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AML/CTF, ABC, Combating Proliferation Financing & Sanctions Compliance Declaration

I&C has made it a priority to combat money laundering, terrorist financing, corruption, proliferation financing, and sanctions evasion.

AML/CTF Compliance

The Bank is committed to the highest standards of anti-money laundering (“AML”) and Counter-Terrorism Financing (“CTF”) compliance and requires management and employees to adhere to these standards to prevent use of its products and services for money laundering, terrorism financing, or sanctions circumvention purposes.
It is the policy of I&C to prohibit and actively prevent any activity that facilitates money laundering, or the funding of terrorist or criminal activities by complying with international standards and all applicable requirements under Lebanese Law No. 44 of November 24, 2015, relating to Fighting Money Laundering and Terrorism Financing, and its implementing regulations.

In light of our changing environment, Investment & Capital Bank continually evaluates the strength and relevance of its existing policies, procedures and employee training programs and, if necessary, updates them to address changes and new risks.
The Bank’s AML/CTF policies and procedures are detailed in a dedicated manual approved by the board of directors.

Investment & Capital Bank has a designated officer responsible for coordinating and overseeing the AML/CTF and Sanctions framework. I&C’s AML/CTF Compliance Person has a deep working knowledge and experience in AML/CTF, is qualified by experience, knowledge and training, and is a Certified Anti-Money Laundering Specialist, Financial Crimes Investigator, and a Certified Global Sanctions Specialist

• Proper Know-Your-Customer (KYC) practices are central, and knowing the customer provides a basis for understanding the general activities in which a customer usually would be expected to engage.
• Investment & Capital Bank developed written policies documenting the processes in place to prevent, detect and report suspicious transactions.
• Investment & Capital Bank has a policy prohibiting accounts/relationships with shell banks.
• Investment & Capital Bank has policies covering relationships with Politically Exposed Persons (PEP), their families and close associates.
• Investment & Capital Bank has a risk-based assessment of its customers and their transactions.

All customers are screened against the Special Investigation Commission (SIC) list, and international lists through Refinitiv/WorldCheck One.

Sanctions Compliance

I&C is fully informed of the laws and regulations governing its correspondents abroad and deals with them in compliance with such laws and regulations. I&C is committed to abiding by the laws, regulations, procedures, sanctions and restrictions adopted by international legal organizations and/or by the sovereign authorities in the correspondents’ home countries.

I&C does not deal with or facilitate transactions or provide financial services to entities designated as terrorist or criminal organizations, or blacklisted by local authorities, international organizations and sovereign authorities in countries where it maintains correspondent accounts or conducts any other activity. Furthermore, I&C does not deal with or facilitate transactions or provide financial services to a person if it has any suspicion that this person is acting on behalf of, or is owned or controlled by such designated entities and refrains from facilitating transactions or providing financial services if it suspects that such transactions or financial services are linked to such designated entities or any criminal and/or terrorist activity.

I&C is therefore, committed to respecting and abiding by international sanctions notably those issued by the United Nations’ Security Council, the US Office of Foreign Assets Control and the European Union; and has the relevant tools and measures in place to make sure its services are not used for sanctions ‘evasion.

Anti-Bribery and Corruption (“ABC”)

I&C is committed to conducting business in an ethical and legal manner, and is committed to implementing and enforcing systems that ensure bribery and corruption, whether in the public or the private sector, are prevented. I&C has zero-tolerance for bribery and corruption activities.
I&C will constantly abide by all local and international laws and regulations relating to anti-bribery and corruption in all the jurisdictions in which it operates, and will comply with all sanctions related to this matter such as those issued by virtue of the US Magnitsky Act.
Furthermore, bribery and corruption being money-laundering predicate offenses, the AML/CFT team includes an anti-bribery and corruption assessment in their customer due diligence and all due diligence conducted over third parties, business partners and all transactions and related parties in general.

I&C does not accept and will not facilitate payments of any nature when it suspects they involve bribery or corruption.
I&C also has a thorough code of conduct and detailed policies and procedures relating to conflicts of interest, gifts and business entertainment, hiring, whistleblowing… These policies and procedures apply to all employees, consultants, trainees, or any other person associated with I&C and its subsidiaries.

Combating Proliferation of Nuclear Weapons Financing

Proliferation financing refers to the act of providing funds or financial services which are used, in whole or in part, for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both technologies and dual use goods used for non-legitimate purposes), in contravention of national laws or, where applicable, international obligations.

I&C has taken effective measures to fight the financing of weapons proliferation by prohibiting the provision of financial services for the development of weapons and their means of delivery.

I&C has also committed to:

• providing financial investigative support to existing counter proliferation investigation systems,
• hindering the financial activities of proliferators, to the extent possible,
• contributing to the identification and disruption of proliferation networks, to any possible extent.