AML

Counteraction to legalization (laundering) of proceeds derived from offence.

 

Understanding the threats for the world community from terrorist and associated with them organizations, the importance of the civilized world politics of counteraction to legalization (laundering) of proceeds derived from offence,  and keeping within the Law of the Republic of Kazakhstan "On Counteraction to Legalization (laundering) of Proceeds Derived from Offence, and Financing of Terrorism", JSC "Development Bank of Kazakhstan" (hereinafter – Bank) conducts activities aimed at:

• expulsion of possible involvement of the Bank to the process of legalization (laundering) of proceeds derived from offence, and financing of terrorism;
• safety and keeping business reputation of Bank and its clients;
• effective revelation and suppression of money transactions and/or other operations with property aimed at laundering of proceeds derived from offence;
• providing reliability and safety of money transactions in accordance with legal norms and rules;
• provision of full and timely submitting of the information set by the Law on CLP/FT to the Authorized Agency (financial monitoring body);
• use of effective risk estimation procedures relating to laundering of proceeds and terrorism financing;

In order to keep within the Law of the Republic of Kazakhstan "On Counteraction to Legalization (laundering) of Proceeds Derived from Offence, and Financing of Terrorism" Internal Control Regulations are adopted and observed. Regulations were developed in accordance with legislation in effect of the authorized agency, considering the recommendations contained in the FATF documents, practical experience in this field of the international organizations, Western financial institutions, leading Russian and Kazakhstani lending agencies, Bank's exclusive legal status, and contain:

• appropriate inspections, procedure of risk estimation for LP/FT, suspect operations' determination criteria;
• appropriate checking the clients, correspondent banks, and list of money transactions and/or other operations with property, subject to financial monitoring;
• programs:
• program  of checking the clients' information and transactions;
• program of documentary fixing, and information storage about Bank clients and their transactions possibly relating to LP/FT; 
• program of documents' and information storage;
• program of organization of the Bank activities on CLP/FT;                
• program of training and instruction of the Bank staff;               
• rules of rejection and stoppage of money transactions and/or other property operations;
• regulations of submitting confidential information to the Authorized Agency.

The person responsible for keeping within the Regulations and its programs' implementation by all Bank divisions and staff was appointed. The division responsible for fixing, storage and submitting information about operations subject to obligatory notification to the Authorized Agency was determined. The responsibility was determined, and procedure of interaction between departments, Compliance-Controller and Accountable Bank Official oriented on counteraction to legalization (laundering) of proceeds derived from offence, and financing of terrorism, was clearly regulated.

Bank with reasonable caution approaches the choice and creation of clients' database, attentively watches the clients, their property structure, interests and fields of activities, and strives to establish relationships with the clients based on transparency and understanding of their business and operations in service.  This helps Bank to timely reveal the clients' transactions subject to financial monitoring, identify and know its clients, identify beneficiaries, estimate risks of laundering of proceeds and financing of terrorism, documentary fix and store information about clients, their transactions, and measures of counteraction to legalization (laundering) of proceeds derived from offence, and financing of terrorism. Bank makes reasonable and available arrangements on revelation of foreign public functionaries among legal entities in service. The possible establishment of business relations with clients, correspondent banks are subject to be agreed with Compliance-Controller of the Bank regulated by the rules in the Internal Control programs.               

The basic principle of the Internal Control system functioning oriented on CLP/FT is involvement of the whole Bank staff independently of position in exposure of transactions subject to financial monitoring in the clients' activities in service, following the Regulations, proving high responsibility and vigilance concerning any suspect operations and dealings, special attention is focused on the clients' high-risk transactions.

Human Resource Management Department, Compliance Service organize the systematic training for Bank staff in order to certify personnel engaged in CLP/FT procedures, familiarize them with changes of the legislation in effect, improvement of internal control, elaboration of suspect operations' types considering international experience. 

Compliance Service exercises permanent control of CLP/FT legislation, Regulations and internal control procedures on CLP/FT observance by all the structural divisions and personnel of the Bank. 

JSC "Development Bank of Kazakhstan" does not establish or keep in touch with the banks, without standing authorities in the countries where they are registered, and have no  accounts in the banks registered in the countries nonparticipating in the international cooperation in the field of  counteraction to legalization (laundering) of proceeds derived from offence, and financing of terrorism.

We express our confidence that you as the potential clients, investors and partners of the Bank will be respectful to the CLP/FT procedures, and very carefully prepare and fill in all the documents offered to you in the context of realization of the principle "Know Your Client".  With that, in this part you can find all the required data about JSC "Development Bank of Kazakhstan" that can help you to get a clear idea of the Bank, its activities, property structure, and other necessary information to identify the Development Bank.

Questionnaire 1

Questionnaire 2