Anti-Money Laundering AML

The negative economic effects of money laundering and terrorist financing on economic development are difficult to quantify

 

Statement of Compliance

Yemen, as one of the Middle East and North Africa Region (MENAFATF) members, adheres to Anti-Money Laundering (AML) and Combating Terrorist Financing (CFT) recommendations.

According to FATF recent statement, Yemen has completed its agreed action plan.  Hence, FATF will continue to monitor the situation, and conduct an on-site visit at the earliest possible date.

Quote:

  “While the FATF determined that Yemen has completed its agreed action plan, due to the security situation, the FATF has been unable to conduct an on-site visit to confirm whether the process of implementing the required reforms and actions has begun and is being sustained. The FATF will continue to monitor the situation, and conduct an on-site visit at the earliest possible date.”

In terms of AML/CFT, Tadhamon Bank has established internal procedures and policies to detect, combat Money Laundering (ML) , Finance of Terrorism (FT) , Fraud, corruption, and bribery in accordance with the Yemeni Law no. (1) of 2010 on Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) which entered to force on Jan.1st 2010 in Yemen. This law, which came into effect following FATF Recommendations, has been amended by the Law no (17) of 2013 and the statutory duties resulting therefrom have been clarified by the corresponding guidelines issued by the Financial Information Unit (FIU) and Central Bank of Yemen.

Tadhamon Bank is required by law to check regularly and document the identity of their customers. We have a written policy in place to meet the requirements imposed, which includes establishing and, ongoing basis, conducting customer due diligence (CDD) and maintaining records in accordance with applicable regulations. These Policies and Procedures are applicable to all domestic branches and subsidiaries abroad as well.

 

Tadhamon Bank carries out an on-going Anti-Money Laundering, anti-Fraud Training and Awareness Programme for appropriate personnel and conduct an independent audit of the Programme. Also implemented clear procedures to identify and report suspicious transactions and to confirm the legitimacy of the source and destination of larger transactions before processing them.

Tadhamon Bank do not offer banking services to any bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group (shell bank). IT has a policy to ensure that we do not conduct transactions with or on behalf of shell banks through any of our accounts or products. Also the bank do neither maintain relationships with banks that use payable-through-accounts nor do keep such accounts in its own books.

It is prohibited to deal with any sanctioned entity. For that reason, Tadhamon Bank has implemented Sanctions Screening Web-Based application which is connected to the SWIFT, this application allows compliance department to monitor and check all SWIFT transactions (inward - outward), and determine to reject a transaction if it is matched with any sanctioned entity or country. Sanctions Screening is being updated by SWIFT corporations with the latest and up-to-date Sanctions Lists (OFAC – UN – EU – UK… etc).

Tadhamon Bank has a policy covering relationships with Politically Exposed Persons (PEPs), their family and close associates. No relationship is to be established with PEPs unless there is an approval from the Top Management. Moreover, Enhanced Due Diligence is taken for every transaction.

In terms of Anti-bribery, Corruption and Anti-Fraud , Board of Directors have adopted dependent policies  to be implemented as part of  Tadhamon Bank's compliance program in addition to a written policy on conflict of interests and Banking Consumer Protection Principles.

 

Revision History

 

Date

Version

Author

Comments

Adoption Party

Jan 1st, 2011

V.1

AML Unit Director

AML/CFT Internal Policies and Procedures

Chairman of BoD

Dec 27th, 2011

V.2

AML Unit Director

AML/KYC Procedures

Chairman of BoD

Jun 30th, 2013

V.3

Compliance Manager

AML/KYC Guidelines

Chairman of BoD

Feb 5th, 2014

V.4

Compliance Manager

Compliance Manual according to Yemeni AML Law amendments

Chairman of BoD

Apr 16th, 2015

V.5

Compliance Manager

Customer Acceptance Policy

Board of Directors

Feb 15th, 2016

V.6

Compliance  Dept.

AML/ CFT Procedures Updates

Board of Directors

Feb 2nd, 2017

V.7

Compliance  Dept.

Compliance AML/CFT Policy Manual

Board of Directors

Jan 31st, 2018

V9

Compliance  Dept.

Adoption Compliance/AML CFT Policy & Procedures

Board of Directors

July 28th, 2018

V1

Compliance  Dept.

Adoption of the ANTI-BRIBERY & CORRUPTION Policy

Board of Directors

Dece 25th, 2018

V2

Compliance  Dept.

Editing the ANTI-BRIBERY,  CORRUPTION & Fraud Policy

Board of Directors

Sept 23rd, 2019

V1

Compliance  Dept.

Anti-Fraud Policy

Consumer Protection Program 

Board of Directors

 

 

 

 

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