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Anti-Financial Crime Policy Statement

Introduction

The Board of the CTB Plc recognise that financial crime is a threat to the Bank and to the financial services industry. The Bank is committed to the prevention of financial crime in all its forms – money laundering, terrorist financing, bribery and corruption, fraud and market abuse, tax evasion, human trafficking and slavery.

The Bank employs Board approved and risk-based internal policies, procedures, systems and controls to ensure that high standards of financial crime prevention and awareness are maintained by all staff.

The CTB Plc has established a Financial Crime Programme to ensure that all financial crime risks are identified and appropriately mitigated to meet our legal and regulatory obligations to prevent, deter, detect and investigate all forms of financial crime.

Anti-Money Laundering (AML)

As a financial institution authorized by the Prudential Regulation Authority (PRA) and regulated by the Financial Conduct Authority (FCA) and the PRA, the CTB Plc is subject to a robust legal and regulatory framework.

The principal obligations, on which the Bank’s AML systems and controls are based, are contained in the:

  • Proceeds of Crime Act 2002 (POCA) as amended;
  • Terrorism Act 2000 (as amended);
  • Counter-Terrorism Act 2008;
  • Bribery Act 2010;
  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017;
  • Fraud Act 2006;
  • Criminal Finances Act 2017;
  • Sanctions and AML Act 2018;
  • FCA Handbook of Rules and Guidance;and
  • the Joint Money Laundering Steering Group (JMLSG) guidance for the UK Financial sector on the prevention of money laundering and combating of terrorist financing.

AML Policy

The Bank’s AML policy is designed to ensure that all Bank employees comply with the requirements as set out in UK legislation, regulation, rules, and industry guidance for the financial services sector.

This policy includes the appointment of a Compliance Oversight and Money Laundering Reporting Officer (MLRO) – Senior Management Functions 16 and 17 respectively under the Senior Managers and Certification Regime (SMR), a risk based customer due diligence programme incorporating customer identification and verification and know your customer principles, enhanced due diligence for higher risk customers, including but not limited to, politically exposed persons (PEPs), ongoing monitoring and control requirements, and internal and external suspicious transaction reporting obligations.

Staff are required to report any knowledge or suspicion of financial crime to the MLRO. Where appropriate, these concerns are reported to the relevant law enforcement and/or regulatory authorities. The Bank is committed to supporting law enforcement agencies to detect and confiscate criminal proceeds.

Prohibited Customers / Relationships

The CTB Plc prohibits, among others, anonymous accounts or relationships, engagement with shell banks, and it does not facilitate payable through accounts or downstream correspondent clearing.

Sanctions

The CTB Plc complies with all applicable sanctions or restrictions on activity with respect to targeted individuals, countries, governments and entities as imposed by the UK Treasury, the EU, the UN and the Office of Foreign Assets Control (OFAC), among others.

Anti-Bribery and Corruption

The CTB Plc has a zero-tolerance policy in relation to bribery and corruption. The Bank recognises that these activities are often associated with organised crime, money laundering and terrorist financing.

Cognisant of the negative implications of bribery and corrupt practices, the Bank’s Financial Crime framework endorses its zero-tolerance approach and sets the standards to be applied to the conduct of the Bank’s business. These standards are reinforced in the Bank’s Code of Conduct, Employee Handbook and employment contracts.

The CTB Plc is committed to taking all steps to ensure that its zero-tolerance stance is communicated to all stakeholders, including contractors, suppliers, intermediaries, alliance companies and that its stance is embedded in relevant contracts.

Tax Policy

The Bank complies with all applicable tax legislation, domestic and international. It is committed to ensuring that it is not used a vehicle to facilitate tax evasion and that its employees and associated persons are fully informed regarding their obligations to prevent the facilitation of tax evasion.

Anti-Fraud

The CTB Plc does not tolerate fraud, impropriety or dishonesty and will investigate all instances where fraud is suspected either internally, with related parties or with external organisations. Penalties include dismissal and/or prosecution of any staff defrauding or attempting to defraud the Bank or its stakeholders and prosecution of any external parties.

Anti-Slavery and Human Trafficking

The Bank takes a zero-tolerance approach to any form of human slavery or trafficking or “Modern Slavery”. It is committed to acting transparently, ethically and with integrity in all of its business dealings and commercial relationships.

As a matter of best practice, the CTB Plc policies and associated controls are designed to ensure that “Modern Slavery” does not take place within its business activities or its suppliers.

Record Keeping and Retention

The Bank retains records associated with its obligations for a period of five years from the later of the date of the last transaction or the end of the customer relationship.

Training

All Bank staff attend regular and mandated training as part of the Bank’s financial crime programme. This includes, but is not limited to, money laundering and financing of terrorism concepts, principles with respect to customer due diligence, identification of suspicious transactions, channels for suspicious activity reporting (incl. whistleblowing), record keeping, and the Bank’s financial crime framework.

Governance

The Bank has a robust internal governance structure comprising a hierarchy of Board and Management committees. Regular review of the effectiveness of policies and procedures are performed in addition to internal and external audits to provide the Board and Senior Management with the necessary assurance regarding the operating effectiveness of the Bank’s systems and controls. Please refer to the Bank’s Governance section for details of the Board structure.