Lebanese Canadian Bank, SAL may be used unwittingly as intermediaries in a process to conceal the true source of funds that were originally derived from criminal activity. This is referred to as money laundering. Even unintentional involvement in any criminal activity is of a great concern to the Lebanese Canadian Bank, SAL management and shareholders since the public’s confidence in the institution may be undermined through such activity.

This policy statement is intended to guard against Lebanese Canadian Bank, SAL’s unintentional involvement in any criminal activity, and to restate the bank’s policy of cooperation with law enforcement and regulatory agencies.

With a view to ensuring, that the financial system is not used as a channel for criminal funds, managers and their subordinates should continue to make reasonable efforts to determine the true identity of all customers and beneficial owners that request Lebanese Canadian Bank, SAL products and services. Significant business transactions will not be conducted with customers who fail to provide evidence of their identity.

Lebanese Canadian Bank, SAL will continue to conduct its business in conformity with high ethical standards in the countries in which it does business, and to fully adhere to all laws and regulations pertaining to financial institutions. While it is accepted that the bank may not be always be able to determine whether a transaction originates from, or is a part of, a criminal activity. Lebanese Canadian Bank, SAL shall conduct its business in compliance with the following general principles:

• Will exercise reasonable steps to determine the true identity of all customers and beneficial owners of Lebanese Canadian Bank, SAL products and services. Shall not knowingly accept funds from, make loans to, or do any type of business. Will not ignore indications that costumer’s money originated from criminal or other money laundering activities. when Lebanese Canadian Bank, SAL becomes aware of facts which lead to a reasonable presumption that funds held by it are from criminal or other money laundering activity or that transactions entered into are themselves criminal in purpose, appropriate measures, consistent the law, shall be taken, including, for example, denial of assistance to the customer, severing relations with the customer, closing or freezing accounts and when appropriate filing of a suspicious activity report. Will continue to avoid providing support or assistance to customers seeking to deceive law enforcement agencies through the provision of false, altered, incomplete or missing information. Undertake to cooperate fully with law enforcement and regulatory agencies through the extent that it can do so under all applicable laws and regulations.
• To make sure to report all identified instances of suspicious activity to the Special Investigation Commission Fighting Money Laundering.

All Lebanese Canadian Bank, SAL branches wherever located, are to be informed of this Policy Statement, and attention will be given to establishing standard procedures and to set training seminars and workshops for branches and departments’ staff members in matters covered by this policy, as appropriate.

It is vital for all Lebanese Canadian Bank, SAL branches and foreign offices to fully understand those actions that may be violation of applicable anti-money laundering statutes, and to report any potential violation in the manner set forth in the appropriate Anti-Money Laundering (AML) compliance manual.

Actions such as structuring transactions to avoid AML reporting requirements, failing to prepare or file required AML reports, prepare inaccurate reports, money laundering, attempted money laundering laws. All requirements of anti-money laundering compliance apply to branches network in the performance of their daily responsibilities.

Each manager should make reasonable attempts to ensure that all subordinates in his or her area are fully informed regarding this Policy. Complete details are available through the AML compliance manual guide located in each banking center, in other areas throughout the bank, or from the AML compliance Unit.

There are three categories of action to be aware of:

• Intentional non-compliance Willful blindness
• Negligence

The bank will not cause or tolerate any violation of law 318 dated April 20, 2001 or the Central Bank of Lebanon basic circular number 83 (and its modifications) in the conduct of its business or related activities.

Any Lebanese Canadian Bank, SAL staff member who violates any applicable AML law or regulation under any of these conditions will be subject to disciplinary action, up to and including termination.

Also, if a Lebanese CanadianBank, SAL staff member intentionally violates any applicable AML law or regulation, this shall be reported to the Special Investigation Commission Fighting Money Laundering and law enforcement officials in accordance with local laws and regulations.

 

.
Georges Zard Abou Jaoudé
Chairman - General Manager
President Special Committer Money Laundering Prevention