Anti-Money Laundering (AML) Policy of BRICS Bank SA

Valid from August 7, 2024

Policy Statement
BRICS Bank SA is committed to the highest standards of anti-money laundering (AML) compliance and combating the financing of terrorism (CFT). The Bank is dedicated to preventing the use of its products and services for money laundering or terrorist financing purposes.

Purpose
The purpose of this policy is to establish a framework for detecting, preventing, and reporting money laundering and terrorist financing activities. This policy ensures compliance with all applicable AML laws and regulations.

Scope
This policy applies to all employees, directors, officers, and third parties acting on behalf of BRICS Bank SA. It covers all products, services, and transactions, regardless of the business unit or geographic location.

Definitions
- Money Laundering: The process of concealing the origins of illegally obtained money, typically by passing it through a complex sequence of banking transfers or commercial transactions.
- Terrorist Financing: The provision of funds or financial support to individual terrorists or terrorist groups.

Policy Requirements

1. Customer Due Diligence (CDD):
- The Bank will conduct thorough due diligence on all customers to verify their identity and assess the risk of money laundering or terrorist financing.
- Enhanced due diligence is required for high-risk customers, including politically exposed persons (PEPs).

2. Transaction Monitoring:
- The Bank will implement robust systems to monitor transactions for suspicious activity.
- Unusual or suspicious transactions will be investigated and reported to the relevant authorities.

3. Record Keeping:
- The Bank will maintain comprehensive records of all transactions and customer identification information for a minimum period as required by law.
- Records must be readily accessible for inspection by regulatory authorities.

4. Reporting Obligations:
- Employees must report any suspicious activity or transactions to the Bank's designated AML Compliance Officer.
- The Bank will report suspicious activities to the appropriate regulatory authorities in a timely manner.

5. Training and Awareness:
- The Bank will provide regular training to employees on AML and CFT obligations, including how to recognize and report suspicious activities.
- Training will be updated to reflect changes in laws, regulations, and industry best practices.

6. Risk Assessment:
- The Bank will conduct regular risk assessments to identify and mitigate potential money laundering and terrorist financing risks.
- Risk assessments will be reviewed and updated periodically.

Roles and Responsibilities
- The Board of Directors is responsible for ensuring the effectiveness of the AML framework.
- The AML Compliance Officer is responsible for implementing and overseeing the Bank's AML program.

Monitoring and Review
- The Bank will conduct regular audits and reviews of its AML program to ensure its effectiveness and compliance with legal requirements.
- The policy will be reviewed annually or as necessary to ensure it remains current and effective.

This Anti-Money Laundering Policy demonstrates BRICS Bank SA's commitment to preventing money laundering and terrorist financing, ensuring compliance with all applicable laws and regulations, and maintaining the integrity of the financial system.