Anti-Money Laundering and Counter-Terrorism Financing Principles

The purpose of Anti-Money Laundering (“AML”) and Counter-Terrorism Financing (“CTF”) laws and regulations globally is to prevent criminals from laundering funds and financing terrorism.
 
Money laundering and terrorism financing undermines the confidence of the public in the international financial system and presents a reputational risk to Hellenic Bank.  
 
Hellenic Bank is committed to combating money laundering and terrorism financing (“ML & TF”) and complying with the Cyprus Anti-Money Laundering Laws 2007 to 2018, and other applicable legal and regulatory requirements.  Hellenic Bank has zero tolerance for Economic Sanctions ("ES") breaches. 

Consistent with Hellenic Bank’s compliance culture, Hellenic Bank’s approach to controlling ML & TF risk is governed by the following key principles:

  1. Compliance with AML & CTF laws and regulations;
  2. Cooperation with and support of regulators and law enforcement agencies in their efforts to prevent, detect and control money laundering and terrorism financing;
  3. Provide customers with products and services consistent with Hellenic Bank’s ML & TF risk appetite and code of conduct, and
  4. Adherence to the requirements of Hellenic Bank’s Group AML & CTF Program.


Hellenic Bank’ s Group AML & CTF Program is commensurate with Hellenic Bank’s risk profile and is approved by Hellenic Bank’s Board of Directors. The Group AML & CTF Program is documented in written policies and procedures, including the AML, CTF Policy, and provides a group consistent system of controls to identify and mitigate ML & TF risks and comply with AML & CTF laws and regulations.

The Group AML & CTF Program is structured to reflect Hellenic Bank’s AML & CTF Control Framework aiming to prevent, detect and report suspicious activity.  This framework includes:

  1. Written AML & CTF policies and procedures covering Customer Due Diligence, Know Your Customer and Know Your Transaction requirements, Transaction Monitoring and Reporting of Suspicious Activity;
  2. ML & TF Risk Assessment;
  3. AML & CTF automated monitoring and screening systems;
  4. A designated AML Compliance Officer;
  5. An ongoing employee training program;
  6. Records Retention, and
  7. An independent audit function to test the AML & CTF Program.


Article 60 of the Law refers to the obligation of banks to adopt measures and procedures for, amongst other, identifying and verifying the identity of their customers and collecting information on the purpose and intended nature of the customer relationship. Furthermore, paragraph 83 of the Directive mentions that banks must ensure that their customer identification records and the information that form the business/ economic profile of their customers remain completely updated throughout the customer relationship.
Failure or refusal by a customer to submit the required data and information for updating and as a consequence, Hellenic Bank is unable to comply with the customer identification requirements set out in the Law and the Directive, then Hellenic Bank, in accordance with article 62(4) of the AML Law and paragraphs 81 and 100 of the Directive, does not perform a transaction through client’s bank account/s and should terminate the business relationship and close all of client’s accounts, while at the same time it should examine whether it is warranted, under the circumstances, to submit a report of suspicious transactions/ activities to the Unit for Combating Money Laundering (MOKAS) .