Vnesheconombank’s Internal Control procedures designed to prevent money laundering and terrorism financing were developed in conformity with the Russian legislation, the Bank of Russia’s regulatory documents, as well as with due regard for the nature and major areas of the Bank’s activities, its customer base and the level of risks related to customers and their transactions. The procedures mentioned include:

  1. Procedure to apply to setting up and introducing in Vnesheconombank appropriate and effective measures to prevent laundering of ill-gotten gains and terrorism financing;
  2. ‘Know your customer’ procedure providing for customer and beneficiary identification in Vnesheconombank;
  3. Procedure to apply to detecting in the customers’ activities transactions that are subject to mandatory control, as well as spotting other operations related to money laundering and terrorism financing;
  4. Procedure to apply to checking all the information about a customer and the respective operations, as well as about a beneficiary in order to confirm or eliminate the suspicions concerning money laundering or terrorism financing;
  5. Data documenting procedure;
  6. Procedure to apply to storing of information and documents obtained through implementing the Internal Control measures designed to prevent money laundering and terrorism financing;
  7. Programme of training Vnesheconombank’s personnel in preventing money laundering and terrorism financing;
  8. Procedure for declining to conclude a banking account (deposit) agreement with an individual or a legal entity;
  9. Procedure for declining to follow customer instructions related to transaction execution;
  10. Procedure for suspending monetary and other related transactions.