Bank Refah Kargaran Anti- (AML) & Combating the Financing of Terrorism (CFT) Policies and Procedures

Last updated in 2020

AML & CFT Policies and Procedures of Bank Refah Kargaran

Introduction Nowadays, the crime of money laundering and terrorism financing are considered as one of the difficulties and at the same time the most concealed kind of crimes targeting the economy and subsequently the society. This is certainly the underlying reason for countries and international societies for being decisive to fight against the destructive impacts and consequences of this phenomenon while considering its international and organized nature in the current era. Compiling international standards, providing legal infrastructures (relevant rules and regulations) and identifying proper methods to encounter this problem have caused the governance of countries to oppose money laundering and terrorism financing activities along with international authorities through ratifying rules and regulations and implementing them in order to prevent the crime in financial and institutions or to present the criminals to judicial authorities in case of occurrence. By approving the law of AML and its executive by-laws, the Islamic Republic of has been also among the countries confronting this indecent phenomenon and has considered money laundering and terrorism financing as a crime and has also prepared necessary rules and regulations which have been approved by the related authorities to prevent these acts. Accordingly, in order to prevent the commitment of such crimes, Anti-Money Laundering & Combating Financing of Terrorism Policies of Bank Refah Kargaran have been ratified and are herewith presented while considering the updated law of AML under number 347/95820 dated 23/01/2019 approved by the Islamic Consultative Assembly and the law of CFT number 15/90661 dated 12/03/2016 approved by the Islamic Consultative Assembly while binding to the rules and regulations circulated by the of Iran and the FIU, latest guidelines of FATF, principles of Banks for International Settlements (BIS) and the Wolfsberg International Group. AML/CFT policies and procedures of Bank Refah Kargaran which are herewith compiled and being presented have the confirmation of the bank’s board members and are as follows:

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AML & CFT Policies and Procedures of Bank Refah Kargaran

1- Definitions: 1-1- The Law:  AML Law approved in 2008 and its amendment in 2019,  CFT Law approved in 2019. 1-2- The Council: The high council of AML/CFT mentioned in article 4 of the Law. 1-3- FIU: Financial Intelligence Unit for AML mentioned in article 7 of the Law. 1-4- AML/CFT Unit: AML/CFT unit which is responsible for AML/CFT tasks mentioned in article 37 of the AML by-law for the included people. 1-5- Included People: people mentioned in article 5 and 6 of the Law. 1-6- Client/Customer: includes any person or legal entity, the principal, the lawyer or legal representative of the person who refers to the included people for having deals, financial transactions, conducting finance project or any other economic activities. 1-7- Suspicious Transactions and Operations: includes any kinds of transactions, paying or receiving wealth in cash or electronically which according to observations and references deem to be suspicious. 1-8- Determined threshold: threshold amount applied for holding bids in retail dealings in cash or the equivalent in any other or precious goods which is annually ratified by the ministry board according to article 3, note 1 of the Bids Law. 1-9- High-risk regions: countries and geographical regions in which the occurrence of money laundering and terrorist financing seems to be high. The list is determined and announced by the Council. 1-10- People under Surveillance: the list and specifications of all individuals whose connection to money laundering and terrorism financing has been proved through risk monitoring and the issue is then announced to the included people by the FIU so that counter measures can be made in order to lessen the risk of money laundering and terrorism financing. 1-11- Suspicious people: the list and specifications of all individuals, whose connection to money laundering and terrorism financing has been determined due to suspicion, are announced to the included people by the

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AML & CFT Policies and Procedures of Bank Refah Kargaran

