Anti-money laundering and countering terrorism financing (AML/CTF)
Bank Millennium identifies and assesses the risks of money laundering and terrorist financing relating to the Bank’s activities, taking into account risk factors concerning clients, countries or geographical areas, products and services, transactions, their delivery channels, taking into account the nature and size of the Bank.
The Bank’s Internal Procedure for Anti-Money Laundering and Combating Terrorism Financing (AML/CTF) is a comprehensive system to identify risk areas related to the crime of money laundering or terrorism financing. In order to minimize the risk, the Bank operates in accordance with the AML/CTF Procedure, which defines the rules of conduct consistent with national and international laws and banking standards.
The Bank applies financial security measures with respect to its clients, appropriate to the level of identified AML/CFT risk, takes steps to mitigate the risk of opening relationships and conducting business with persons or entities suspected of obtaining their funds illegally.
The Bank complies with Polish AML/CFT regulations, European Union and United Nations legal regulations and international banking standards concerning specific restrictive measures (sanctions). The AML/CFT internal procedure is reviewed at least once a year for compliance with applicable laws and regulations.
All Bank Millennium employees are obliged to make every effort to prevent the use of the Bank's products and services for money laundering and terrorist financing and to report any suspicious activity promptly to the appropriate banking unit.
The Bank conducts AML/CFT training for all employees in order to meet the highest standards, in particular with regard to the applicable AML/CFT regulations, including inter alia the application of financial security measures and specific restrictive measures within the client business relationship and the typology of money laundering. 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 adequately described in the Bank’s internal regulations. A dedicated AML unit is appropriately placed in the Bank’s organizational structure, and the persons responsible for the Bank’s AML activities have appropriate competence and qualifications.
The Bank’s Management Board is regularly informed on how the AML/CFT Procedure is being implemented. In particular, reporting includes the most relevant information as part of management information, including major changes in laws and regulations, statistical data and other data required to present a complete picture of AML/CFT risk in the organization. The Bank has in place a specialized AML Committee, which receives regular information on this subject, as does the Supervisory Board, which is informed on at least an annual basis.
Bank Millennium Group companies which are obligated institutions have separate AML/CFT policies and apply the requirements of AML/CFT regulations in a consistent manner. Employees performing AML/CFT related duties are appropriately trained in this respect, according to the training program.