships with family members or close associates of PEPs involve reputation risks similar to those with PEPs themselves."
PEPs are identified either through local knowledge/criteria. SNB has a designated team to monitor and apply enhanced due diligence measures based on a risk-based approach for customers classified as "High Risk". All PEPs are classified as "High Risk". This involves obtaining additional information pertaining to their activities and business relationships and close monitoring of the financial transactions. All relationships classified as "PEPs" require the Higher Management's approval before establishing and continuing a business relationship.
Neither SNB nor any institution within the shareholding structure are based on bearer shares. In addition, customers who hold bearer shares in their shareholding structure are prohibited from establishing/maintaining a relationship with SNB.
Transaction Monitoring of Suspicious or Unusual Transactions
SNB uses the Symphony AI which is a sophisticated automated solution to detect unusual or suspicious activity. This covers all financial and non-financial transactions. SNB has implemented rules/scenarios that identify transactions and activities outside of the customers' profile and investigates these transactions accordingly.
Reporting of Suspicious Transactions
SNB employees have a legal responsibility to report all unusual or suspicious transactions which are overly complicated or do not make economic sense. Where suspicions arise, employees complete a "Suspicious Transaction Report" which is sent immediately to the AML/CTF Division and a new case is created within the Symphony AI Transaction Monitoring System. Further investigation is then undertaken by the AML/CTF Division who decide whether a formal report should be made to the Authorities. SNB has a policy of protecting employees if they report, in good faith, any suspicious activity. SNB employees are aware that the notification of suspicious transactions to the Authorities does not conflict with the provisions of banking secrecy and customer confidentiality under the Saudi Banking Laws and Regulations.
Walk-in or occasional customers include citizens, residents and visitors on a temporary visa/residence. SNB 's policy states that any transactions from walk-in customers must not be accepted unless they fall under the following categories:
- Payment of utility bills;
- Government dues;
- Purchase of visitor mandatory insurance policies
Walk-in or occasional customers are also allowed to have currency exchange and cashing cheques. The amount of each transaction shall not exceed SAR 5,000 or a total of SAR 50,000 during one year.
In accordance with the Anti-Money Laundering and Terrorist Financing Guidelines, SNB prohibits the opening of anonymous or numbered accounts. Valid identification is referenced to original identification documents. Thus, no accounts will be opened until a valid personal or commercial identity has been verified and established.
SNB has policies to reasonably ensure that it only transacts with correspondent banks that possess licenses to operate in their countries of origin. SNB complies with the SAMA rules and regulations that prohibit Saudi Arabian banks to establish any relationship with a Shell Bank.
SNB uses a mixture of tailor-made and standard Wolfsberg questionnaires in order to examine and evaluate its correspondents' AML/CTF policies or practices. A formal review is conducted on every Correspondent Bank on a regular basis utilizing a Risk-Based Approach. The same procedure is being observed in relation to the establishment of new corresponding banking relationship. All documentation is reviewed to ascertain country of incorporation, office location, license, ownership structure, AML policy, board of directors and the fully completed AML/CTF questionnaire, etc.
Sanctions Compliance Program
SNB Sanctions Compliance Program governs and informs all facets of the bank's operations to ensure robust controlling measures. The SNB Sanctions Compliance Program creates a sanctions compliance framework to ensure compliance and effectively manage risk. The Sanctions Compliance Program addresses sanctions-related components of the bank's policies and procedures, bank management and personnel roles and responsibilities, risk assessment, internal controls, testing and monitoring, employee training and awareness, and regular auditing.
SNB has established policy dictating the bank compliance with local and international sanctions (including Sanctions imposed by local authorities, the United Nations (UN) Security Council, the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC), and other sanctions programs where applicable) and defined procedures and processes to set the responsibilities of each line of defense.
The SNB Sanctions Compliance Program is the standard that all operations of the Bank, overseas offices, branches, subsidiaries or associates must follow. In addition to this, all overseas offices, branches, subsidiaries or associates are required to comply with their local laws and regulations.