FIU so that counter measures can be made in order to lessen the risk of money laundering and terrorism financing. 1-12- Sanction List: a list including the name of any individuals or legal entities under the UN Security Council resolution number 1267 and its subsequent resolutions and people under I.R.I sanctions list which have been determined according to the UN Security Council resolution number 1373. 1-13- Client Risk: the risk of money laundering and terrorism financing occurrence which is resulting from factors such as social and occupational status, financial status, type and nature of professional activity, history record and mainland of the person. 1-14- Region Risk: the risk of money laundering and terrorism financing occurrence which is resulting from the geographical status in which the working communication takes place. 1-15- Service Risk: the risk of money laundering and terrorism financing occurrence which is resulting from the type or value of service or transaction presented to the client. 2- The structure of AML/CFT Department of Bank Refah Kargaran : Today, the concept of money laundering has got a wide range of multiple functions in a way that it includes all financial revenues derived from illegal activities such as complicated money transfers, disproportion of the customer’s account turnover with the related profession, non-transparency of the real beneficial owner, nested accounts, tax evasion, etc. Due to the expansion of financial dealings and the application of fraudulent tricks in novel technologies by the money launders, the need for smart systems to be applied against financial crimes has been proved to be more than before. At the same time, due to the installation of AML system which has been established based on FIU principles while considering all other obligatory by- laws from supervisory and legal authorities, the AML/CFT department of the bank has experienced a considerable increase in the volume of referred tasks in recent years. In this regard, the structure of the AML/CFT department has been reviewed according to all requirements announced by the outsourced competent authorities and has gone under some changes and subsequently been approved by the Bank’s Board which includes the following: 4

AML & CFT Policies and Procedures of Bank Refah Kargaran

 The establishment of a unit for monitoring, tracing, reporting, conducting CTR and STR, analyzing and complying the reports, responding to auditors regarding money laundering and terrorism financing, supervising the bank’s customers for identifying suspicious transactions, etc.  The establishment of a unit for making AML/CFT policies and expanding AML/CFT projects and updating the policies when the need arises, conducting the bank’s annual project of AML and CFT and controlling the same on monthly basis, etc.

3- Risk Evaluation and adopting risk-based approach : All organizations and entities under article 5 and 6 of the amended law of AML including the banks, are obliged to collect and implement their internal AML/CFT plans while applying risk-based approach and considering the national deed of risk- evaluation. Accordingly, all the bank’s units and related personnel must evaluate and classify the risk when making decisions for extending banking services to customers prior to rendering any banking services and in order to manage and lessen the risk of money laundering and terrorism financing. Risk classification for the subject transactions must be clear, comprehensive and preventive so that according to the performed classification, the released information and its related measures to confront with money laundering and terrorism financing acts, the derived results seem to be logical. To accomplish this, the following criteria must be taken into consideration:  Legal entities who are of abnormal economic activity methods or complicated ownership structure, or those whose financial activities are not consistent with and proportionate to their Articles of Association,  Politically Exposed Person (PEP),  People commuting in high-risk regions,  People with conviction records in relation to money-laundering acts or security issues. Therefore, all the bank’s softwares and systems must be designed in a way that extending banking services becomes possible only when all required information for 5

AML & CFT Policies and Procedures of Bank Refah Kargaran

risk-evaluations is gathered and registered. Furthermore this procedure must be constantly and mechanically supervised and necessary measures must be made when deviations are observed. 4- National Cooperation and Coordination According to AML/CFT rules and by-laws, relevant organizations are obliged to establish and install AML systems while determining the possibility of access to the information and the related levels of access for each category. Some of the related measures which can be pointed out are establishing a core system for identifying all Iranian individuals through National Organization for Civil Registration, establishing a unique address system for individuals and legal entities by the Ministry of Communications and Information Technology, establishing a system for registering expensive lux automobiles and carpets by the Ministry of Commerce, Mining and Industry, etc. 5- Supervisory Procedures All included entities including banks are obliged to establish a unit/department in the capacity of their AML/CFT unit based on their type of activities and organizational structure and all necessary requirements including budget, human resources, IT infrastructures , etc. must be provided to ascertain the full execution of related AML/CFT rules and regulations. Some of the related assigned duties for AML/CFT departments are as follows:  Supervising customers’ activities in order to identify suspicious transactions,  Sending suspicious transaction reports to FIU while not informing the customer,  Providing softwares in order to facilitate the access to required information for full implementation of rules and regulations and the systematic identification of suspicious transactions,  Issuing and circulating necessary directives with regard to anti-money laundering and counter terrorism financing,  Providing annual plans for performing AML/CFT rules while conducting monthly supervision on its progress,

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AML & CFT Policies and Procedures of Bank Refah Kargaran

 Supervising and inspecting subordinate units to ensure full execution of related AML/CFT rules and regulations.

