Introduction
The Private Banking business line offers a variety of tailored financial services targeting affluent and High Net-Worth Individuals (HNWI). These services, although genuinely offered, may be attractive to money launderers and criminals who are constantly seeking new means to access the financial system and hide the true nature of their money.
In that respect, Cedrus Invest Bank is committed to the highest standards of Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT). Management and employees are bound to adhere to these standards to prevent the misuse of the bank’s products and services for illegal purposes. CIB maintains an effective AML/CFT program, one that complies with local regulatory requirements and reflects international standards. This program is revised and amended—if need be—on an annual basis to ensure its alignment with the Board of Director’s strategic vision.
Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT)
Complying with local regulations and international legislation on money laundering and financing of terrorism, Cedrus Invest Bank has put in place effective policies, procedures, and management controls that encompass the following:
- structuring a self-governing Compliance Department—independent from the bank’s executive and operational activities—with a direct reporting line to the AML/CFT Board Committee and the Chairman - General Manager
- designating an AML Reporting Officer
- setting up a compliance program that is approved by the Board of Directors
- issuing a “Know Your Client” policy that includes:
- Client Acceptance Policy: a guide that specifies the types of accounts the bank accepts to deal with and the types that are not acceptable
- Customer Due Diligence: a proactive program that sets the requirements for proper client identification, name screening, and identification of ultimate beneficial owners, the purpose of an account, and the projected activity of an account. This program allows the bank to detect any unusual activity.
- Risk-based approach: a process by which clients are classified according to the ML/FT risks the bank is exposed to; such classification allows the Bank to effectively identify, assess, manage, and mitigate areas of client risk before applying the appropriate levels of due diligence
- monitoring transactions constantly to detect 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
- testing the Compliance Program periodically and independently by the internal audit, external audit, and regulators
Sanctions
Cedrus Invest Bank follows and applies the sanctions programs established mainly by the United Nations, the United States, and the European Union. The bank screens all names to make certain that no transactions transpire with stated parties on the Specially Designated Nationals (SDN) list.
CIB neither conducts business with, nor derives revenue from, nor has assets in or affiliations to sanctioned countries, mainly Syria, North Korea, Iran, and Myanmar.
Anti-bribery and Corruption
In 2009, Lebanon ratified the United Nations Convention against Corruption (UNCAC). Cedrus Invest Bank follows this convention and has strict prohibitions against bribery and corruption when dealing with both clients and suppliers.
Tax Compliance
In terms of FATCA, Cedrus Invest 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. CIB 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.
Relationships with Correspondent Banks
The stringent customer due diligence measures that Cedrus Invest Bank performs on each cross border transaction ensure that such transactions are justified by the profile of the customer or by reliable supporting documents. In addition to this, CIB is fully committed to respecting all the international standards that govern these relationships—mainly Wolfsberg Transparency Principles—and to responding to all the enquiries or demands of the correspondent banks in a prompt, clear, and accurate manner.