Financial and
ESG report 2020

Anti-money laundering and countering terrorism financing (aml/ctf)

Bank Millennium identifies and assesses money laundering and terrorist financing risks related to the Bank’s activities, taking into account risk factors connected with clients, countries or geographical areas, products and services, transactions, delivery channels, taking into account the nature and size of the Bank.

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 or terrorist financing. In order to minimize the risk, the Bank operates in accordance with the principles of the AML/CTF Program which sets out rules of conduct in line with national and international legislation and banking standards.  

The Bank applies to its clients the financial security measures appropriate to the level of identified AML/CFT risk, takes steps to mitigate the risk of establishing relationships and conducting business with persons or entities suspected of obtaining their funds illegally.  

The Bank complies with the Polish AML/CFT laws, the legal regulations of the European Union and the United Nations, as well as the international banking standards with respect to specific mitigation measures (sanctions). The AML/CFT program is reviewed for compliance with applicable laws and regulations at least annually.  

All Bank Millennium employees are obliged to make every effort to ensure that the Bank’s products and services are not used for money laundering and terrorist financing and that any suspicious activity is promptly reported to the appropriate banking unit. 

The Bank provides AML/CFT training to all employees in order to meet the highest standards, particularly with regard to the applicable AML/CFT regulations, including but not limited to the application of financial security measures and specific mitigation measures in the business relationships with clients, and money laundering typology. The Bank has procedures and channels in place to report AML violations that ensure anonymity and fully reflect the requirements of the Act. 

The most important functions, roles, and responsibilities as well as specific areas, in particular high risk areas, are appropriately described in the Bank’s internal regulations. A dedicated AML unit is properly placed in the Bank’s organizational structure and the persons responsible for the Bank’s actions in the field of AML have the appropriate skills and qualifications. 

The Bank’s Management Board is regularly informed of the implementation of the AML/CFT Program. The reporting includes, in particular, the most significant management information, including the most important changes in the law and regulations, statistical data and other data required to provide a comprehensive presentation of the AML/CFT risk in the organization. The Bank has a specialized AML Committee which receives regular information on the matter, as does the Supervisory Board which is informed on at least an annual basis. 

The Companies of the Bank’s Group that are obligated institutions have in place separate policies on anti-money laundering and counter-terrorist financing and apply the requirements of AML/CFT regulations in a consistent manner. Employees performing the AML/CFT duties are properly trained in line with the training program. 

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