6- Know Your Customer All banks and financial and credit institutions are obliged to organize policies and procedures (basic, regular, double) appropriately in performing KYC in a way that evaluating the related risk is possible both upon the start of business with the customer and throughout business interaction with the customer. Required information must at least include the type of customer (individual/legal entity), customer’s citizenship, geographical region and customer’s domicile, origin and destination of financial transactions, occupations and type of activity, income and financial resources level, required type of banking services, etc. so that the transaction’s nature, target and risk are specified. 6-1- Policy of receiving customers: Implementing KYC policies in Bank Refah Kargaran is based on the instructions and circulars of the Central Bank of Iran and all the personnel of the bank are obliged to make necessary measures for updating and completing the information and documents related to previous customers according to article 15 of the executive by- law approved by the Board of Ministers regarding the classification of former customers. In case customers are not cooperating in presenting their identity documents or when trying to give misinformation, the staff in related branches refuses to render any kinds of banking services to such customers. Meanwhile according to article 8 of the instruction of “The manner of identifying the customer of Iranian credit institutions” approved by the Supreme Council of AML, those customers for whom discrepancies are found in their identity information - after being informed by the bank to present documents and to complete required information- are bound to resolve the mentioned discrepancies and if the customers refrain from doing so, the staff will prevent the customer from receiving any banking services and stop extending any basic services to them in such a manner.

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AML & CFT Policies and Procedures of Bank Refah Kargaran

6-2- KYC Procedures: By implementing the AML/CFT instructions (including the instruction of identifying Iranian customers of credit institutions and the instruction of identifying foreign customers, PEPs who are appointed by the supreme committee of the country’s AML council) identifying customers in Bank Refah Kargaran is possible according to complying the specifications received from the customer with valid ID documents and after identity identification of customer through contacting competent organizations. (Including National organization for Civil Registration and Company Registration General Office) According to the instruction notified by the Supreme Committee of AML, banking services in Bank Refah Kargaran are divided into two types of “basic services” and “non-basic services”. Basic services are those banking and credit services which, according to regulations are considered to be pre-requisite and required for providing other services by the bank after which customers call on the bank to receive frequent and continuous services. Basic services may include opening different kinds of accounts or allocating credit facilities, leasing operations, etc. Non-basic services are the banking and credit services which are not preliminary for extending other kinds of services and after which customer may not call on the bank to receive frequent and continuous services. Non basic services include receiving and paying funds, Buying and selling foreign exchange, etc. The process of identifying customers (including individuals or legal entities) in Bank Refah Kargaran is divided into three levels of basic, regular and double identification according to the type of banking services: 1. Basic identification: In order to perform basic identification procedures, simple and easy strategies are adopted for knowing the customer according to the customer’s risk level. After a general risk evaluation, basic identification procedures are performed only when the risk of business interaction with the customer is at a low level. Rendering non-basic banking services below the determined cash threshold can be considered as an example of such interactions. 8

AML & CFT Policies and Procedures of Bank Refah Kargaran

2. Regular identification: In regular identification procedures, minimum strategies are considered, three types of data including identity information, economic information and beneficial owner status are gathered from the customer as the case may be and after checking the authenticity, the information is systematically displayed in the customers’ profile. Related personnel in branches are obliged to determine customers’ activity level based on executive by-law of article 14 of AML/CFT Law in order to thoroughly control both KYC and risk evaluation procedures in business interactions with the customers.

