Sample using dark blue

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Anti-Money Laundering Policies and Procedures
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Domicile and Organization

• Turkey is one of the 33 member countries of the
  FATF
• Turkey is internationally recognised as having
  adequate anti-money laundering standards since
  September 24, 1991, on the date of which Turkey
  became a FATF member.
• Turkish banks are subject to regulatory
  supervision by many external and internal
  authorities such as
• Ministry of Finance Inspectors
• Internal Auditors
• Revenue Controllers
• Sworn-in Bank Auditors
• Capital Market Board Experts
• Independent Auditors
• Central Bank Auditors

3
Milestones for Turkeys Combat with Money
Laundering

• September 24, 1991 Joined the FATF (Financial
  Action Task Force)
• November 22, 1995 Ratified the Vienna
  Convention (UN Convention against Illicit Traffic
  in Narcotic Drugs and Psychotropic Substances
  dated December 12,1988)
• September 4, 1996 Banks are required to make
  Customer Identification
• November 19, 1996 Enactment of Law No. 4208 on
  the prevention of Money Laundering

4
Milestones for Turkeys Combat with Money
Laundering

• February 17, 1997 Financial Crimes
  Investigation Board (MASAK), Turkish Financial
  Intelligence Unit, has been established
  (www.masak.gov.tr).
• July 2, 1997 Regulations on Law No. 4208 (Reg.1
  Customer Identification, Reg.2 Suspicious
  Transactions) and regulations on the Coordination
  Board for Combating Financial Crimes have been
  promulgated.
• June 1998 Turkey has joined the EGMONT Group,
  (co-operation between Financial Intelligence
  Units of 101 countries to combat money laundering)

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Milestones for Turkeys Combat with Money
Laundering

• May 26, 1999 A convention has been signed
  between Turkey, Greece, Albania, Bosnia
  Herzegovina, Bulgaria, Hungary, Macedonia,
  Moldavia, and Romania to fight against crimes
  committed overseas.
• February 1, 2000 Changes made on Regulations on
  Law No. 4208. MASAK has required Banks to include
  Anti Money Laundering Supervision in their
  Internal Audit Programs as well as to appoint
  compliance officers.

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Milestones for Turkeys Combat with Money
Laundering

• September 27, 2001 United Nations
  International Agreement for Preventing Terrorist
  Financing was signed by Turkey.
• January 10, 2002 - International Agreement of the
  Anti-Terrorist Financing on Law No 4738 was
  accepted.
• June 18, 2003 FATFs 40 Recommendations were
  revised.
• January 01, 2004 Turkey joined GRECO (Group of
  States Against Corruption).
• October 11, 2006 Prevention of Laundering
  Proceeds of Crime Law on Law No 5559 was adopted.

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Structure of AML/KYC Standards

• FATF 409 Recommendations BCBS Customer Due
  NCCT Reports Diligence for Banks
• EU Directives
• Local Laws
• Local Regulatory Guidance
• Local Industry Guidance / Best Practices
• Policies Procedures

8
3 Headlines of FATFs 40 Recommendations

• Improvement of National Legal Environment Against
  Anti Money Laundering
• Strengthening the role of the financial sector
• International Co-operation

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The Main Features of FATFs 40 Recommendations

• A list of crimes that must underpin the money
  laundering offence
• The expansion of customer due diligence process
• Enchanced measures for higher risk customers and
  transactions
• The extension of AML measures to designated
  non-financial businesses and professions.

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The Main Features of FATFs 40 Recommendations

• The inclusion of institutional measures,
  especially regarding international co-operation.
• The reinforcement of transparency requirements
• The prohibition of cooperation with shell banks
• The extension of many anti-money laundering
  requirements to cover terrorist financing.

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Turkeys Compliance with FATFs 40 Recommendations

• Turkey is compliant with 40 Recommendations of
  FATF.
• In accordance with the Financial Intelligence
  Unit, MASAK serves and functions as a central
  national intelligence unit collecting,
  evaluating, implementing, auditing, regulating,
  coordinating, analyzing and circulating to the
  relevant authorities all financial data and
  information.

12
FATFs 8 Special Recommendations

• FATFs 8 Special Recommendations have been
  introduced following the attacks on September
  11th, 2001 to specifically confiscate and freeze
  terrorist assets and prevent, report and
  criminalize financing of terrorism

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FATFs 8 Special Recommendations

• Taking immediate steps to ratify and implement
  the relevant United Nations instruments.
• Criminalize the financing of terrorism, terrorist
  acts and terrorist organizations.
• Freeze and confiscate terrorist assets.
• Report suspicious transactions linked to
  terrorism.
• Provide the widest possible range of assistance
  to other countries law enforcement and
  regulatory authorities for terrorist financing
  investigations.

