AML/KYC Policy

1. OBJECTIVE AND SCOPE OF THE POLICY

 The purpose of Policy on The Prevention of Laundering Proceeds of Crime and Financing of Terrorism is;

This policy sets the duties of Law No. 5549 on Prevention of Laundering Proceeds of Crime and relevant legislation and international regulations.

This policy is composed of the following measures;

    • Know your customer principle
    • Monitoring and control activities
    • Suspicious transaction reporting
    • Training
    • Internal audit
  1. KNOW YOUR CUSTOMER PRINCIPLE

2.1. IDENTITY VERIFICATION

The Bank accordingly adopts a policy in line with the international standards and the applicable legislation and practices on know your customer principle.

Under the “Know Your Customer” principle, necessary measures shall be adopted subject to the applicable legislation, and the Bank Policy and Procedures in order to:

Customer identification shall be completed before the business relationship is established or the transaction is conducted. When establishing permanent business relationship, information on the purpose and intended nature of the business relationship shall be received. Customer identification process shall be conducted for below given cases;

In cases where customer requesting the transaction declares that customer is acting for the benefit of someone else, the identity of the person requesting the transaction and the identity of the person for the benefit of whom the transaction is conducted shall be identified.

In cases where there is a suspicion that the person is acting in his/her own name but for the benefit of someone else although he/she has declared that he/she is not acting for the benefit of someone else, measures for the identification of the beneficial owner shall be applied.

The Bank shall retain documents, books and records, identification documents and records kept in all forms regarding their transactions and obligations for ten years starting from the last transaction date respectively and submit when requested.

2.2.INDIVIDUALS, ENTITIES AND COUNTRIES WITH WHICH BUSINESS RELATIONSHIP SHALL NOT

BE ESTABLISHED

According to “Know Your Customer Principle” Sardis Global do not accept the following categories of customers;

2.3.INDIVIDUALS AND ENTITIES FOR WHICH ENHANCED MEASURES SHOULD BE TAKEN AT ESTABLISHMENT OF BUSINESS RELATIONSHIP

On the basis of a risk based approach the following categories of customers identified as high-risk and may require enhance due diligence.

Before establishing new correspondent relationships, approval shall be received from a senior manager. It has to be ensured that financial institutions have combat system against laundering and terrorist financing is appropriate and efficient via sending relevant questionnaires and information should be obtained from public resources on whether the financial institutions have gone through an inquiry related to laundering or terrorist financing and have been imposed a penalty; their field of business; reputation; and adequacy of audits performed in that bank.

Required controls are applied to determine whether the customer is a politically exposed person and business relationship is made according to enhanced approval mechanism.

  1. MONITORING AND CONTROL ACTIVITIES

The purpose of monitoring and control activities is to protect the Bank against risks and to monitor and control on a permanent basis whether the Bank's operations are carried out in accordance with the Law and other arrangements issued as per the Law as well as the Bank's policies and procedures. Monitoring and control activities are executed by the Compliance Department under responsibility of Compliance Officer.

Monitoring and control activities include the following topics;

  1. SUSPICIOUS TRANSACTION REPORTING

Where there is information or matters that would arise suspicions, indicating that a transaction which was or is to be executed by or through the Bank upon an application is associated or related with laundering of criminal proceeds or terrorism financing, necessary investigation to the extent permitted by the applicable means shall be carried out and any transaction concluded to be suspicious shall be reported to The Financial Crimes Investigation Board (FCIB) within such term and subject to such conditions defined in the applicable legislation.

Suspicious transactions shall be reported to FCIB regardless of the amounts.

Natural and legal persons, their compliance officers, legal representatives of the obliged parties, their managers and personnel complying with the obligation of reporting suspicious transaction, shall not be held responsible judicially and criminally in any way.

While fulfilling their tasks employees shall be alerted and act in accordance with legal obligations about identifying and reporting suspicious transactions against the following cases;

  1. TRAINING

The purpose of training is ensuring compliance with obligations imposed by Law and the regulation and communiques issued in accordance with Law, creating an institution culture by increasing the sense of responsibility of staff on policy and procedures of institution and on risk-based approach and updating of staff information.

Education programs are prepared by Compliance Unit and classroom trainings can be given by the Compliance Unit’s staff. Training activities are organized by the coordination and cooperation of Compliance Unit and Education Unit.

It is essential to train the new employees about the subject during the basic banking training period. The bank’s existing personnel shall regularly be trained with classroom and e-learning methods.

The trainings to be given to staff by obliged parties shall at least cover the following subjects;

Necessary information and statistical data in relation to the training courses in progress regularly keeping subject to the applicable legislation, and shall report through Compliance Officer to FCIB at such times and in such manner to be defined.

  1. INTERNAL AUDIT

The internal audit management is responsible to audit periodically on a risk sensitive basis whether the activities of the Bank related to anti-money laundering law, regulations and communiques thereunder are conducted in compliance with the aforementioned legislation and policies and procedures of the Bank.

Necessary information and statistical data in relation to the internal audit activities in progress regularly keeping subject to the applicable legislation, and shall report through Compliance Officer to FCIB at such times and in such manner to be defined.

  1. COMPLIANCE UNIT AND COMPLIANCE OFFICER

Compliance Unit has been established and Group Head of Internal Systems has been assigned as Compliance Officer for ensuring compliance with obligations established with Law and regulations and communiques issued.

Duties, powers and responsibilities of compliance officer are;

  1. EFFECTIVENESS

Compliance Officer is responsible to the Board of Directors for implementing this policy.

This Policy shall be effective upon its approval by the Board of Directors.