3. Double identification: When the risk of entering into business interaction with customers is valuated as high, all the bank’s branches have to adopt double procedures and make additional measures. Serious double identification procedures have to take place at least for the two following business types,:  With regard to business interactions with individuals and legal entities for which the risk evaluation is announced as high according to the information given by international authorities and after gaining confirmation from the National Security Council,  With regard to foreign correspondent accounts,  When extending private banking services,  When extending basic services to PEPs,  When conducting unusual transactions or patterns without any particular legal and economic purposes.

7- Risk-based Approach in AML In this approach, banks are obliged to initiate business relations with customers after passing complete KYC procedures through holding training courses for the bank’s personnel , implementing customers’ effective KYC measures and obtaining information regarding the purpose of establishing relationship with Bank Refah Kargaran, the main types of activities, financial status, customers’ background, types of services, domicile, etc. Furthermore, customers’ risk evaluation is conducted based on some criteria such

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AML & CFT Policies and Procedures of Bank Refah Kargaran

as the customer’s background, occupation, wealth resources, asset and mainland of residence. It must be noted that according to article 11 of the instruction of “The manner of identifying Iranian credit institutions”, the personnel of the bank are exempted from extending any kind of basic services to the following entities:  Individuals who refrain from presenting information or required documents,  Unauthorized exchange companies (without license),  Individuals who are not permitted to open accounts due to judicial decisions ,  Iranian individuals without ID or national number. It is reiterated that the following entities are categorized as the bank’s high risk customers:  Nonprofit organizations, charity oriented organizations, investment and retirement Funds,  Exchange companies and non-financial occupations,  Applicants to open pooled and joint accounts,  Non present and non-resident customers ,  PEPs (Politically Exposed People), their family members and close associates,  SDN individuals who are announced as per note 2 of Article 16 of AML by-law.

8- Electronic money transfer and correspondent banking All included entities, Bank Refah Kargaran as well, are obliged to make necessary measures regarding international money transfers and must appropriately evaluate the risks in relation to money laundering and terrorism financing activities followed by conducting proper KYC procedures. Therefore, correspondent banks have to gather sufficient information prior to initiate any business in order to fully make sure of the nature of the business of the respondent bank. Money laundering and terrorism financing risks must be constantly evaluated. Establishing any correspondent banking relations with shell-banks is prohibited.

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AML & CFT Policies and Procedures of Bank Refah Kargaran

In line with making precautionary measures with regard to correspondent banking relations, Bank Refah Kargaran, collects and controls the following data prior to initiating any correspondent banking relations:  The structure of ownership, management, shareholders, etc. ,  Main domain of activity,  Country of domicile,  Internal directives and procedures of the correspondent bank with regard to AML/CFT principles,  Main reason of opening account,  The status of banking supervisions and regulations in that country,  Precautionary measures regarding banking services that leads to maintaining or transferring funds which are out of money laundering or terrorism financing activities,  Not establishing any correspondent banking relations with shell-banks or banks which have financial business with shell banks,  Reassuring that the correspondent bank is not located in high-risk regions regarding money laundering and terrorism financing,  Obtaining senior managers’ approval prior to establishing new correspondent banking relations,  Controlling the managers and shareholders of the correspondent bank with regard to the presence of PEPS in their structure,  The manner of identifying, controlling and extending services to PEPs as the bank’s customers,  The manner of controlling and supervising suspicious dealings and transactions,  Inclusion of any probable sanctions on the correspondent bank even during previous years,  Policies of the correspondent bank when opening accounts and when extending services to customers and with regard to high-risk accounts,  The manner of controlling and perusing SDN list and regional and international sanctions,

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AML & CFT Policies and Procedures of Bank Refah Kargaran

