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National
Bank of Kuwait (Lebanon) s.a.l
Anti-Money Laundering and Counter-Terrorist Financing
Information about our policies and procedures
GENERAL
The following information has been prepared to address the
many anti-money laundering and terrorist financing
questions/questionnaires we receive from organisations with
which we have a business relationship in order to provide each
institution with a suitably complete response.
Lebanon is a member of the Financial Action Task Force on
money laundering (“FATF”). Lebanon is subject to mutual
evaluations by FATF.
The National Bank Of Kuwait (Lebanon)sal ,(‘’NBKL’’) ,has
adopted strict procedures for dealing with the comprehensive
topic of anti-money laundering and terrorist financing. NBKL
is regulated by the Central Bank of Lebanon (“BDL”). All of
NBK’s overseas locations are subject to local regulations,
which in the case of the United Kingdom, United States of
America, France, Singapore and Switzerland are fully compliant
with the requirements of the FATF. Both local and Central Bank
of Lebanon regulations complement each other and all overseas
locations have a dedicated anti-money laundering
reporting/compliance officer.
Central Bank of Lebanon has issued comprehensive instructions
as well as detailed guidance notes that deal with the issue of
anti-money laundering and terrorist financing. These
instructions are based on:
a) Lebanese Law No. 318/April 2001 regarding combating money
laundering operations;
b) The forty recommendations related to combating money
laundering as well as the eight recommendations related to
combating terrorist financing issued by the FATF;
c) The International Monetary Fund’s guidance for combating
money laundering and terrorist financing;
In addition to the above, NBKL has also considered other
international guidance on the subject of anti-money laundering
and terrorist financing including (but not limited to) Basel
Committee publication No. 85 – Customer due diligence for
banks, United Nations guidance on the suppression of terrorist
financing etc.
The Central Bank of Lebanon’s instructions as well as
international guidance on anti-money laundering and terrorist
financing are considered of extreme importance by NBKL and to
this end it has issued, for internal purposes, publications,
manuals, and workshops and has conducted seminars for the
implementation by all members of management and staff..
SPECIFIC PROCEDURES WITHIN LEBANON
Know Your Customer Guidelines
NBKL has strict KYC procedures in place. All customers are
required to provide valid identity and residential address
documentation. Identity and account information is updated and
reviewed from time-to-time as required. No anonymous or
numbered accounts are permitted.
No account is opened without the branch AMLO review and
approval of the appropriate documentation. Furthermore, a bank
reference from a well-recognised financial institution is
required in order for the account to be opened.
NBKL does not maintain accounts for shell banks (as defined by
the US Patriot Act). In addition, any charity related
organisation wishing to open an account must present an
approved licence from the Ministry of Interior .
Regulatory reporting requirements
NBKL requires from clients, except from those exempted, to
fill and sign a cash transaction slip (CTS), which must
include the amount involved and the source of funds, when
making a cash deposit exceeding ten thousand US dollars or the
equivalent, or when carrying out multiple operations involving
lower amounts but totaling more than USD 10,000 or the
equivalent.
To prepare tables for operations that exceed the ceiling
specified for clients exempted from filling the cash
transaction slip, and to take the necessary measures to
safeguard these tables, in order to make them available, on
request, to internal auditing officers or bank auditors, or to
the Special Investigation Commission at the Central Bank of
Lebanon.
Terrorist financing transactions
The Central Bank of Lebanon issues listings of designated
terrorists (individuals and organisations) that follow the
United Nations guidelines. NBK monitors transactions with
customers against this listing. In addition, our overseas
units also monitor transactions against this listing as well
as any local listings (including OFAC in our New York branch)
that regulators provide.
In addition to our detailed KYC procedures, all new accounts
are scrutinised against the Central Bank lists of suspected
terrorists. All amendments to the listings issued by The
Central Bank of Lebanon are reviewed at all NBKL local
branches and a confirmation of no activity with these
individuals and/or organisations is returned to the Central
Bank of Lebanon.
Unusual large transactions
Our internal procedures are designed to highlight unusual and
large transactions so that the bank’s staff can take the
necessary actions to ensure that the transaction is bona fide.
Large transactions also require a manager’s override before
the transaction can be executed. Our systems require that
special care and scrutiny is carried out on any large or
unusual transaction(s) which have no commercial purpose and
the systems have been enhanced to alert staff of any customers
that have had cumulative cash transactions exceeding
predefined limits
In addition to the above, where an unusual large transaction
is identified, we take the necessary precautions to verify the
source of the customer funds. This also applies upon the
opening of an account with a new customer.
Money Laundering Reporting Unit
NBKL has a money laundering reporting officer who handles all
issues pertaining to the subject. This officer (and his staff)
will investigate any matters that cannot be cleared by branch
or business management and will take whatever follow up action
is required.
In accordance with the Lebanese anti-money laundering law,
Central Bank of Lebanon instructions and our opening account
terms and conditions, NBKL has the right to block customer
funds until suspicions are cleared. Any suspected transaction
that is unable to be cleared by the bank is forwarded to
Central Bank of Lebanon for further action. The local
anti-money laundering law imposes financial penalties and
imprisonment for individuals and entities convicted of a money
laundering offence.
Internal Training Requirements
It is NBKL policy and Central Bank of Lebanon regulation that
all bank staff be trained on anti-money laundering procedures.
NBKL has detailed training programs for all new recruits as
well as regular training and knowledge updates for existing
staff.
Compliance with Policies and
Procedures
A separate Branch Compliance Unit was established (2001) to
monitor compliance with policies and procedures, including,
but not limited to, anti-money laundering and terrorist
financing procedures. In addition, our internal auditors
review money laundering initiatives in all critical areas at
least once per year. Finally, we are subject to regular
Central Bank of Lebanon inspection and annual external auditor
review which specifically covers anti-money laundering
procedures.
External Auditors
Our external auditors are currently Ernst & Young. In addition
to the statutory audit, an A rated audit firm is required to
sign off on our internal controls, including money laundering.
We have consistently obtained a clean opinion regarding our
compliance with money laundering from this internal controls
assessment.
Other information
• For information concerning the Central Bank of Lebanon,
please refer to www.sic.gov.lb
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