Compliance and Financial Monitoring System
According to Laws of Ukraine "On Prevention from and Counteraction to Legalization of Income, obtained through.
Criminal Activity (Money Laundering)", "On Banks and Banking Activity", Regulations of National Bank of Ukraine, the Internal Financial Monitoring System has been established with PSC Prominvestbank.
The work of Internal Financial Monitoring System of the Bank is provided by special division - Сompliance Department, which is headed by the responsible worker, the member of the Bank Board.
The internal regulatory documents of the Bank which govern the questions in the field of prevention of legalization of incomes received from criminal activity are the background of Internal System. The mentioned documents are approved by the Bank Board in compliance with the requirements of the current Ukrainian legislation.
Internal Financial Monitoring Rules
Rules governs the questions on organisational structure of internal financial monitoring system of the Bank; characteristic and procedures of registration of financial transactions subject to financial monitoring; procedures and terms of reporting to State Committee for Financial Monitoring of Ukraine about financial transactions subject to financial monitoring; procedures of retaining, circulation and ensuring of confidentiality of information concerning financial monitoring.
Program of Identification and Monitoring of the Bank Customers
Program is based on "Know Your Customer" policy. The Program include the procedure of identification of customers while establishment of relations as well as in the process of servicing. While establishing the relations the Bank governs by the prudence concept. On the regular basis the Bank provides the analysis of the customer's transactions in order to check their correspondence with the Bank's information about the client, his business, type of activity and financial situation.
According to the requirements of the current Ukrainian legislation the Bank should obligatory identify:
- establishing business relationships with clients;
- rising of suspicion that transaction can be connected with money laundering or terrorism financing;
- customers that conduct transactions that are subject to financial monitoring;
- customers that conduct cash transactions for the amount exceeding UAH 150,000 or its equivalent in foreign currency without opening account;
- persons acting on behalf of the above said customers.
Financial Monitoring Programs
Financial monitoring programs are developed in all spheres of bank's activity, including cash operations; transactions with cash funds; transactions provided via plastic cards of international payment systems and etc.
Programs determine the procedure of transactions disclosure, which are subject to financial monitoring; measures usage procedure on examination the substance and the goal of financial transaction of the client; control conducting procedure on examination transactions which are subject to financial monitoring and notification procedure of responsible worker of the Bank about transactions which are subject to financial monitoring.
Program of Training and Improving Skills Level of the Bank's employees
The training program for improving professional skills of the Bank's employees in financial monitoring is developed and involves the process of education of all employees of the Bank while acceptance for employment as well as while working process (within their competence) including management personnel:
The Program includes the following:
- studying Ukrainian legislation, recommendations of Basel Committee on Banking Supervision and international documents on counteraction to money laundering of income obtained through criminal activity and terrorism financing;
- studying internal banking documents which governs the questions on counteraction to money laundering of income obtained through criminal activity and terrorism financing;
- conduction the practical trainings;
- personnel's knowledge assessment.
Program of management and risk assessment on money laundering
Program is developed to control, manage and minimize risks of using Bank's services for money laundering/terrorism financing. Program includes:
- procedure and methodology on clients' risks assessment;
- risks' analysis on using Bank's services for money laundering/terrorism financing;
- procedure of usage of appropriate measures on minimizing risks for money laundering/terrorism financing;
- procedure of practical trainings organization with Banks' personnel on questions of risk assessment Program realization.
- Internal audit department of the Bank annually provides examinations of Banks' activity on financial monitoring; results of such examinations are discussed on Supervisory Board meetings. PJS Prominvestbank conducts its activity according to requirements of current legislation of Ukraine, standards of Basel Committee on Banking Supervision, other international rules and standards in field of money laundering and terrorism financing.
- neither opens, nor maintains anonymous (numbered) accounts;
- does not enter into contractual relations with corporate and individual customers in case there is doubt that the entity/person acts on its/his behalf;
- not establish correspondent relations with financial institutions non-residents that don't take proper measures to prevent money laundering, and with 'shell banks' (without physical presence in the place of registration).