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.