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FATFs 8 Special Recommendations

• Impose anti-money laundering requirements on
  alternative remittance systems.
• Strengthen customer identification measures in
  international and domestic wire transfers.
• Ensure that entities, in particular non-profit
  organizations, cannot be misused to finance
  terrorism.

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Turkeys Compliance with FATFs 8 Special
Recommendations

• As a member of FATF, Turkey has
• implemented all 40 8 FATF recommendations
• and encourages their widest international
• adoption and application.

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Headlines of Tekstilbanks Main Principles for
Prevention of Money Laundering

• Know Your Customer Policy
• Compliance with all applicable laws and
  cooperation with external and internal
  authorities, comptrollers, auditors and
  inspectors.
• Internal procedures and intensive training,
  monitoring and reporting activities.

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Tekstilbanks Main Principles for Prevention of
Money Laundering

• Our bank identifies all clients and related
  parties before initiating transactions that
  exceed YTL 2,000.-(approximately 1,500)
• We request identification regardless of monetary
  limit before executing transactions related to
  insurance, financial leasing, deposit box
  services and opening all kinds of accounts.
  (deposit, current, repo etc)

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Tekstilbanks Main Principles for Prevention of
Money Laundering

• We keep all identification documents for 5 years
  from the transaction date.
• Our Bank has a Compliance Department to develop
  programmes and strategies against Money
  Laundering and terrorist financing.
• We have established written Anti Money Laundering
  policies and procedures.

19
Tekstilbanks Main Principles for Prevention of
Money Laundering

• Internal Auditors check the system in general and
  make supervision at branch level at regular
  intervals.
• Our bank established a training program through
  which Internal Auditors and our Compliance
  Officer train our personnel on
• National laws and regulations
• Our internal AML Policy
• Customer identification standards
• International regulations and standards
• Identification and reporting of suspicious
  transactions on a regular basis.
• Risky industries, territories and transaction
  types

20
Tekstilbanks Main Principles for Prevention of
Money Laundering

• Our Computer system works on a real time on line
  basis and has automated controls in order to
  avoid double client entries.
• The Operations Department makes daily controls to
  check whether idenfitication requirements are
  fulfilled for every new account opened.
• Names of suspicious persons and organizations
  supplied by Government Authorities are listed at
  our Intranet in order to warn our employees prior
  to initiating transactions.

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Tekstilbanks Main Principles for Prevention of
Money Laundering

• Changes in the list of Non Cooperative Countries
  (NCC) published by FATF are announced to our
  employees promptly through Intranet.
• Compliance Officers approval is required when
  opening accounts for clients incorporated in
  foreign jurisdictions.

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Tekstilbanks Main Principles for Prevention of
Money Laundering

• Our employees are informed on any changes in anti
  money- laundering laws and regulations through
  our banks intranet.
• We report all kinds of transactions that fall
  into the category of 20 suspicious transactions
  mentioned in the Law 4208, to MASAK (Turkish
  Financial Intelligence Unit)

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Tekstilbanks Main Principles for Prevention of
Money Laundering

• We do not maintain anonymous accounts.
• We do not conduct business with shell banks,
  having no physical presence in any country.
• Our anti money laundering control policy does not
  make reference to politically exposed persons.

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Red Flags

• Reluctance to provide adequate identification or
  information when opening an account
• Backgroung is inconsistent with proposed business
  activity
• Frequent offshore wire transfers-especially if no
  connection to the customers business is obvious
• Customers place of business or residence is not
  geographically proximate to the bank
• Industry risk
• Geographical risk-Country level
• Politically exposed persons
• Use of shell companies

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What are we looking for ?

• Transactions derived from restricted persons
  countries listed and updated periodically by FATF
  and other national international authorities.
• Fund transfers to/from off-shore, shell banks and
  non-profit organizations
• Unoriginal or photocopy documentation and/or
  identification
• Insufficient or invalid information,
  documentation, identification.
• Suspicious customer behaviour or activity
• Multiple transactions below the threshold
• Risky sectors and transaction types

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What are we looking for ?

• Change of account behavior without any logical
  explanation
• Large scale cash transactions
• Unrealistic business turnover
• Large or rapid fund transfers
• Unrealistic wealth for client profile
• Suspicious counterparties, customers, suppliers
  or vendors
• Multiple accounts
• A typical or uneconomic fund movements (currency
  conversions)
• Fund movement to/from a foreign jurisdiction
  especially from Non-Cooperative Countries and
  Territories (NCCTs).

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Your contact

• Mr. Gürdogan YURTSEVER
• Compliance Officer
• Tel [phone]
• Fax [phone]
• E-mail gyurtsever_at_tekstilbank.com.tr