COMPLIANCE STATEMENT

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 real source of their money.

Recognizing the detrimental consequences of ML/TF on the financial system, Cedrus Invest Bank sal is committed to apply the highest standards of integrity, transparency and accountability. It adopts an effective Compliance Program for fighting all the financial crimes mainly ML/TF, tax evasion, bribery and corruption, proliferation of weapons of mass destruction and its financing… that complies with national regulatory requirements and reflects the international standards.

Compliance policies:

The Bank’s Compliance Program is focused on the below mentioned pillars:

Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT)

Complying with national regulations and international legislation on money laundering and financing terrorism, Cedrus Invest Bank has adopted 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 and establishing a compliance program

·         Issuing a “Know Your Client” policy that includes:

o    Client Acceptance Policy: a guide that specifies the types of accounts the bank accepts to deal with and the types that are not acceptable

o    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.

o    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

·         Compliance Audits and 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 is committed to applying appropriate controls to keep money launderers and fraudsters out of local and international financial system. For this purpose, the bank establishes an automated database that contains all the names circulated by the local authorities mainly Special Investigation Commission and Internal Security Force (ISF) in addition to the international lists promulgated by the United Nations (UN), the United States (US), the European Union (EU) and HMRC. 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

Lebanon has recognized bribery and corruption in Law 44 dated November 24, 2015 (amending Law No 318 of April 20, 2001, on Fighting Money Laundering) which considers corruption as predicate offences to money laundering.

Lebanon has agreed to adhere through accession on 22 April, 2009 with the UN convention against corruption. This convention has been developed to promote and strengthen measures to prevent and combat corruption more efficiently and effectively.

Accordingly, Cedrus Invest bank SAL, adopted an organized policy where it applies to all stakeholders including but not limited to:

-          All the Bank’s employees including senior managers and members of the Board of Directors

-          The Bank outsourcing companies and their business partners and employees

-           Any external public or private party with whom the Bank may deal or serving on behalf of the Bank including suppliers, consultants, attorneys, and external auditors.

 Any agreement with an external party must be concluded in accordance with the spirit of this Policy

 

Combatting Tax evasion

The Bank is committed to applying local laws and international standards by abiding to the most known regulations for combatting tax evasion: FATCA and CRS. In terms of FATCA, Cedrus Invest Bank is a Participating Foreign Financial Institution (PFFI). In terms of CRS, the bank is operating in a participating jurisdiction and applies all related requirements. 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.

 

Data Privacy Compliance

Cedrus invest Banks sal is guided by the local and international regulations and best practices in the area of privacy and is dedicated to maintaining the confidentiality and security of all personal data entrusted to us. Accordingly, it adopted a Data privacy policy that provides:

·         Transparency regarding how we handle personal information and affirms our commitment to upholding the highest standards of privacy and data protection.

·         Comply with data protection regulations & laws.

·         Only reveal customer data to those authorized, customer data must be protected from any unauthorized access. 

Tipping Off and whistleblowing

In line of the Bank’s commitment and to enhance a good governance and transparency, a policy was developed and it was intended to:

·         Develop a culture of openness, accountability and integrity within the Bank.

·         Deter wrongdoing and promote standards of good banking practices.

·         Enable Management to be informed, at an early stage, about any misconduct.

·         Encourage employees and persons who work with or for the Bank to report suspected wrongdoing and reassure them that their disclosers shall be taken seriously, investigated as appropriate and managed in a timely and professional manner.

·         Assure whistleblowers that their confidentiality shall be respected and they are able to raise genuine concerns without fear of retaliations, even if they turn out to be mistaken.