Bank’s sanctions policy and AML/CFT measures 

Statement

Bank’s Sanctions Policy

ID Bank CJSC (hereinafter referred to as the Bank), is fully committed to it’s mission and carries out it’s business following and adhering to the highest ethical and regulatory standards and ensures that neither the Bank, nor the Bank's services are used to facilitate, directly or indirectly, violations of applicable international sanctions and/or restrictions.

As a responsible participant of international financial system the Bank mostly values and protects clients’ interests, safety and their business continuity. The Bank complies globally with sanctions imposed by the United Nations Security Council, the European Union, the United Kingdom, the United States and other international sanctions and/or restrictions.

Sanctions Policy prohibits any activity by the Bank’s clients that would breach applicable sanctions, as a result of such actions, transfers/transactions will be rejected and the Bank may refuse to serve these clients.

                                                                                                                   AML/TF Policy

The Policy is based on the Law of the Republic of Armenia on “Combating Money Laundering and Terrorism Financing”, Regulation of the CBA on “Minimum Requirements to Reporting Entities in the Field of Preventing Money Laundering and Terrorism Financing, other laws and legal acts, the main objectives of which are:

• Prevention the use of the Bank as a tool for money laundering and terrorism financing;
• Mitigation of possible risks associated with money laundering and terrorism financing;
  
• Protection of the business reputation of the Bank and its clients;
  

The Policy includes:

• Implementation of the “Know Your Customer” principle (including the identification of beneficiaries and authorized persons),
• Customer due diligence,
• Enhanced customer due diligence,
• Daily monitoring,
• Updating customer data,
• Implementation of a risk-based approach,
• Identification of suspicious transactions,
• Submission of mandatory reports on suspicious transactions/business relationships to the Central Bank of the Republic of Armenia,
• Training of employees in AML/CFT principles

Additionally,

• The Bank does not open or maintain anonymous accounts or accounts in fictitious names;
• The Bank does not open accounts with only numeric, alphabetic, or other conventional symbolic expression;
• The Bank does not service bearer securities;
• The Bank rejects a transaction if the customer fails to provide the documents required for establishment of business relationship or execution of the transaction;

It is prohibited to conduct transactions or establish business relationships involving:

• Nuclear energy
• “Red-Light” business
• Marijuana
• Virtual currencies.