Author: Telmuun Gankhuyag

Anti-money laundering and countering the financing of terrorism policy:

Transport and Development Bank has implemented compliance principles into our business operation in accordance with the Law on Anti-money laundering and countering the financing of terrorism (AML/CFT Law), as well as regulations, recommendations and standards issued by international and domestic regulatory bodies.

The Bank has developed an AML/CFT program covering Know Your Customer (KYC) Procedure, Customer/Product ML/TF Risk assessment, Implementation of international sanctions and Correspondent bank and financial institution’s relationship in accordance with applicable laws and regulations.

In accordance with the AML/CFT Law and Regulations, the Bank shall undertake appropriate KYC measures to fully ensure and verify customer’s data, payment slip, agreements, invoices and any other documents prior to providing any banking services.

The information indicated below shall be authenticated by an official source and documents. These include:

1. The purpose of business relationship with the bank;
2. Beneficial owner and shareholder structure, asset management information;
3. Customers’ nature of business and operations are in line with the purpose of the transaction;

Prior to establishing any financial and business relationship with foreign banks, the Bank shall comply with the requirements of the Correspondent Banking Due Diligence Questionnaire (CBDDQ) and recommendations on correspondent banking relationships issued by Wolfsberg Group, US Patriot Act and FATCA Regulation.

Wolfsberg CBDDQ:

Please click on here to access Correspondent Banking Due Diligence Questionnaire (CBDDQ) for FIs defined by the “Wolfsberg Group”.

US Patriot Act:

Please click on here to access Global USA Patriot Act certification issued by the U.S. Department of the Treasury.

FATCA:

Transport and Development Bank, akin to every financial institution in the world is obligated to report foreign financial assets and accounts held by US Person and legal entities to the US Internal Revenue Service (IRS) under the Foreign Account Tax Compliance Act (FATCA).

Please click on here to access FATCA W-8BEN-E form completed by the Transport and Development Bank.

TransBank is committed to ensuring that it has adequate controls to counter money laundering and terrorist financing activities, in line with all applicable laws, rules and regulations mandated by the governments of Mongolia as well as other relevant international standards and/or recommendations.

 

Translation of legal and regulatory obligations into procedures

We have established policy and procedures designated to combat Money laundering and Terrorism Financing in line Mongolian AML law, FATF standards and other regulatory’ s respective rules and regulations. The AML/KYC policy is included policy of identifying and verifying the identity of the customers and of the beneficial owners on the basis of documents, data or information obtained from a reliable and independent source. We do not allow anonymous accounts.

Moreover, we pay special attention to:

• Understand the ownership and control structure of our customers;
• Obtain information on the purpose and intended nature of business relationship; and
• Monitor the business relationships, including scrutiny of transactions to ensure consistency of transactions with obtained information about and intended nature of business relationship.

All legal and regulatory documents related to the Mongolian law and other international AML/CTF framework have been translated into internal written procedures and they are regularly reviewed and updated. These mandatory policies and procedures are compliant to the FATF and other AML standards.

The AML/CTF policies and procedures have been approved by the BoD.

Acceptance of new customer and new business relations

For all new accounts opening requests, branch front-office staffs are required to fill out a detailed questionnaire asking for precise information about prospective customers, their type of business, the origin of their wealth and the type of operations they to conduct with the bank, etc.

Prospective customers are screened in an ongoing process through official lists in order to avoid to enter into relationship with individuals or institutions which appear on applicable lists of terrorists or terrorist organizations, or against whom sanctions have been imposed by the UN or US OFAC list, EU or with someone being or having been involved in criminal activities.

We have procedures in place for the identification and the monitoring of politically exposed persons (PEPs). Enhanced due diligence is conducted on these customers. In accordance with a risk based approach, account opening requested by prospects considered as requiring an enhanced due diligence (such as PEP, clients’ resident in high risk country from AML/CTF perspective, clients having a high risk professional activity, etc) have to be formally approved by the Senior management with a Compliance recommendation.   The Bank does not enter knowingly into any business relation with a “shell bank/shell company”.

Any new business relation with a potential banking correspondent in a country with non-equivalent international and domestic AML/CTF measures has to be approved at Compliance level on the basis of a duly motivated request and a thorough analysis of the identity, the reputation and the AML process of that particular correspondent (for instance via the Wolfsberg questionnaire). We do not allow direct use of correspondent accounts by third parties (payable through account).

Monitoring transactions

We use dedicated AML tools to be detect suspicious transactions and to filter incoming and outgoing payments. The detection of suspicious transactions will trigger an in-depth investigation of the customer account by Compliance department who analyses deeply the situation. The bank filters transfer messages and screens its clients database against official lists and internal lists.

Employee AML/CTF training

A mandatory Compliance awareness and training program has been implemented in order to provide training and information to relevant employees taking into account the level of risk exposures of their function and to comply with the standing legal requirements. These trainings include introductory training for new employees as well as ongoing training for existing employees, either face-to-face or through other means. In case of legal or regulatory changes, supplementary training and information are provided.

Responsibility of branches, departments

Transbank has instructed all branches and departments to respect the Bank standards regarding AML/CTF and KYC. General AML/CTF policies and procedures are available to the employees on our internal intranet site. Starting 2022 Transbank’s branches have appointed internal Compliance staffs, each Compliance staff responsible for implementing AML/CTF policies and procedures within the branch, train and advice branch staff in order to opening a new account, conducting wire transfer, performing customer DD etc.

Our Internal Audit Department is auditing Compliance activity on a regular basis and compliance procedures and practices from AML/CTF perspective. In parallel, Compliance is also performing controls and risk assessments of the operational procedures and their practical application, new product and services.

 

Please find here under the information concerning the responsible AML Officers:

Delgersaihan Amarjargal
Head of Compliance unit
Tel: 976-7716999 (ext 114)
Email: delgersaikhan.a@transbank.mn

Turgerel Tumurkhuyag
Senior AML officer
Tel: 976-7716999 (ext 106)
Email: turgerel.t@transbank.mn