Compliance Statement

Introduction
Private banking has always been an attractive business because it offers potentially high returns through the provision of value added services. While these services are attractive to legitimate customers with substantial assets and relatively complex financial affairs, they often have characteristics that are attractive to criminals with significant funds to launder as well. .

Cedrus Invest Bank is committed to the highest standards of Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) compliance. Management and employees are committed to adhering to these standards to prevent the misuse of its products and services for such adverse purposes. Cedrus Invest Bank maintains an effective AML/CFT program appropriate to the Bank’s business and size and which complies with the local regulatory requirements and reflects the international standards.This program is reviewed annually to make sure it remains aligned with the board of director’s guidance and strategic view.

Anti-money Laundering and Counter-financing of Terrorism (AML/CFT):

The Bank has put in place strong policies, procedures and controls to comply with the requirements of applicable AML/CFT laws and regulations, including:

  • Creating a Compliance Department that is independent from the business, executive and operational activities of the Bank, with a direct reporting line to the AML/CFT Board Committee and the Chairman of the Board/General Manager
  • Designating an AML Reporting Officer
  • Setting up a compliance program that is approved by the Board of Directors
    • Setting up a “Know Your Client” policy that includes:
    • Client Acceptance Guidance
    • Customer Due Diligence program: mainly requirements for proper client identification, name screening, identification of ultimate beneficial owner, purpose of the account, and projected account activity
    • Risk-based approach to effectively identify, assess, manage and mitigate areas of client risk and apply the appropriate due diligence level
  • Establishing an effective ongoing monitoring of transactions with respect to any unusual, irregular or unexpected activity
  • Establishing a process for internal and external reporting of unusual transactions
  • Performing continuous AML/CFT training to all employees
  • Reviewing annually the Compliance Program in addition to the periodic independent testing by the internal audit, external audit and the regulators

 

Sanctions:

The Bank follows and applies the sanction programs established mainly by the United Nations, the USA and the EU. The Bank screens all names related to a transaction against SDN lists. The Bank confirms that it does not conduct business with, nor derives revenue from, nor has assets/affiliations in sanctioned countries, mainly Syria, Sudan, Cuba, North Korea, Iran and Myanmar.

 

Anti-bribery and Corruption:

Lebanon ratified the United Nations Convention against Corruption (UNCAC). The Bank follows this convention and has strict prohibitions against bribery and corruption, whether dealing with clients or with suppliers.

 

Tax Compliance:

In terms of FATCA, the Bank is a Participating Foreign Financial Institution (PFFI) under GIIN NIVZ7H.00000.LE.422. In terms of CRS, the Bank is operating in a participating jurisdiction. The Bank is committed to be fully FATCA and CRS compliant and this commitment is reflected by its internal FATCA and CRS policies and procedures and by a technical infrastructure that detects reportable accounts.