- Compliance with AML laws and regulations;
- Cooperation with and support of regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime;
- Serving customers and providing products and services consistent with IIB’s AML risk appetite and commitment to responsible finance and the highest ethical standards, and
- Adherence to the requirements of IIB’s Global AML Program.
IIB recognizes its obligation to cooperate with and support regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime, and to comply with AML laws and regulations to close off the financial channels that money launderers and terrorist organizations use for illicit purposes. We have also worked to ensure that we have proper policies, processes, and controls in place to deter money laundering and other financial crimes against the bank, our clients, and stakeholders.IIB’s Global AML Program
IIB has established a comprehensive Global AML Program to help protect both our clients and our franchise from the risks of money laundering, terrorist financing, and other financial crimes. The foundation of this global program is IIB ‘s Global Anti-Money Laundering Policy, which provides a globally consistent system of controls to identify and mitigate AML risks and comply with AML laws and regulations. These include:
- Bank Secrecy Act (BSA) Officer: The Global AML Compliance Officer has been designated by IIB’s Board of Directors as the BSA Officer responsible for overseeing IIB AML Program, including apprising the Board of Directors and senior management of AML compliance initiatives, any significant compliance deficiencies, and the reporting of suspicious activity;
- Governance and Enterprise-wide controls: This control framework governs the overall program, including Global AML policies, processes, training, and testing.
Built on and guided by this foundation are the key Program elements that are executed throughout three phases of the AML Control Lifecycle: Prevention, Detection, and Reporting:
- Prevention: Building and adhering to a robust Know Your Customer (KYC) program that focuses on the creation and administration of globally consistent standards/policies, customer risk scoring, onboarding, and maintenance of customer data housed in an enterprise-wide repository.
- Detection: Global transaction monitoring to identify unusual or suspicious transactions or patterns of activity, as well as robust Global AML Investigations to provide holistic reviews of both new and existing clients across various businesses and regions.
- Reporting: Active creation, tracking, and filing of Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs), and Currency Transaction Reports (CTRs), as required in many countries.
IIB’s risk management framework – including the AML Program – is based on three lines of defense:
- First Line of Defense (Business Management) – Each of IIB’s Businesses, including in-Business risk personnel, owns and manages the risks, including compliance risks, inherent in or arising from the Business, and is responsible for having controls in place to mitigate key risks, performing manager assessments of internal controls, and promoting a culture of compliance and control.
- Second Line of Defense (Independent Control Functions) – IIB’s independent control functions, including Compliance, Finance, Legal, and Risk, set standards according to which IIB and its businesses are expected to manage and oversee risks, including compliance with applicable laws, regulatory requirements, policies, procedures, and standards of ethical conduct. In addition, the independent control functions provide advice and training to IIB ‘s Businesses and establish tools, methodologies, processes, and oversight of controls used by the Businesses to foster a culture of compliance and control and to satisfy those standards. AML Advisory and Coverage AML Compliance Officers (AMLCOs), support their respective Business by providing regulatory compliance expertise and guidance in an advisory capacity to Business Management. They are responsible for coordinating, monitoring, and, where appropriate, overseeing day-to-day compliance with the Global AML Program.
- Third Line of Defense (Internal Audit) – IIB’s Internal Audit function independently reviews activities of the first two lines of defense based on a risk-based audit plan and methodology approved by the IIB group Board of Directors.
IIB is fully committed to remaining vigilant to prevent the use of our products and services by those who seek to abuse them. We continually seek to combat money laundering and terrorist financing through the prevention, detection, and reporting of unusual or suspicious behavior. We actively work to prevent terrorist organizations from accessing our financial services, readily assist regulators and law enforcement agencies in their efforts, and promptly respond to inquiries.
We also continually evaluate the strength of our existing policies, procedures, and technologies, and update them, as necessary, to address the changing environment. We also train our staff to assure that they are well-versed in the evolving techniques that criminals use to infiltrate the system and are well-equipped to combat money laundering and other financial crimes.
The fight against money laundering is a constant and evolving process. At IIB, we recognize that preventing money laundering and identifying possible terrorist financing activities involves constant diligence and the ability to keep pace with the sophisticated schemes employed by criminals. We acknowledge that we must constantly work to identify and understand the potential risks of money laundering and terrorist financing and implement appropriate processes to mitigate, and ultimately alleviate such risks.Due Diligence
IIB is a contributor and user of the Know Your Customer (“KYC”) information exchange platform SWIFT KYC Registry, designed to increase transparency and enhance financial institutions’ capacity to maintain business relationships with key correspondents by exchanging KYC information simply and centrally. Third-party banks and vendors conducting KYC due diligence, including the Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ), should first use this platform to collect information and documents. If additional information is required, please submit a request to IIB directly by emailing email@example.com. The Wolfsberg Group Financial Crimes Compliance Questionnaire (FCCQ) is a shorter version of the CBDDQ and contains a basic set of questions to address industry demand.Anti-Money Laundering
IIB Development Group has implemented an enterprise-wide Anti-Money Laundering (AML) compliance program, which covers all of its subsidiaries and affiliates and is reasonably designed to comply with applicable laws and regulations. Should you or your institution require general information about IIB Development Group’s AML compliance program, please see the following:IIB Development Group Anti-Money Laundering (AML) and Counter-Terrorist Financing Policy Statement
“Crime has a destructive and devastating effect on the communities in which we operate. Safeguarding the global financial system is critically important for the economic and national security of the jurisdictions in which we operate. Accordingly, it is the policy of IIB Development Group to take all reasonable and appropriate steps to prevent persons engaged in money laundering, fraud, or other financial crime, including the financing of terrorists or terrorist operations, (hereinafter collectively referred to as “money laundering”) from utilizing IIB Development Group products and services. Compliance with both the letter and the spirit of the anti-money laundering regulatory regimes in the countries and jurisdictions in which IIB Development Group operates is one way the IIB works to achieve this policy.”IIB Development Group AML Compliance Program
IIB Development Group has developed an Anti-Money Laundering Compliance Program to comply with applicable laws and regulations. Please click the following link to view and/or print a letter from IIB Development Group’s Global Financial Crimes Compliance Executive.IIB Development Group AML Questionnaire
IIB Development Group has also prepared an AML Questionnaire, based on Wolfsberg’s publication of the IIB’s Almanac AML Questionnaire, for use by any financial institution that requires more detailed information about IIB Development Group’s AML compliance program.Patriot Act Certification
- IIB Development Group has prepared a global certification for use by any financial institution that requires a Patriot Act Certification (PAC) for an IIB Development Group foreign entity. Please click the below link to view/print our Patriot Act Certification.
- IIB Development Group Economic Sanctions Compliance Program.
- IIB Development Group has developed an Economic Sanctions Program to comply with applicable laws and regulations. Please click the following link to view and/or print a letter from IIB Development Group’s Global Economic Sanctions Executive.