In line with Banque du Liban (BDL) circular 128 dated January 12, 2013, Banque BEMO started establishing its compliance department which includes two main units: the Legal Compliance unit and the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Compliance unit. The Regulatory Compliance and AML/CFT Compliance units are vital components for firms operating in today's global financial market in order to avoid any reputational risks or financial losses that could result as a consequence of non-compliance.
AML/CFT Regulation/Policies & Procedures
With the aim of protecting the Bank's name and reputation, and in order to prevent the use of the Bank's products or services for money laundering or terrorist financing, Banque BEMO introduced internal policies and procedures, which are updated annually or when deemed necessary.
Customer due diligence /Know Your Customer
The Bank is constantly refining its tools, including its systems for fighting money laundering and terrorist financing. For all accounts to be opened in the Bank's books and prior to granting potential customers an ID, the Bank ensures that the necessary approval is obtained from the Customer Acceptance Committee (CAC), where the Compliance Officer is a member whose duty is to make sure of the adherence to regulations. Moreover, the Compliance department screens all customer names against local and international watch-lists including those of SIC, EU, OFAC, UN, CBC and MOKAS and searches the Internet thoroughly using trusted websites and search engines for any related information. As an additional required step, the "know your customer, KYC" procedures have been improved. All customers are required to identify the beneficial right owner of the account; the purpose and intended nature of the relationship; the economic and business profile of the customer; the source of funds; the source of wealth; the expected account turnover; the residential and business addresses. No account is opened without obtaining all the required information mentioned afore. Continuous monitoring of transactions is conducted by all branches as well as by the compliance staff. Transactions that are suspected of hiding illegal activities are reported to Special Investigation Commission/MOKAS.
Training and awareness
All new recruits systematically attend due diligence sessions prepared by the AML/CFT compliance officer in close cooperation with the Human Resources department: these sessions cover raising awareness on due diligence and money laundering as well as on terrorist financing fighting methods. External trainings are attended by the compliance staff and the branches AML/CFT officers in order for them to stay updated on the latest International Sanctions Regulations in addition to the new tools used to launder money and to finance terrorism. Staff members are regularly updated on anti-money laundering and fighting terrorists' policies and procedures to prevent the Bank from being used in criminal activities.
The Foreign Account Tax Compliance Act (FATCA) was enacted by the American Congress in 2010 to target non-compliance by U.S. tax payers using foreign accounts. This law requires foreign financial institutions to inform the Internal Revenue Services (IRS) about accounts owned by U.S. persons, as it requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFI) that do not agree to provide the identity and to report information on U.S. account holders. Being a foreign financial institution, all Banque BEMO branches and affiliates are in line with the orientation of the banking institutions worldwide and intend to be fully compliant with FATCA, as required. On a corporate level, we are working with Deloitte as external advisors. Internally, the project has been centralized and headed by a FATCA project manager who is coordinating the FATCA implementation across business lines under the oversight of a FATCA steering committee. The FATCA implementation has been divided into phases such as: updating the on-boarding processes; documentation; due diligence; system enhancements; reporting; withholding; etc. All necessary measures are taken by the Bank in order to meet FATCA requirements within the time frame set by the regulators. The Bank is highly committed to a culture of Compliance, and strictly abides by the requirements of the Sanctions Regulations imposed by the International Community by implementing additional preventive measures on a certain category of clients with a high risk line of business and cross border transactions.