Anti-Money Laundering and Terrorist Financing Policy

Al-Amal Microfinance Bank is committed to combat money laundering and terrorist financing activities in accordance with the regulations and legislation issued by the Central Bank of Yemen, and in line with international best practices in place to counter money laundering and stop terrorist financing. AMB is fully prepared to disclose suspicious activities related to money laundering, including tax evasion, financial fraud and terrorist financing, as well as reporting to the Central Bank in line with regulations. We are moving forward in our unremitting endeavors to conduct our business in accordance with the highest levels of transparency, reliability, integrity and security, through an absolute compliance with all applicable laws and regulations. Based on the foregoing, AMB has adopted the best anti-money laundering practices in its all branches in the Republic of Yemen, backed by its advanced infrastructure and advanced software, which ensures full and continuous compliance with anti-money laundering and terrorist financing policies.

AMB continues to be in full compliance with local laws and regulations, which reflect the relevant recommendations issued by the Financial Action Task Force (FATF) and the Basel Statement of Principles issued by the Basel Committee on preventing the banking system from being used for criminal purposes.

AMB is keen to continue to detect financial violations, support anti-money laundering measures, and strengthen the necessary periodic and continuous oversight, through the implementation of an internal and external audit program.

Al-Amal Microfinance Bank is committed to implementing an effective program to combat money laundering and terrorist financing, according to four main pillars as follows:

– Develop relevant internal policies and procedures.

– Appointment of an officer responsible for the compliance function.

– Provide a comprehensive and continuous training program.

– Conduct an independent audit for the compliance program.

Customer Identity Verification (KYC)

At Al-Amal Microfinance Bank, we adopt advanced mechanisms to verify the identity of the client in accordance with the regulations for combating money laundering and terrorist financing, which are followed locally and internationally, no matter how much amount is involved in the transaction.

We are also committed to implementing strict Know Your Customer (KYC) and Know your Customer’s Customer (KYCC) policies at all levels. The application of “Customer Due Diligence (CDD) and Enhanced Customer Due Diligence (EDD) procedures”  when necessary a routine process for us at AMB to identify and report any form of money laundering in accordance with the legal framework.

Customer Due Diligence (CDD) Procedures

 As part of the Customer Due Diligence (CDD) process, we require all customer specific details to ensure that their transactions are completed in line with their business profile and activities. Our main focus has always been to ensure the legitimacy of the funding sources and the purpose of the financial transaction

Know Your Customer / Enhanced Due Diligence (EDD) Procedures

The enhanced KYC/Customer Duty Verification procedures are part of the additional procedures to learn more about customers , sources of funds and to ensure that the transactions carried out by him are within his capabilities, in addition to verifying the legitimacy of the funds and not related to any criminal or suspicious activities, by obtaining More original client documentation, which must support both the primary and  clear objectives .

The risk-based approach is one of the most important pillars on which Al-Amal Microfinance Bank relies, in order to identify and eliminate potential risks, and therefore the employees take due diligence in verifying the identity of customers, compulsorily on all high-risk accounts.

Report unusual/potentially suspicious financial transactions:

All staff is fully trained and equipped to report any unusual or suspicious transaction by informing the compliance officer through a range of well-developed internal channels, which in turn conducts a comprehensive investigation and takes all necessary procedures and measures before informing the Financial Information Unit ( FIU )in the Central Bank of Yemen about this transaction.

Employee training:

At Al-Amal Microfinance Bank, we believe in the importance of empowering our employees at all levels. Anti-money laundering training helps the bank develop compliance management within its various internal levels. New employees are trained on anti-money laundering and terrorist financing procedures within thirty (30) days from the date of their joining the Bank, provided that the training is followed up on an annual basis. This training includes all employees who are in direct contact with customers, or who are authorized to carry out cash and non-cash transfer transactions.

Internal Security Measures – Know Your Employees

The process of hiring employees has become more accurate and strict, as the Human Resources Department verifies the validity authenticity of  the documents submitted by the applicant before completing the process.

Record keeping and confidentiality.

All records, documents, and information related to Customer , in addition to financial transaction data and other related documents, are kept for a period of no less than 5 years, in line with the laws of the Central Bank of Yemen. Al-Amal Microfinance Bank maintains the confidentiality of the information provided by Customer , including records of their transfers.

Independent Audit of the Compliance and Anti-Money Laundering Unit

The Compliance Unit is subject to independent reviews by the Internal Audit Department, which acts as a third line of defense, and by the Central Bank of Yemen staff and independent external auditors to ensure continuous updating of the compliance program and its compatibility with the organizational risk management.

The most prominent tasks and priorities of the Compliance Unit in the bank in the field of combating money laundering and terrorist financing are as follows:

• Cooperating with internal departments in updating and developing procedures and standards for controlling suspected cases.
• Follow up the decisions / instructions issued by the relevant internal and international government agencies, and ensure that the concerned branches and departments adhere to the relevant regulations for combating money laundering.
• Monitoring outgoing / incoming foreign transfers, and taking the necessary measures in this regard in coordination with the relevant departments and branches.
• Work on finding an automated system that serves anti-money laundering procedures and assists in classifying customers according to risks.
• Preparing a questionnaire (AML Questionnaire) for Know Your Customer, and sending it to the foreign banks that the bank deals with.
• Responding to correspondent bank inquiries related to:

1. •   (AML/CTF Internal Policies)

• •  (Customer Due Diligence)
  •  (Know Your Customer)
  • (Risk Assessment)
  • (Transaction Monitoring)
• Coordinating with the Department of Financial Institutions with regard to opening accounts for foreign banks with the bank and vice versa, to ensure that no accounts are opened except after referring to the Anti-Money Laundering Unit to complete verification procedures for these banks in accordance with the principle of knowing your customer.
• Coordinating with the Remittance Department in responding to foreign banks’ inquiries about correspondence and data related to remittances before preparing responses in this regard.
• Coordinating with the Control and Internal Audit Department to take the necessary measures to correct deficiencies in applying the controls and instructions of the internal regulations to combat money laundering in the bank’s branches in the governorates.