 The quality of rules and regulations the correspondent bank’ country in cooperation for providing correspondent banks with further details when the need arises, Executive units have to conduct all electronic inner-bank money transfers only through national payment infrastructures of the Central Bank of Iran such as SATNA, PAYA and SHETAB and must register all the records including the following information in related C.B.I. systems: The specifications of sender, receiver, SHAHAB number, SHEBA number, etc. 9- Cash Couriers Paying cash to individuals above the determined daily threshold is prohibited. In case customers insist on receiving funds in cash and above the determined threshold, executive units are obliged to report the issue to AML unit of the related organization. Furthermore, the authorized threshold for cash payments to customers is determined by the C.B.I. as per the situation and on periodic basis. Credit and financial institutions must upgrade their softwares in cash payment so that they include information on the type and nature of the cash provided to the customers and must ensure of not delivering any cash above the determined threshold. In the meantime, operators in branches are obliged to report any cash depositing to accounts above the determined threshold to the AML department as per the related directive. The AML department must report the issue to the FIU of the Central Bank of Iran. 10- Sanction policies Requirements for screening and supervising KYC procedures are considered as the Bank’s lawful commitments and all the staff must avoid rendering banking services to people or entities listed on local or international sanctions lists which are in connection with illegal or terrorism activities. Sanction lists include the specification of individuals or legal entities subject to UN Security Council resolution number 1267 and its subsequent resolutions and all other entities under I.R.I. sanctions which are determined as per National Security High Council according to AML/CFT law which are based on resolution number 1373 of UN Security Council. Accordingly, included entities 12

AML & CFT Policies and Procedures of Bank Refah Kargaran

such as Bank Refah Kargaran are bound to refrain from extending any banking services to these entities and must immediately apply specified limitations announced by the FIU for them. 11- The mechanism of Supervision on conducting policy document Precise implementation of current AML/CFT policies is supervised through annual and case inspections on operations performed by the Bank’s executive units as per the inspectors’ checking list. Obviously, AML liaisons in units (branches) have a remarkable role in implementing the policies and rendering proving documents and deeds to supervisory authorities in this regard. Furthermore, due to the compilation of AML/CFT policies and through benefiting from knowledgeable experts, effective measures have been made and are currently undergoing as well in order to reduce the risks pertaining to money laundering and terrorism financing and to clarify financial relations and to enhance the performance of the Bank in general, the personnel, the customers, the shareholders and the correspondent banks in particular. 12- Compliance with the AML Law By approving and advising AML/CFT law to the banking system, all financial and credit institutions are bound to implement the law, its bylaws and related instructions ratified by the High Council of AML. In this regard, Bank Refah Kargaran as one of the most active commercial banks in international banking has adopted a novel approach in order to meet such rules and to implement the following instructions: 1. Instruction on “ The manner of identifying Iranian customers of credit institutions” in 37 articles and 18 notes, 2. Instruction on “ The manner of reporting cash depositing above the determined threshold” in 11 articles and 2 notes, 3. Instruction on “ The manner of identifying suspicious transactions and the method of reporting” in 15 articles and 4 notes, 4. Instruction on “ The manner of determining the customer’s expected level of activity “ in 10 articles and 4 notes, 5. Instruction on “ Observance of AML rules in electronic payment systems” in 21 articles and 3 notes, 13

AML & CFT Policies and Procedures of Bank Refah Kargaran

6. Instruction on “ The necessity of observing AML rules in correspondent banking relations and identifying shell banks” in 6 articles and 4 notes, 7. Instruction on “ Controlling people under suspect in credit institutions” in 8 articles and 1note, 8. Instruction on “ The manner of sending the related documents and deeds of customers to their mailing address” in 12 articles and 6 notes, 9. Instruction on “ The required measures and adoptions in assuring the proper observance of AML rules in offshore/international units” in 44 articles and 1 note, 10. Instruction on “ The manner and the period of keeping commercial securities, documents and records approved by the Money and Credit Council on 14/06/2010 “ in 12 articles and 11 notes, 11. Instruction on “ The manner of exercising care and special attention while presenting base services to foreign PEPs in credit institutions” in 12 articles and 6 notes, 12. Instruction on “ The manner of identifying foreign customers of credit institutions” in 22 articles and 14 notes, 13. Executive Instruction of AML in foreign exchange companies in 20 articles and 14 notes, 14. Executive Instruction of opening deposit account in local (Rials) for foreigners in 17 articles and 3 notes, By implementing the current policy document, Bank Refah Kargaran is committed to obey national rules and regulations in AML/CFT as well as international standards and recommendations in order to combat money laundering and terrorism financing and must make proper decision when some actions are violating those above-mentioned rules and the bank’s internal policies. 13- Executive measures The performance of Bank Refah Kargaran in connection to AML and CFT is set up according to the country’s rules and regulations and all advised instructions from the C.B.I. as the regulator and supervisor of financial and credit institutions. The performance of Bank Refah Kargaran regarding AML/CFT:

