AML/CTF policy

On measures taken by JSC VTB Bank to prevent money laundering and terrorism financing

Please be advised that in fulfillment of the Federal Law "On Anti-Money Laundering and Terrorism Financing" and regulations of the Bank of Russia", VTB Bank Group consolidated policy on anti-money laundering and terrorism financing" (available at www.vtb.ru), "Rules of internal control on anti-money laundering and terrorism financing" and "Instruction on preparation and representation of information stipulated by the Federal law "On anti-money laundering and terrorism financing"  were developed and approved in JSC VTB Bank.
 
Denis V. Novikov (Phone: +7 (495) 783-19-20, Fax: +7 (495) 783-19-21, e-mail: novikov_dv@msk.vtb.ru), Head of Banking Transactions Monitoring Division of JSC VTB Bank was made responsible for observing the rules of internal control over anti-money laundering and terrorism financing and executing related programs by the divisions of the Bank.
Please be informed that JSC VTB Bank does not establish and maintain relations with non-resident banks without any standing regulatory bodies on the territory of the countries of their incorporation.

JSC VTB Bank has no accounts in the banks registered in the countries, which do not abide by anti-money laundering and terrorism financing standards (if it is known from international sources).

Please be advised that under the Bank of Russia Regulation No. 283-P "On the Procedure for Formation by Lending Institutions of Reserves for Possible Losses" dated 20.03.2006, JSC VTB Bank has currently no requests from the taxation authorities to transfer payments to every budget of the Russian Federation budget system as well as governmental non-budgetary funds and has not received any regulation on sequestration of correspondent accounts in other banks. JSC VTB Bank will notify you of any changes introduced into the information above.

Looking forward to mutually beneficial cooperation.

Declaration by a group of Russian banks

With the aims of fighting penetration of criminal capital into national economies and opposing financing of terrorist activities many countries of the world have created or are in the process of creation of national mechanisms of counteraction to laundering of criminal incomes and join efforts in this area under the auspices of international organizations.

The Russian Federation also joined the international system of measures aimed at prevention of legalization of criminal incomes and terrorism financing and is an active participant of the Financial Action Task Force (FATF) and of the Egmont Group. The Russian legislation on money laundering and terrorism financing incorporates major recommendations elaborated by world community.

Since many products and services offered by banks are used as instruments for money laundering and financing of terrorism, and assuming the necessity of fulfilling the requirements of Russian legislation

THE SBERBANK OF THE RUSSIAN FEDERATION,
VTB BANK,
VNESHECONOMBANK,
ALFA BANK,
BANK OF MOSCOW,
BANK ZENIT,
INTERNATIONAL MOSCOW BANK, and
RAIFFEISENBANK AUSTRIA (MOSCOW)

declare that in their professional activities they will be guided by the following principles:

• inadmissibility of utilization of the Bank for money laundering and terrorism financing purposes;
• identification of all customers of the Bank;
• application of "know your customer" principle to each of the Bank's customers;
• ban on opening of bearer accounts;
• establishment of correspondent relations only with financial institutions that take measures aimed at prevention of money laundering and terrorism financing;
• ban on correspondent relations and transactions with " shell banks" having no physical presence at the address of their registration;
• timely information of the Federal executive body empowered to fight money laundering and terrorism financing (FSFM) of transactions subject to reporting.

Assuming the complexity of anti-money laundering and terrorism financing tasks facing the Russian banking community, the aforementioned banks while fulfilling Russian legal requirements and recommendations of international organizations of which Russian Federation is a part, will also undertake joint actions such as:

1.       Sharing experience in the area of internal control aimed at prevention of money laundering and terrorism financing.

2.       Development of common approaches to realization of the principle "Know your customer".

3.       Joint elaboration of methods of revealing suspicious transactions and financial schemes and of standard characteristics money laundering and terrorism financing transactions.

4.       Pursuing of united policy towards correspondent banks.

5.       Elaboration of unified standards of staff training in the field of money laundering and terrorism financing; organization of joint training seminars, round tables, research-and-practical conferences.

6.       Preparation and sending to the Bank of Russia, the Federal Service for Financial Markets and the Federal Service for Financial Monitoring of joint proposals on improvement of legal and normative base in the field of money laundering and terrorism financing; rendering of practical assistance to these institutions in elaboration of normative documents in this field.

7.       Development of coordination between the 8 banks based on the principle of free will.

8.       Development of cooperation with Russian and foreign banks, their groups and associations interested in strengthening and improvement of Russian and international systems of money laundering and terrorism financing.

This Declaration is open for joining by Russian credit institutions that share principles and intentions stated herein.