ANTI-MONEY LAUNDERING (AML) POLICY
1. Introduction & Purpose
Core Commitment: Enter Corporate Bank (“ECB”) is committed to preventing money laundering and terrorist financing.
Legal Compliance: This AML policy ensures compliance with all applicable national and international anti-money laundering laws.
Zero Tolerance: ECB maintains a zero-tolerance stance toward financial crimes and illicit activities.
2. Scope & Applicability
Personnel: It applies to all employees, senior management, board members, contractors, and third-party representatives.
Operations: It covers all business units, geographic locations, and financial transactions.
3. Customer Due Diligence (CDD)
ECB applies a risk-based approach to verifying the identity of clients before establishing a business relationship.
Simplified Due Diligence (SDD)
Application: Used for low-risk clients, such as publicly listed companies or regulated entities.
Requirements: Basic company/corporation (“entity”) registration check and verification of official existence.
Standard Due Diligence (CDD)
Individual Clients: Verification of full name, date of birth, and residential address using government-issued photo ID and proof of address (utility bill under 3 months old).
Corporate Clients: Collection of entity incorporation certificates, registered address, and list of directors.
Ultimate Beneficial Owners (UBO): Identification and verification of any individual owning or controlling over 25% of the entity shares or stock.
Enhanced Due Diligence (EDD)
Application: Applied to high-risk clients, transactions, or Politically Exposed Persons (PEPs).
Requirements: Source of Wealth (SoW) verification, Source of Funds (SoF) documentation, and senior management approval.
4. Sanctions and PEP Screening
Initial Screening: All new clients are screened against global sanctions lists (OFAC, EU, UN) and PEP databases prior to onboarding.
Continuous Monitoring: Existing client databases are rescreened at regular intervals monthly.
Prohibited Clients: No business relationship will be established with individuals or entities on active sanctions lists.
5. Transaction Monitoring & Red Flags
ECB monitors transaction patterns to detect anomalies. Red flags include, but are not limited to:
Structured Transactions: Breaking down large cash deposits into smaller amounts to evade reporting thresholds.
Unusual Behavior: Clients who provide vague, misleading, or fake information, or are overly anxious about ID requirements.
Mismatched Logic: Transactions that do not align with the client’s known business model or economic profile.
High-Risk Jurisdictions: Funds originating from or sent to weak AML controls countries.
6. Suspicious Activity Reporting (SAR)
Internal Reporting: Employees must immediately report any suspicious activity to the MLRO using the Internal Escalation Form.
Confidentiality: Staff is strictly prohibited from informing ("tipping off") a client that they are under investigation.
External Reporting: The MLRO evaluates the internal report and, if validated, files a formal SAR with the financial intelligence unit within the legally mandated timeframe.
7. Record Keeping
Retention Period: All CDD documents, transaction records, and SAR logs must be securely stored for a minimum of 5 years following the termination of the business relationship.
Format: Records can be kept electronically or physically, provided they are easily retrievable for regulatory audits.
8. Employee Training
Frequency: All relevant employees must undergo AML training upon hiring and attend mandatory refresher courses at least twice a year.
Content: Training covers legal obligations, recognizing red flags, internal reporting processes, and penalties for non-compliance.
Approved by the Board of Directors on July 28, 2026.