Anti-Money Laundering

Anti-Money Laundering (AML) and Policy of Anti-money laundering and Combating the financing Financing of Terrorism (CFT)
In Tourism Bank


Introduction
Money laundering and financial support of terrorism is a big threat for world economy. Islamic Republic of Iran in addition to providing necessary infrastructure for preventing of money laundering and confronting with it, is applying a special supervision on good performance of rules and regulations of Anti-money laundering in Iranian banks. These rules together with other regulations and guidance, have determined some commitments and assignments in regard with Anti-money laundering and combating financing of terrorism for Tourism Bank.
Policy of Tourism Bank is preventing any use of bank services for the purpose of money laundering and financial assistance to terrorism and or criminal activities.

Anti-money laundering office
By virtue of Islamic Republic of Iran Anti-money laundering law adopted in 2007 and its executive regulations, Tourism Bank has formed the Anti-money laundering office with full responsibility and duties under direct supervision of Managing Director of the Bank.
Anti-money laundering office of Tourism Bank is committed to observe following points:
• Identification of matching risk regarding Anti-money laundering through received internal and external information and reports.
• Identification of vulnerable places in sections related to Anti-money laundering
• Preparation and submission of drafts of circulars, instructions and necessary regulations in the line of execution of Anti-money laundering law for approval of superior officer,
• Sending suspicious operations reports to financial information center
• Sending the reports of funds settlement over limit to financial information center
• Sending power of attorney of customers to financial information center
• Sending monthly information of beneficiaries of basic services to financial information center
• In person and online inspections in order to assurance of observance of criteria and requirements of Anti-money laundering
• Reply to inquiries of financial information center and judicial authorities regarding identification of real and legal entities and or linked transactions
• Other assignments delegated from concerned entities

Identification and verification of customers’ identity
• Tourism bank has approved a written instruction for its customer’s identification. Before offering any services to customers, we match their identity information with provided documents and simultaneously we ask online about the originality of persons’ identity information from concerned authorities.

Mandatory information for providing services to customers
Tourism bank at the time of providing all credit and banking services( including non-basic and basic services) to the customers( including transient and permanent) including any kind of receiving and payment, money transfer, issuance and payment of cheque, facilities, issuing of cards, issue of warranty, foreign exchange, acceptance of warranty and commitment of sponsors in any form such as permission note signature, drafts and letters of credit, identification of customers and obtaining information such as name and family name, ID code, residence and work address, postal code, father’s name and birth year, perform and record the information in its information system.
At the time of providing any basic services to permanent customers, Tourism bank proceeds for full identification of the customer and also according to case obtains complementary information as below:
Real Persons:
• Reliable introduction letter with the signature of at least one of the known customers or persons trusted by the bank or introduction letter from one of credit institutions licensed from Central Bank of Islamic Republic of Iran, governmental organizations and or official professional associations and entities.
• Customer relationship records with any of credit institutions licensed from Central bank of Islamic Republic of Iran and request from that institution in order to determine the accuracy of provided information by the customer.
• Reliable business license specially about non-financial businesses
• Certificate of employment from persons having business license and or from legal persons having national ID.
• Information about type, measure and customer’s activity goal in order to determine customer expected cash flow level in the area of its activity.

Legal Persons:
• Type, subject, nature and activity level of legal person
• Information about ranking of legal persons (from authorities such as validation company, ranking planning and strategic supervision Deputy of the President and or other professional authorities.
• Details of person or persons that have the right to withdraw from the legal person account(including name, family, name, IN No, father’s name, birth date, address and postal code) and their post9with sample of their authorized signature)
• Names, details, address and postal code of residence of Board members, Board/managing Director
• Main place of activity, address and postal code of central office, its Telephone and fax numbers, name and authorized signature and sample of their signature, and information about recognition of all financial documents and related correspondence, time and the jurisdiction of Board of Directors and Managing Director and or similar positions in institution about accounts.
• Commitment from managers and owners of authorized signature in legal persons based on that latest documents and information related to legal person have been presented and commitment on any changes in above cases to be informed immediately to credit institution.

Inquiry of information and documents of the customers
• Inquiry of information about Iranian real customers is performed through online system of Census organization of Islamic republic of Iran
• Inquiry of information about Iranian legal persons is performed through national ID system of legal persons of Islamic republic of Iran.
• Inquiry of information about non-Iranian legal real customers is performed through online system of data base registry of foreign nationals.
• Inquiry about accuracy of postal address informed to the Bank is performed through sending invitation letter to the customer’s address for receiving services.

Below persons are deprived from receiving Tourism bank services
• Iranian persons without national ID and number
• Foreigners without inclusive Code
• Unauthorized exchange offices

• Persons deny to provide required documents of the Bank
• Persons who cannot open an account due to the judgment of the courts

Matching of customers’ information with the list of accused persons and or suspected to money laundering
Tourism bank by using of software systems, matches the customer identity information with the list of suspected persons(watch list) submitted from financial information center(IRIFIU) and in case of performing any transaction by these persons, necessary reports will be submitted to relevant centers. Also list of wanted terrorists (issued by UN) has been loaded in the black list of centralized banking software of Tourism Bank. Persons listed in the black list are deprived from receiving any services in our bank.

Relationship with Shell and Offshore banks
Policy of Tourism Bank is based on disaffiliation of any financial relationship with banks as well as shell and offshore companies according to instructions about necessity for compliance with Anti-money laundering regulations in broker relations and identity of shell banks issued by Central Bank of Islamic republic of Iran, and on risk-based approach, we collect enough information about foreign banks.
Following cases are the information that are obtained from foreign banks:
• Information about ownership and management of foreign banks (including its management and ownership structure, share holders, managers and …)
• Main fields of activity
• Seating
• Instructions and inter procedures of the Bank for Anti-money laundering(specially customers identification procedures) and title of responsible section for Anti-money laundering in the Bank.
• Goal of opening the said account( in case that credit institution to be the broker bank)
• Identity of any other third party that will benefit from the services of broker bank( in case that a credit institution to be the broker bank)
• Supervisory status and banking regulations in the country of foreign bank
• Reputation risk status and full observance of Anti-money laundering regulations in foreign bank.

Identity of suspicious operations and transactions (STR)
All the personnel of Tourism Bank are obliged to inform any behavior and operations suspected money laundering and financing of terrorism, confidentially, to the Anti-money laundering office.
Submission of suspicious transactions reports, express no charge to individuals and informing it to Anti-money laundering office, will not be considered as disclosure of personal secrets, and consequently there will be no charges against reporters.

Report of cash settlement more than determined limit
In case of cash settlement more than determined limit, it is necessary that report of cash settlement to be performed and signed exactly by the customer, and to be handed over to the branch tellers.user the branch.
After working time, after aggregation, the branches Branches will submit all reports to Anti-money laundering office of the bank.

Protection of records and achieves
Tourism Bank will register and protect the information of all customers, whether real/legal and Iranian or non-Iranian, with time limitation.
Tourism bank is committed to act in such a manner that while keeping security and quality of documents, provides the access to original of those documents, easily, when required.

Confidentiality of information
• All transactions and operations suspected to money laundering are considered as confidential reports and if personnel inform the same to client, violator will be treated with the rules
• Names and details of suspicious persons are confidential and only will be in the access of concerned personnel. In case of any disclosure and or unauthorized usage of said information, violators will be treated with the rules.

Training
Tourism Bank is committed to organize in person training courses in relation with Anti-money laundering for all its personnel. At the end of each training course, certificate of Anti-money laundering will be granted to those persons that pass the exam successfully.