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AML & CFT Policies and Procedures of Bank Refah Kargaran

1. Performing identity authentication of the customer, his lawyer, agent or guardian through valid documentation , reliable informative data and at last through inquiry from competent sources such as National Organization for Civil Registration and Real State Registration Organization of Iran, 2. Conducting continuous supervision on accounts with higher risk, 3. Refraining from opening accounts for individuals for whom the action is not permitted, 4. Refraining from opening accounts with no names, 5. Refraining from establishing any correspondent banking relations with shell banks, 6. Conducting continuous control on suspicious persons’ accounts and the black list, 7. Reporting cash depositing above the determined threshold and suspicious transactions to FIU, 8. Holding general training courses for all the bank’s personnel while keeping their records, 9. Holding specialized training courses for staff occupied in AML/CFT department while keeping their records, 10. Conducting internal controls based on AML/CFT rules, 11. Keeping and maintaining customers’ information while preserving their secrecy and preventing from their disclosure or unauthorized use, 12. Refraining from conducting any electronic which is un- traceable or without name, 13. Obtaining commitments from the customers when presenting basic services to non-financial occupations regarding implementation of AML/CFT rules, 14. Exercising care and control on individuals and institutes whose names are listed in connection to money laundering or terrorism financing crimes, 15. Obtaining commitments from the customers applying for receiving base services regarding the observance of AML/CFT rules, 16. Designing proper forms and suitable softwares for inserting one of valid ID numbers of the customers, 17. Applying necessary measures for proper maintaining and processing of the information,

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AML & CFT Policies and Procedures of Bank Refah Kargaran

18. Assigning a liaison in each branch for supervising the proper implementation of AML/CFT rules and regulations, 19. Assuming essential measures of prudence (such as payment card) after full identification of the customer and complied registration of ID specifications with the specifications existing in the tool, 20. Adopting risk-based approach according to the customer’s identifications while conducting simple identifying procedures for walk-in customers, performing regular identification procedures for customers receiving basic services and conducting due diligence and EDD for high risk customers.

14- Seizure and temporary measures With the help and cooperation of executive officers in Justice and Judicial powers, the FIU adopts a mechanism in which the sanction or seizure list is updated immediately after the order is issued and this is announced to the AML unit or responsible senior officials systematically. Therefore, all illegible entities including Bank Refah Kargaran are obliged to organize and enhance their infrastructures and systems open and sensitive to any changes regarding the seizure of wealth or its temporary blocking. This must be reported to the FIU and after the instruction of the FIU on obstruction of the properties, the list must be prepared including detailed divided items and necessary measures must be made within 24 hours. 15- Reporting As per their type of activity and organizational structure, all the branches of the bank are obliged to report any suspicious act or transaction related to money laundering or financing terrorism to AML/CFT department without prior notice to the customer. Subsequently, the related department reports the issue to FIU after primitive investigation and as per the announced mechanism. In the meantime, along with the mentioned primitive inspections while rendering services or conducting a transaction, identification of suspicious dealings and transactions must be done through complying the existing information with the same in data bases. 15-1- Suspicious Transaction Report (STR)

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AML & CFT Policies and Procedures of Bank Refah Kargaran

