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Anti-Money Laundering Policy

Prevention of Laundering Proceeds of Crime and Financing of Terrorism

T. Garanti Bankası A.Ş., its branches, affiliates, subsidiaries (hereinafter referred to as Garanti BBVA) are committed to cooperating with law enforcement and regulatory agencies to fight against money laundering, terrorist financing, and other financial offences.

Money laundering can be referred to as activities to disguise or conceal the origin of funds generated through criminal activities.

Apparently financial institutions may be used at any point in money laundering process. Even unintentional involvement in any criminal activity may weaken the institution's public reputation.

The Financial Intelligence Unit in Turkey is Financial Crimes Investigation Board (Mali Suclari Arastirma Kurulu Baskanligi - MASAK).

Turkey is a member country of the Financial Action Task Force (FATF) and has enacted laws and regulations to combat money laundering, terrorist financing and other financial crimes.

The purpose of regulations is to prevent laundering proceeds of crime and financing of terrorism and to determine the principles to be applied.

An anti-money laundering program is implemented in order to ensure that Garanti BBVA complies with all applicable laws, regulations and rulings to combat money laundering, terrorist financing and other financial crimes in the countries in which it does business.

This program includes;

  • Written policies and procedures,
  • Assigning a compliance officer responsible for implementing anti-money laundering (AML ) policies and procedures,
  • An audit and review function to test the robustness of policies and procedures,
  • Monitoring and auditing customer activities and transactions as per AML legislations and regulations,
  • Training of employees on AML.

AML program is responsibility of all of the employees.

A summary of policies and procedures follows:

  • Know Your Customer (KYC): True and adequate identification of customers and beneficial owners, monitoring transactions, monitoring banking behaviors to determine the correspondence with their income, welfare, social life, type of business, etc.
  • Account Opening: Account opening requests should only be met if required evidence of identity and customer data is obtained. An account must bear the real name of the account holder. No numbered or coded or anonymous accounts are permitted. Black list controls are also performed for applicants.
  • Record Keeping: Records and evidence of identification and transactions must be kept for at least 8 years.
  • Suspicious Activity Reporting: All suspicious transactions and activities must be reported to related authorities.
  • Correspondence Banking: When establishing accounts for correspondent banks, enhanced due diligence must be carried out for identifying the institution and nature of business. Sufficient information should be obtained with regards to institutions' AML and KYC policies and procedures. Garanti BBVA does not establish any relationship with shell banks.
  • Cooperation with Authorities: Where applicable, cooperation with law enforcement and regulatory authorities is essential. This may include, consistent with laws, freezing of accounts, providing information, and so on.