The Bank’s AML/CTF activity is governed by the Ukrainian legislation in force, in particular by the Constitution and laws of Ukraine, including the Law of Ukraine On Banks and Banking, the Law of Ukraine On Prevention of and Counteraction to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and the Financing of Proliferation of Weapons of Mass Destruction (hereinafter – the Law), Resolutions of the Verkhovna Rada of Ukraine (the Parliament), Decrees and Orders of the President of Ukraine, Decrees, Resolutions and Orders of the Cabinet of Ministers of Ukraine (the Government), regulations of the National Bank of Ukraine (the Central Bank and the regulator), and in particular Regulation on Financial Monitoring by Banks approved by Resolution of the Board of the National Bank of Ukraine No.65 dated 19.05.2020, regulations of the Ministry of Finance of Ukraine and of the State Financial Monitoring Service of Ukraine, the Statute (Articles of Association) of the JSC Ukreximbank, regulations of the Bank as well as by the recommendations of the Financial Action Task Force on Money Laundering (FATF) and the Basel Committee on Banking Supervision.

In accordance with the FATF recommendations and in fulfillment of Ukraine’s legislative requirements, JSC Ukreximbank updates its Rules and Procedures for Prevention of Legalization of Proceeds from Crime and Know Your Customer Rules and Procedures (AML and KYC rules and procedures) on regular basis in order to ensure their strict compliance with the Ukrainian Law and best international practice.

JSC Ukreximbank has developed and implemented its internal documents on financial monitoring:

• the Rules of Financial Monitoring,
• the Identification, Verification and Know Your Customer Program,
• the Compliance Risk Management Program,
• specific activity-related financial monitoring programs (in respect of settlement, cash management, deposit, foreign exchange, credit, securities transactions, money transfer services, etc.) applied in the process of customer services and with the use of electronic means of payment of international payment systems and the in-house payment system,
• the Program for Training and Professional Development of Employees in Prevention of Legalization of Proceeds from Crime/Financing of Terrorism.

The Bank shall not open and not maintain anonymous (numbered) accounts; not establish correspondent relations with shell banks, and non-resident banks and other financial institutions maintaining correspondent relations with shell banks; not enter into contractual relations (does not carry out foreign exchange transactions, transactions with banking metals, cash transactions) for legal entities or individuals, in case of suspicion that the legal entity or individual is not acting on its own behalf, or if they are included in the list of persons related to terrorism activity, or are sanctioned persons or entities, and in other cases stipulated by the Law.

The Bank’s AML and KYC rules and procedures apply to all branches and subsidiaries of the Bank. The compliance of such policy and procedures with the effective law is audited and reviewed regularly.