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 Program for appropriate personnel and conduct an independent audit of the Program. 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). The bank has a policy to ensure that no transactions are conducted 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.
You can download the compliance report (click here)
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 |