SNB internal policies require payment and non-payment messages to be transparent, in line with Basel requirements and FATF recommendations. Furthermore, SNB does not omit, delete or alter information in the payment messages or orders. All payments are screened against International and Local Sanction Lists (United Nations (UN), Saudi Central Bank (SAMA), Office of Foreign Asset Control (OFAC), Interpol, European Union (EU), and HM Treasury) using the Symphony AI Sanctions Screening System in real-time. Subject to applicable local laws and regulations, SNB will cooperate as fully as practicable with other financial institutions in the payment inquiry when requested in order to provide information about the parties involved.
Sanctions and Embargoes
SAMA requires all Saudi Arabian banks to adhere fully to the UN and SAMA sanctioned countries, sanctioned entities and individuals' lists. SNB has its own internal policies to manage local and international sanctions based on each sanctioned country and sanctions program. In addition, SNB issues and frequently updates Sanctions Guidelines in order for Business Units to take the necessary actions when dealing with countries subject to restrictive measures including escalating cases that require compliance guidance/approval.
Furthermore, SNB screens all relationships, individuals, corporate customers and beneficial owners on a daily basis against International and Local Sanction Lists (UN, SAMA, OFAC, Interpol, EU, HM Treasury) through the Symphony AI Transaction Monitoring System, using the World-Check database. In addition, payment/non-payment messages are screened in real-time through the BAE Sanction Screening System (incoming/outgoing) prior to processing.
SNB has established an AML/CTF employee-training program to educate employees about anti-money laundering and combating terrorist financing in order to assist them in identifying suspicious or unusual customer transactions. Employee anti-money laundering and combating terrorist financing training is an on-going process.
Training is conducted at the start of joining the Bank and then annually thereafter. The AML/CTF training includes:
- Identification and reporting of transactions that must be reported to government authorities through AML/CTF Division;
- Examples of different forms of money laundering involving the Customer's products and services;
- Internal policies to prevent money laundering and terrorist financing; and
- Informing Bank employees to comply with SNB's internal policy and procedures and making them aware that warning customers (Tipping off) that a suspicious report has been made or that they are under suspicion/investigation constitutes a criminal offence.
In addition, Sanctions Compliance training programs have been developed to educate all employees about their responsibilities towards sanctions compliance (including sanctions imposed by local authorities, United Nations Security Council, The U.S. Department of the Treasury's Office of Foreign Assets Control, and other sanctions programs where applicable).
Furthermore, changes in AML/CTF/Sanctions related laws or changes to existing policies or practices are communicated to relevant employees by distributing these new circulars/rules/laws through e-mails, revised policies and procedures and through the Banks' Intranet site. Training SNB employees at foreign branches and subsidiaries is conducted by Compliance personal within these jurisdictions.
Retention of Records
SAMA requires financial institutions to maintain all types of records for ten (10) years, at a minimum. SNB retains all records/documents relating to their operations in accordance with normal banking practices, for ease of reference and for their own use as well as for the perusal and reference of its own Supervisory Authorities, Internal and External Auditors.
Assessment of Overseas Branches and Subsidiaries
Pursuant to the Saudi Arabian AML/CTF Law and Anti-Money Laundering and Terrorist Financing Guidelines, SNB assesses its Overseas Branches and Subsidiaries. These assessments focus on the following main subjects:
- Governance and Oversight;
- AML/CTF and Sanctions Policy;
- Risk-Based Approach (RBA);
- Customer Risk Ranking/Profiling;
- Products, Services, Programs and Channels Risk Assessment;
- Know Your Customer Procedures;
- Customer Identification Program;
- Customer Due Diligence (CDD);
- Employee Training;
- Record Keeping;
- Transaction Monitoring (AML/CTF and Sanctions);
- Reporting; and
- FATF and Sanctions Requirements.
If you have any questions or inquiries regarding The Saudi National Bank's Anti-Money Laundering, Combating Terrorist Financing and Sanctions Programs, please contact:
Attention: Head of Anti-Money Laundering and Counter Terrorist Financing, Group Compliance.
The Saudi National Bank, King Fahd Road 3208 - Al Aqeeq District Unit No.778 Zip Code 13519 – Additional No. 6676 Riyadh, Kingdom of Saudi Arabia