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2018 Financial and Social Report

Anti-money laundering and countering terrorism financing

The Bank’s Anti-Money Laundering and Combating Terrorism Financing (AML/CTF) Program is a comprehensive system to identify risk areas related to the crime of money laundering.

The Bank Group’s Companies have separate fraud prevention policies; however, the actions taken in the application of these policies are similar. They involve, among others, the use of financial security measures depending on the evaluation of money laundering risk, registration and reporting of transactions, selection of suspicious transactions, cooperation with the Inspectorate General of Financial Information.

Bank Millennium and the Bank Group Companies adjust their reports on an ongoing basis to the analysis of suspicious transactions, by adding the schemes operating in a given period (sectors, money flow directions, client behavior). These activities aim to identify effectively and report transactions that may be related to the illicit activity of money laundering.

Efficient operation of the fraud prevention policies is procured through the implemented internal procedures, organizational solutions and employee training programs.

AML Program – preventing money laundering
2018 Group 2018 Bank 2017 Group 2017 Bank 2016 Bank 2015 Bank
Number and % of trained employees* 1,511
(24%)
1,381
(24%)
1,572
(26%)
1,247
(23%)
1,093
(20%)
1,259
(23%)
Number of Suspicious Activity Reports (SARs) sent to GIIF** 224 221 177 176 148 152
Number of clients covered by the SAR reports 842 839 558 557 450 472

* new employees of selected units undergo training

**General Inspector of Financial Information