All the employees in the bank’s departments and branches are bound to give a report upon observing any suspicious banking transactions and operations which are in connection with money laundering or terrorism financing acts according to AML/CFT rules and regulations and the instruction on identifying suspicious transactions. These reports are confidentially sent to FIU for further investigations if suspicious financial relations are detected. In the meantime, based on article (27) of the executive by-law of AML, suspicious transaction report as well as any other probable necessary reports does not bear any accusation to these individuals and the announcement of the issue to FIU is not considered as the disclosure of their personal secret. According to circular number 91/161337 dd. 13/09/2012 of the C.B.I., Bank Refah Kargaran’s AML software is implemented within the bank and all suspicious transactions of customers are thus controlled. While conducting continuous control on suspicious financial relations, the AML/CFT department of Bank Refah Kargaran makes the following measures:  Investigating the reports received from the branches and the AML software,  Controlling the suspicious individuals,  Conducting periodic inspections (either in-person or remotely) in order to control the method of implementing AML/CFT rules. 15-2- Currency Transaction Report (CTR) above the determined threshold According to the instruction of the Central Bank of Iran on the method of reporting any cash transaction over the determined threshold, CTR is sent on a mechanized basis to the AML department and after their compilation the issue is reported to the FIU. According to note 3 under article 4 of the AML law, all the by-laws ratified by the supreme council of AML (including all customers’ identification procedures and the methods of reporting) are obligatory to execute and violators are condemned to a two to five-year dismissal from service as per administrative and judicial discretion. 16- Non-Financial jobs and occupations, non-profit organizations and charities

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AML & CFT Policies and Procedures of Bank Refah Kargaran

Bank Refah Kargaran and all the related units are bound to make counter measures in order to prevent the actions in connection with money laundering or terrorism financing which may be conducted by non-profit organizations or charities. Furthermore, necessary arrangements must be done to prevent individuals and terrorist groups from finding a means of escape from rules and regulations supervising the blocking of properties. Examples of non-financial occupations can be the following:  Exchange companies,  Real estate agents,  Car dealers,  Sellers of , silver and coins ,  Sellers of precious metals and stones ,  Sellers of carpet and price boards.

17- Record keeping Bank Refah Kargaran and all its executive units must maintain and keep the records of all documents, papers and records for business transactions for ten years in a way that upon their calling from the competent authorities, the records can be provided immediately. Documents, deeds and records pertaining to this article include the following items:  All documents and records related to the KYC procedures including the basic, regular and double identification as well as the copy of ID documents which prove the real identity of the customer and the exact beneficial owner,  All documents and records related to accounts and commercial correspondences,  All documents and records for financial dealings and transactions being either local or international.

18- Guidelines and Training Bank Refah Kargaran makes necessary measures to hold OJT courses for the bank’s employees. These training courses are designed to present information of AML/CFT

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AML & CFT Policies and Procedures of Bank Refah Kargaran

rules and regulations, related by-laws, latest tricky actions of money launderers and terrorists and their methods on eliminating the criminal source of funds. All personnel of the bank must pass the related training courses regarding the methods of identifying customers, controlling the ID documents (ID card, passport, national card, etc.) and their compliance with competent sources such as National Organization for Civil Registration and Real State Registration Organization of Iran. Obviously, the employees in AML/CFT department of the bank are obliged to participate in the training courses held by the FIU of the Central Bank of Iran and other local or international entities and must enhance their level of professional knowledge. 19- Other According to article 5 of the AML law, implementing AML law is obligatory for all the included entities including the banks and violators are condemned by the decision of relevant authorities according to the law of administrative violations as the case may be. All executive entities are bound to make lawful measures against the violators within their authorities and report the issue to judiciary or non-judiciary sources. Furthermore, all included people, Bank Refah Kargaran as well, are bound to present information required by special executive officers based on judicial orders related to AML/CFT in the framework of announced criteria by the FIU and with their cooperation.

2020

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