Protection against money laundering
CONCEPT AND BASIC PRINCIPLES OF PROTECTION OF THE BANK AGAINST MONEY LAUNDERING AND TERRORIST FINANCING
OTP Banka Slovensko, a.s. has adopted the concept of protecting the bank against money laundering and terrorist financing in order to prevent abuse of the bank for this purposes. In the concept, the fundamental principles based on mainly Slovak and also international legislation, the practice and own activities of the are defined. For the purpose of its application in practice The Board of Directors approved the program of activities of OTP Banka Slovakia a.s., which is continuously available to all employees of the bank.
For the purpose of its application in practice, the Board of Directors of the Bank approved the Program of activities of OTP Banka Slovensko, a.s., which is continuously available to all employees of the bank.
1. Fundamental responsibilities and powers of the Bank
The fundamental responsibilities and powers of the bank regarding money laundering and terrorist financing (hereinafter as AML) are laid down by Act No 297/2008 Coll. on the prevention of money laundering and terrorist financing and on the amendment of certain laws, as amended and by Act No 483/2001 Coll. on banks and on the amendment of certain laws, as amended.
Responsibility of employees in the field of AML is defined in the organizational structure of the bank. Within the Statutes and Competency Guidelines Regulations, the competence and responsibility in the area of prevention, detection, monitoring and reporting of unusual transactions is defined.
The Board of Directors of the Bank is responsible for the overall protection against money laundering and terrorist financing the laundering and terrorist financing and implementation of the concept of prevention. The AML Officer is responsible for its practical implementation ensuring the fulfilment of the concept of protection and reporting of unusual transactions and other legal requirements.
2. Risk assessment, client care, client's risk profile
When creating rules and specific procedures, in addition to the above laws the bank relies on methodological guidance of NBS, international standards, guidelines gained in the course of the exercise of supervision and control by the NBS and the Financial Intelligence Unit (hereinafter referred to as "FIU") as well as the experience and practice of obliged persons in the sector of financial services.
The system of risk assessment, client care and client´s risk profile is based on internationally recognized standards, compliance with obligations set in generally binding legal regulations and based on the group standards.
Procedures for assessing the risk of the clients and their business is based on a risk-based approach, taking into account the rules of the so-called "KYC" - know your customer, the range of products and services that clients use in the bank and monitoring their business operations.
In terms of protection against the laundering of proceeds of crime and the prevention of terrorist financing, adequate care is also paid to correspondent banks and the Bank emphasis on compliance with Regulation (EU) 2015/847 of the European Parliament and of the Council on information accompanying transfers of funds.
3. Activity programme
The Bank has prepared a so-called Activity Programme, approved by the statutory body. This programme is based on generally binding legal regulations, mainly on the act on protection against the laundering of proceeds of crime and the prevention of terrorist financing, act on banks, NBS measures on risk management and methodological directions and FSJ guidelines, as well as bank Statutes.
The programme specifies the concepts and principles of the Bank's AML policy, regulates the basic principles and practices of the Bank, regulates permissions, responsibilities and procedures for employees of first contact, the designated person(s) and the unit responsible for the protection in the field of AML.
4. Literacy, staff training, information system
Professional training of bank employees in the field of AML is carried out regardless of the employee's work position. Within the adaptation process, each new employee undergoes a series of specialized trainings, inter alia, on the issue of AML. Subsequently, employees are enrolled into the internal training system (eLearning), in which they pass a test that is evaluated by authorized persons.
Periodic training of staff who are in contact with clients is carried out at least annually.
As part of the training of personnel, there is a separate chapter on typology of unusual transactions.
5. Assessing and implementation of transactions in terms of unusualness and system of reporting Suspicious Financial Transactions (SFT)
Assessing and processing of suspicious financial transactions is carried out on two levels. First contact employees are the first level, they process customers' orders for execution of transactions, or financial operations. Authorized employees centrally process inputs from employees of first contact and monitor other operations detected by their own methods and systems designated for this purpose. All business transactions evaluated as unusual in terms of legal requirements are reported to the Financial Intelligence Unit.
6. International sanctions
OTP Banka Slovensko, a.s. fulfils the obligations arising from of laws defining international sanctions such as a summary of limitations, commands and prohibitions introduced for the purpose of maintaining or restoring international peace and security arising from specific internationally binding documents and measures.
As a result of enforcement of these restrictions, the Bank uses a system to detect entities against which there are international sanctions / embargoes declared. As part of the payment system, it has set a control of subjects who are on various sanction lists.
7. The internal control system and its security
The concept of protection against legalization of proceeds from crime and protection against terrorist financing is elaborated and specified in several by-laws of the bank so as to be able to detect at different levels of management.
The Bank operates a system of control aimed at the fulfilment of measures in the field of AML at all levels of management.
Authorized employees inform min. once a year the Board of Directors and the Supervisory Board about their activities, which also include inspection activities.