Prevention of Money Laundering
Česká exportní banka, a.s. (hereinafter referred to as “CEB”) in accordance with legal regulations
- Act No. 253/2008 Sb., on Selected Measures against the Legitimisation of the Proceeds of Crime and Financing of Terrorism (hereinafter referred to as the “AML Act”),
- Act No. 69/2006 Sb., on Carrying Out of International Sanctions,
- CNB Decree No. 67/2018 Sb., on Certain Requirements for the System of Internal Principles, Procedures and Control Measures against the Legitimisation of the Proceeds of Crime and Financing of Terrorism,
- Government Regulation No. 210/2008 Sb., on the Implementation of Special Measures to Combat Terrorism,
adopted Procedures to Prevent Money Laundering and Financing of Terrorism in the conditions of CEB (hereinafter referred to as “the Procedures"), which are the basic internal document in the field of preventing and combating money laundering and financing of terrorism. The Procedures are also aimed at detecting money laundering and financing of terrorism. The Procedures are regularly updated and thus reflect the overall development of the issue in the market with a focus on export financing. The Procedures are defined with regard to the fact that CEB does not have any branches or carry out cash transactions.
The Procedures are approved by the CEB´s Board of Directors.
With regard to its mission, CEB provides its products to legal persons and identifies and controls these persons, including statutory bodies, in accordance with the AML Act. Inspection dates take place depending on the client's risk category. CEB also examines members of statutory bodies to ensure that they are not politically exposed persons. At the same time, clients are verified against relevant sanction lists. CEB also examines the management and ownership structure of the client.
CEB regularly, once a year, updates its Risk Assessment, and in the event of changes, the Risk Assessment is updated as necessary. Risk factors include risk activities defined by CEB and countries on the EU and FATF lists.
Client identification data are stored for a period of 10 years from the date of termination of the transaction or business relationship. Confidentiality is observed in accordance with the relevant provisions of Act No. 21/1992 Sb., the Act on Banks, and the GDPR Regulation.
Suspicious transactions are reported to the Financial Analytical Office in accordance with the Procedures and the AML Act.
All CEB employees are trained to prevent money laundering and financing of terrorism, upon starting their employment at CEB and regularly once a year.
Control activities in the area of prevention of money laundering and financing of terrorism are provided by the Compliance Department on the basis of the Control Plan, which is part of the Compliance Performance Plan approved by the Board of Directors on an annual basis. The Compliance Department also performs ad hoc inspections in the area of AML issues, and regularly, twice a month, monitors legislation concerning CEB's activities.