Global Financial Crimes Policy Statement
Financial Crimes Risk Management Overview
MUFG Bank's Approach to Financial Crimes Risk Management
GFCD has issued global policies for managing financial crimes risk consistently within and across business lines, support functions, and legal entities throughout its worldwide operations.
Our people play an important role in the fight against financial crimes. All employees are responsible for complying with the Bank's financial crimes compliance policies, asking questions, and escalating concerns, including seeking advice from a supervisor, Compliance Officer, or through our anonymous reporting channels. The Bank prohibits retaliation against anyone who raises concerns in good faith.
Led by financial crimes compliance specialists, GFCD's global departments address the three financial crimes risk areas – Anti-Money Laundering ("AML")/Countering the Financing of Terrorism ("CFT"), Sanctions, and Anti-Bribery and Corruption ("ABC"). The Policy Statements for each of the three global financial crimes departments are here:
AML/CFT Policy Statement
Specifically, the Bank's Global AML/CFT Policy, which is made available to all employees, prohibits:
- Knowingly facilitating or participating in any financial crimes activity or any activity that facilitates financial crimes (e.g., money laundering and financing of criminal activities);
- Ignoring information or circumstances that may be indicative of financial crimes;
- Informing any person known to be involved or suspected of being involved in illegal or suspicious activity that such activity is being investigated or reported internally and/or to law enforcement authorities and regulatory agencies (known as "tipping off");
- Allowing a new customer to transact (other than initial deposit) prior to completion of the know your-customer ("KYC") process;1 or
- On-boarding a prohibited customer type, without appropriate exception or exemption.
- Designated persons responsible for the implementation and monitoring of the program, including a Global Head of AML/CFT and dedicated AML/CFT officers in each country of operation;
- Annual AML/CFT risk assessments covering the Bank's customers, products and services, and geographies and related controls;
- KYC processes that require identification and appropriate verification of customer identities (including identification of ultimate beneficial owners), customer screening, customer due diligence, enhanced due diligence, customer acceptance/rejection, and customer reviews;
- Transaction monitoring systems and processes designed to detect unusual and potentially suspicious activity;
- Investigation processes to identify and report suspicious activity in compliance with the regulations in each of the jurisdictions in which the Bank operates;
- Prohibitions on relationships with certain customer types, including a prohibition on relationships with shell banks;
- AML/CFT information-sharing and record keeping processes; and
- Annual all-employee training on applicable AML/CFT risks and controls (e.g., policy and procedure requirements).
- Per internal procedures, in limited circumstances, on-boarding units may request a temporary extension to complete the KYC process or an exemption.
Sanctions Policy Statement
The Bank's Global Sanctions Policy, which is made available to all employees, prohibits the funding of accounts and the processing of payments for, on behalf of, or for the benefit of, sanctions targets or jurisdictions in violation of applicable sanctions consistent with local law. MUFG Bank has established a global sanctions compliance program, including the following control processes:
- Sanctions screening and reviews with respect to customer on-boarding and processing of transactions;
- Annual assessments of sanctions risks and controls;
- Due diligence of customers with potential sanctions exposure; and
- Annual all-employee training on applicable sanctions risks and controls (e.g., policy and procedure requirements).
ABC Policy Statement
The Bank's Global ABC Policy, which is made available to all employees, comprehensively addresses the key concepts of bribery and corruption and prohibits offering, giving, soliciting, or receiving, directly or indirectly, anything of value to or from anyone in exchange for an improper business benefit or advantage. The Policy also prohibits facilitation payments and falsifying books, records, and accounts relating to the Bank's business activities.
Consistent with the Bank's Global ABC Policy, the Bank has established a global ABC compliance program including the following control processes, which comprehensively address bribery and corruption:
- Annual assessment of bribery and corruption risks and controls;
- Procedures covering due diligence and oversight of third-party service providers who act on the Bank's behalf (i.e., intermediaries), including risk-based ABC assessment and training of intermediaries, and communication to intermediaries of MUFG Bank’s ABC expectations as covered in the Bank’s Global ABC Policy;
- Review of gifts and hospitality, offers of employment/work experience, and charitable donations, particularly activities involving public officials;
- Evaluation and management of risks associated with business transactions, including mergers and acquisitions; and
- Annual all-employee training on applicable bribery and corruption risks and controls (e.g., a comprehensive review of key concepts of bribery and corruption, including different elements/types, and policy and procedure requirements).
Additional Program Elements
In addition to global compliance programs for each risk area, GFCD has centralized core functions that are applicable to all three programs, including employee training, risk assessment, record keeping/retention, monitoring and reporting to governing bodies (e.g., board- and management-level committees), testing and audit management functions, and management of identified financial crimes compliance issues.