Financial Crime Policy Statement

As a UK regulated financial institution operating in a number of jurisdictions across the globe, BACB is committed to combatting financial crime, and understands the importance of developing and maintaining a robust financial crime control framework.

BACB has zero tolerance for being a means to facilitate any form of illegal activity through the Bank, including financial crime. The Bank also has zero appetite for intentional breaches of financial crime laws and regulations, including breaching applicable Anti-Money Laundering (AML) / Counter Terrorist Financing (CTF), Tax Evasion, Sanctions and Anti-bribery and Corruption laws and regulations.

The financial crime control framework has been designed considering 6 guiding principles:

Senior Management Commitment;

Risk Assessment;

Internal Controls/ Procedures;

Due Diligence;

Communication and Training; and

Testing and Monitoring,

each of which are embedded by way of a suite of Financial Crime policies.

Aligned to the Bank’s culture of compliance with Financial Crime policies, BACB operates a ‘three lines of defence’ model such that roles and responsibilities are defined across the Bank and are applicable to all Bank personnel. The Bank’s Financial Crime policies establish minimum standards of conduct that are expected by all Bank personnel especially when dealing with the Bank’s clients and non-client relationships and when executing transactions or payments.

The Bank’s Financial Crime Function has established the Bank’s Financial Crime Policies and Statements which have been approved and endorsed by the Senior management of the Bank. The statements are detailed below:

Anti-Money Laundering and Counter-Terrorist Financing Policy Statement

Money laundering continues to pose a threat to the integrity of the international financial system, and BACB is committed to mitigating money laundering and terrorist financing risk by maintaining AML/CTF systems and controls which form part of the Bank’s overarching financial crime control framework.

The Bank’s AML/CTF framework has been developed in accordance with applicable UK laws, regulations, and industry guidance. The AML/CTF framework includes but is not limited to:

• The appointment of a Money Laundering Reporting Officer;
• Maintaining policies and procedures, outlining the Bank’s AML/CTF systems and controls;
• Mandating an annual AML/CTF risk assessment of the Bank;
• Conducting risk-based customer due diligence, including enhanced due diligence for customers presenting a higher risk of money laundering or terrorist financing (e.g. correspondent banking relationships);
• Establishing processes and systems designed to monitor customer transactional activity;
• Investigating potentially suspicious activity and reporting to the relevant UK regulatory authorities; and
• Conducting independent testing and providing regular AML/CTF training to the Bank’s employees and contractors.
• The prohibition of certain customer types and industries as follows:
  • Shell Banks
  • Shell Companies
  • Money Service Business
  • Non-bank payment service providers
  • Dealers and traders in precious metals and stones
  • Gambling industry
  • Adult entertainment
  • Virtual currency
  • Illegal drugs

Sanctions Policy Statement

Sanctions are restrictive measures imposed by bodies such as the United Nations (UN), the European Union (EU), or individual countries such as the UK (OFSI) and USA (OFAC). Sanctions can be used to target the activity of countries, governments, entities, individuals, and specific industries.

The Bank’s Sanctions Compliance Policy outlines the minimum requirements to ensure compliance with applicable sanctions regimes, laws and/or regulations and establishes a Bank-wide sanctions compliance programme that mitigates the risk of breaching such sanctions Laws and/or regulations. The purpose of this Policy is not only to comply with relevant legal and regulatory requirements (including the spirit of such requirements), but also to mitigate and reduce the potential risk of the Bank’s products, services, and delivery channels being used to circumvent sanctions.

The Sanctions Compliance Policy sets out the minimum standards which the Bank adheres to including:

• Prohibiting dealing with parties contained on certain sanctions lists;
• Prohibiting dealing with parties owned or controlled by parties on certain sanctions lists;
• Prohibiting dealing with entities, transactions involving certain jurisdictions with the highest degree of sanctions imposed, such as but not limited to:
  • Belarus;
  • Iran;
  • North Korea;
  • Russia;
  • Syria;
  • Venezuela; and
• Prohibitions or Restrictions on dealing with certain sectors such as:
  • Arms/Defence industry;
  • Nuclear proliferation;
  • Goods identified as dual use without appropriate licencing;
  • Restricting activity with jurisdictions with less complex sanctions regimes imposed.

Anti-Bribery and Corruption Policy Statement

BACB takes a zero-tolerance approach to acts of bribery and corruption and has a dedicated Anti-Bribery and Corruption (AB&C) Policy in place. The Bank’s AB&C Policy has been designed in accordance with the UK Bribery Act 2010 (as amended) and other applicable UK industry guidance.

In addition to detailing activity that is not permitted (e.g. giving or receiving bribes etc.), BACB’s AB&C Policy outlines the minimum requirements for mitigating bribery and corruption risk across the Bank, which includes but is not limited to:

• Prohibiting associated persons of the Bank in making facilitation payments;
• Prohibiting paying for services for clients or receiving services paid for by clients; and
• Restricting certain activity, that could present increased bribery risks.

The Bank’s AB&C Policy also details the Bank’s approach towards the provision or receipt of gifts and entertainment. All staff are required to report such gifts and entertainment over certain thresholds to the dedicated Financial Crime Risk function for oversight and monitoring.

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