FAB Financial Crime Compliance Program

FAB Group is committed to uphold the highest standards in combatting money laundering and terrorism financing, in accordance with UAE laws and regulations (including jurisdictions in which it operates), and the Financial Action Task Force (FATF) recommendations and international best practices. As a global financial institution, FAB will not intentionally allow actions and activities that would result in breaching the applicable AML & CTF laws and regulations.

Group AML Program
FAB Group has established a global Anti-Money Laundering (AML)-Counter Terrorist Financing (CTF) program to protect both its clients, branches, subsidiaries, and affiliates from the risks of money laundering and terrorism financing. The foundation of this program is FAB’s AML-CTF Policy, which provides the minimum set of standards to be adhered across the Group and to also ensure Compliance with the applicable local regulatory requirements where it operates.

The program includes but is not limited to:

• Appointment of a Group and Country Money Laundering Reporting Officer (MLRO) as required by local regulation.
• Establishing comprehensive governance and oversight of the program across the bank.
• Undertaking Customer Due Diligence (CDD) measures, which covers customer Identification and Verification (“ID&V”), Know Your Customer (“KYC”), customer risk rating and screening.
• Identification and screening of all customers, with enhanced focus on higher risk customers such as Politically Exposed Persons (“PEPs”), their relatives and close associates.
• Undertaking AML transaction monitoring to identify and report suspicious activities.
• Maintenance of robust systems and technology.
• Providing ongoing mandatory AML and CTF training to all staff.
• Ensuring that an independent function regularly tests the effectiveness and adequacy of internal policies, procedures, systems and controls associated with combating potential ML/TF crimes.
• Ongoing guidance to the business and addressing their queries related to AML and Sanctions.
• Maintenance of all records, documents and data relating to customers and transactions as required by the local regulation.
• The prohibition of the following products, services, customer types and activities:
  • Shell entities / banks;
  • Anonymous or numbered accounts or customers seeking to establish a relationship in obviously fictitious names or pseudonyms;
  • Payable-through-accounts through local or foreign banks customers;
  • Money Service Bureau or similar type of organisations, Charities, Non-governmental Organisations (NGOs), Non-profit Organisations (NPOs) and any other organisations that are not legally established in the country or permitted by local laws, including foreign charities;
  • Establishing relationships or processing transactions with individuals or entities that perform covered Virtual Asset Service Provider (VASP) activities and are not licensed to do so by relevant UAE authorities; and
  • Establishing relationships or processing transactions of foreign VASPs that have not secured a license to operate as a VASP from relevant UAE authorities, even if the foreign VASP is duly licensed or registered outside the UAE.

The Wolfsberg Group Financial Crime Compliance Questionnaire (FCCQ) is a shorter version of the CBDDQ and contains a basic set of questions to address industry demand. Download the FAB Wolfsberg Group Financial Crime Compliance Questionnaire here.

FAB Group has established a group sanctions policy (the “Policy”) to ensure compliance with applicable sanctions laws and regulations administered by United Nations Security Council (“UNSC”), United Arab Emirates (UAE), the United States Office of Foreign Assets Control (“OFAC”), the United Kingdom His Majesty’s Treasury (“UKHMT”) and the European Union (the “EU”). The Policy applies to FAB and its subsidiaries (collectively, the “Group”).

The Policy defines the minimum standards that all Group entities must comply with, including:

• Screening customers and transactions against global sanctions lists issued by the UNSC, UAE, OFAC, UKHMT and the EU, as well as against relevant local sanctions lists that apply to FAB’s operations in a particular jurisdiction;
• Prohibiting business activity that includes on-boarding or continuing customer relationships or providing products or services or facilitating transactions that FAB believes violate applicable sanctions laws or the Policy. This includes, as a matter of policy, prohibitions on business activity with individuals or entities named in a sanctions list screened by FAB or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions. These countries or territories currently include Cuba, Iran, North Korea, Syria, and the regions of Crimea, Donetsk and Luhansk of Ukraine;
• Blocking or rejecting transactions where FAB is required to do so under applicable sanctions laws; and
• Reporting of sanctions breaches to the relevant authorities.

In order to ensure compliance with the Policy, the Group reserves the right in its sole and absolute discretion, not to process transaction(s), or provide products or services even though it is permitted under applicable sanctions laws or are covered under general or specific licenses from the applicable sanctioning authority, where these activities fall outside of FAB’s risk appetite. Where the Group decides to process certain transactions that might be prohibited under the Policy but authorized under valid licenses or local appliable regulations, customers may be required to furnish additional information as and when necessary.

FAB Group in its commitment to fight proliferation financing risks, will not support or knowingly become part of the proliferation financing networks or schemes, in contravention of the relevant obligations and shall take appropriate measures aimed to combating proliferation.

The building block of FAB’s CPF program are as follows:

• Policies and procedures outlining key principles, guidelines, and controls
• Risk assessment to identify inherent PF risks, controls and residual risks
• Enhanced due diligence on customers, goods and transactions found to involve any proliferation sensitive goods or services
• Screening systems, tools and applications (names, payments, trade documents, counterparties, vessels, dual-use goods)
• Freezing/blocking of assets and reporting of potential unusual transactions
• Training and awareness campaigns

FAB Group is committed to conducting the business in accordance with the highest ethical standards and in full compliance with all applicable anti-bribery and corruption laws and regulations including but not limited to; Foreign Corrupt Practices Act (FCPA), UK Bribery Act, UAE laws and other applicable local country laws / regulations where FAB operates.

FAB Group AB&C Policy applies to all activities and operations across the Group, irrespective of their jurisdictions, businesses and operations including second- and third-party employees and is binding for all Group branches, affiliates and subsidiaries except where the provisions of the Policy differ due to the local regulatory requirements (the stricter requirements will take precedence).

FAB Group has zero-tolerance towards bribery and corruption and prohibits them in any form, both directly and indirectly.

Group AB&C Program
Key components of FAB Group AB&C Program include:

• Oversight, governance and escalation
• Risk assessment process Communication and training
• Review and pre-approval processes
• Due diligence on third party relationships
• Confidential reporting, financial controls and record-keeping
• Independent testing processes

FAB’s AB&C Program also encompasses the following overarching key principles:

Gifts, Hospitality and Facilitation Payments

FAB strictly prohibits any form of bribery (payment, offer or promise to pay or provide anything of value), gifts and hospitality, facilitation payments and payments to government to secure or expedite the performance of a routine action or otherwise induce public officials or third parties to perform routine functions they are otherwise obliged to perform in order to secure an improper advantage.

Public Officials

It is strictly prohibited to interact with a public official, including their representatives or agents, with the intention of influencing actions taken within their official function or securing any such improper advantages.

Employment/Internships

Employment opportunities, whether permanent or temporary in nature, and internships (whether paid or unpaid) must be merit-based, fair and in line with the hiring standards applied for all employees, and must not be used as an inducement to anyone to act improperly for obtaining or retaining an advantage in business.

Associated Persons and Third Parties

Associated persons and third parties engaged to represent FAB’s interests must comply with the principles set out in the FAB Group AB&C Policy. FAB mandates appropriate level of due diligence on all such associated persons and third parties, and the application of suitable contractual terms and governance to reduce bribery and corruption risks.