Principles and Codes and FATCA

Anti-Money Laundering & 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 2013(1), and the 2016 amendment, and other applicable legal and regulatory requirements.  Hellenic Bank has zero tolerance for ML & TF breaches. 

  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.
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FATCA - CRS

FATCA, which stands for Foreign Account Tax Compliance Act,  is intended to make United States tax subjects who hold assets outside the United States correctly file tax returns to the United States tax authorities the IRS.

Τhe Common Reporting Standard (CRS) is aiming at improving international tax compliance and preventing tax evasion, through the automatic exchange of information between the countries that implement CRS. 

The Cyprus government has reached an agreement in substance with The United States and is treated as having an intergovernmental agreement in effect. This agreement requires Cypriot  Financial Institutions to identify financial accounts held by U.S.  citizens or by entities that are organized in the U.S.  or controlled by certain U.S persons and report those accounts annually to Cyprus Income Tax Authorities.
 
Hellenic Bank Public Company Ltd,  is registered under Model 1 IGA and the Global Intermediary Identification Number (GIIN) is  7THJLM.00000.LE.196
 
Therefore, customers might be contacted by the Bank, to state information regarding their country of residence and Tax identification number.  It is important to respond to this request.
 
Customers that believe that they as individuals or their companies could be a US person, should visit  The United States IRS website www.IRS.gov for further/additional information.

CRS requires the financial institutions to submit information on financial accounts that are held, directly or indirectly, by account holders who are tax residents of countries which implement CRS.
For more details you can read the announcement below of the Association of Cyprus Banks.

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MiFID

The Markets in Financial Instruments Directive (MiFID) is a new body of regulation mandated by the European Union, intended to enhance and harmonize investor protection and increase transparency and competition in the European markets. It establishes a consistent regulatory framework across the European Economic Area (EEA), and will change the way the capital markets operate across Europe in terms of both individual participants and the market infrastructure. MiFID introduces new and more extensive requirements with which investment firms must comply. 

MiFID was transposed into the national laws of EEA states (EU member states together with Norway, Iceland and Liechtenstein) by 1st November 2007. Cyprus enacted the Investment Services and Activities and Regulated Markets Law of 2007 (Law 144(I)/2007) implementing directives 2004/39/EC and 2006/73/EC of the European Parliament and of the Council on 26th October 2007. 

The implementation of MiFID will have a significant impact on Hellenic Bank Group and how we do business and interact with our clients. MiFID touches on each key stage of our relationship with you as a client of Hellenic Bank Group, and will impact upon the following key areas:

  • Best Execution
  • Order Handling
  • Client Categorisation
  • Terms of Business and Client Agreements
  • Suitability and Appropriateness
  • Client notifications
  • Pre and Post Trade Transparency
  • Transaction Reporting
  • Safeguarding Client Financial Instruments and Funds; and
  • Conflicts of Interest. 

Whilst the changes being brought in by this EU directive are significant, we wish to make the transition to the post-MiFID landscape as smooth as possible for our existing clients. 

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Regulator Authority

Hellenic Bank Public Company Ltd is a public limited liability company duly registered with the Department of Registrar of Companies and Official Receiver of the Republic of Cyprus licensed by the Central Bank of Cyprus to carry out banking operations in accordance with the Central Bank of Cyprus Laws of 2002 and the Banking Laws of 1997 as these have been and/or may from time to time be amended, replaced, extended or re-enacted . Hellenic Bank Public Company Ltd is regulated by the Central bank of Cyprus and submits to it financial returns and reports in accordance with the provisions of the relevant law and the regulations issued subject thereto.

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