TBC Bank is committed to high standards of anti-money laundering/counter terrorist financing (AML/CTF) and requires all TBC group companies, management and employees to adhere to these standards in order to prevent the use of TBC's products and services for money laundering/terrorist financing purposes. Implemented AML/CTF compliance program comprises written policies, procedures, internal controls and systems including but not limited to: 

  • The identification of potential AML/CTF risks relevant to each bank's activities.
  • Global and local AML/CTF policies and procedures to ensure compliance with AML laws and regulations.
  • Customer identification and verification ( including  beneficial owners)
  • Rules regarding transactions of Politically Exposed Persons  (PEPs)
  • Enhanced due diligence of  increased risk clients
  • Internal procedures for monitoring and reporting suspicious activities of the Bank's customers
  • Customer screening against global list of terrorists and specially designated nationalities, relevant financial and other sanctions lists
  • Maintenance of relevant records
  • Regular staff training and awareness raising
  • Management of regulatory inquiries and incidents
  • Coordinating day-to-day compliance by responsible compliance staff

 

Standards set out in the internal AML/CTF policy are based on applicable legal and regulatory requirements to prevent TBC Bank and its clients from money laundering, terrorist financing or other fraudulent activities.

 

TBC Bank conducts its business in compliance with the following general principles:

Know Your Client and Customer Identification procedures

KYC procedures include the following key elements: customer identification, customer acceptance policy, risk management and permanent monitoring of high risk clients' accounts. Prior to executing any type of business, the Bank determines and documents the true identity of customers and obtains information about the purpose and real nature of the business. The Bank obtains and documents any additional information, appropriate to the assessment of the money laundering risk with a risk-sensitive approach.

 

TBC Bank clarifies whether the customer is acting on behalf of third party or legal entity as trustee or intermediary. In such cases, the Bank obtains satisfactory evidence about the identity of any intermediaries and of the persons upon whose behalf they are acting, as well as the nature of the trust measures in place. 

 

KYC procedures are always complied with when customers open accounts and establish a new business relationship. The Bank's AML/CTF and KYC procedures are conducted on a risk-based approach. Consequently, anonymous accounts are not opened in the Bank.

 

TBC Bank has an automated controlling system in place whereby the Bank, constantly monitors private individuals and legal entities against global watch lists. 

 

Correspondent Banking Relationship

The Bank does not have correspondent relations with "shell-banks".

The Bank always determines the reputation of correspondent institutions, including whether they have been subject to money laundering or terrorist financing investigations or other regulatory actions/sanctions. 

 

Monitoring and Reporting of Suspicious Transactions and Activities

In accordance with the requirements of the law of Georgia on Facilitating the Prevention of Illicit Income Legalization, TBC Bank implements and maintains measures for handling suspicious transactions. The Bank considers indications that a customer's money originated from unlawful activities or other money laundering activities and reports all identified instances of suspicious activities to the relevant authorities.

 

The Bank avoids providing support or assistance to parties seeking to deceive law enforcement authorities through the provision of false, altered, incomplete or missing information.

 

Reporting of suspicious transactions/activities complies with the law of Georgia on Facilitating the Prevention of Illicit Income Legalization, with the Order N 4 of the Head of Financial Monitoring Service of Georgia on Receiving, Systemizing and Processing the Information by Commercial Banks and with other normative acts and regulations. Accordingly, all the staff is diligent in monitoring of any unusual or suspicious transactions/activities based on the relevant applicable criteria. 

 

All employees of TBC Bank who come into a direct or indirect contact with customers are trained to deal with and respond to transactions that raise suspicion of money laundering or financing of terrorism.

 

Record and Document Keeping

Records of all documents obtained for the purpose of identification and all transaction data, as well as other documents are kept electronically for at least 15 years.

 

If you have any questions or require additional information regarding TBC Bank's Anti- Money Laundering efforts, please contact:

 

FMS@tbcbank.com.ge
Chief Compliance Officer
JSC TBC Bank

 
FATCA Disclosure
JSC TBC Bank and its subsidiary FFIs were registered with the IRS to be FATCA compliant on 2nd of May, 2014.  The FATCA regulations require JSC TBC Bank to review existing onboarding and withholding processes and enhance them accordingly with the regulations, where required. JSC TBC Bank must collect and verify appropriate client information, then report to local government authorities that have entered into intergovernmental agreements.
 
GIIN assigned to JSC TBC Bank is the following: YWY4EU.00000.LE.268.
 
JSC TBC Bank is proactively implementing changes to its current business in order to comply with FATCA regulations while best serving its clients and counterparties.
 
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