Compliance and correspondent banking policy and procedures at MEAB
Since its establishment, MEAB has assured adherence to all the rules and regulations issued by our Lebanese regulatory who comply with the provisions of the United States patriot act.
WE, at MEAB strictly comply with the central bank’s circulars and laws concerning money laundry and any terrorist financing activities which was regulated by circular #83 and law #318 both issued since 2001 and followed later by several memos and circulars which we strictly comply with.
Proper application of above circulars is reviewed periodically by our external auditors, and reported by them to the central bank of Lebanon regulators represented by(special investigation committee and banking control commission known as SIC and BCCL consequently).
From the beginning, a compliance officer has been appointed for making sure that the policies are strictly applied throughout the bank. He coordinates and supervises officers at each branch who report directly to him. These employees have been well trained to execute the policies. They attend in-house and out-house workshops and seminars to keep them updated with any new issues.
Before opening any account for a potential client, the following processes must be taken into consideration:
1. Based on the submitted documents by the client, we ascertain his/her identity, the beneficiary right owner identity, and the activities before opening any account.
In case of personal accounts, the identity card or passport presentation is a must.
In case the client is a legal entity, registered documents must be presented regarding their status, registration certificate; the identities of the persons empowered to sign on its behalf, and the identity of its legal representative.
In case of the presence of an authorized representative, the original power of attorney or a certified copy plus identification must be presented.
2. Potential blacklisted persons are never accepted as clients. We verify these persons by entering their names on special software for identification.
3. Executing banking operations is denied to non-clients.
4. For each outgoing/incoming transfer, verification of the source of funds and their destination must be presented through reliable documents.
5. In case of any suspicious transaction, a report is sent to the special investigation commission (SIC) at the central bank.
6. A trace of funds transferred for at least five years is kept to facilitate any investigation if needed.
7. A risk-based approach is applied to classify the borrowers and operations according to risk rate. Special precautions are taken against those classified as high-risk.
8. MEAB has established (AML and Risk committees). They are supervised by the GM. Their members include the deputy GM, risk manager, operations manager, and branches’ manager.
Correspondent banking relations
Before establishing any relation with foreign banks, a check list is reviewed by our compliance officer, who investigates the bank status; at the same time we request the bank to provide us by supported documents including the following:
A list of the shareholders and the board of directors, the physical address of the bank, certificate of registration, and the license, in addition to AML questionnaire that should be filled by them and checked by us to be sure that the information matches with our sources. After that the file is raised to the concerned committee for final approval.
No relationship is established with sanctioned banks, sanctioned countries or clients.
In case of existing client got involved in any suspicion we report directly to the regulators who will instruct about the suitable action that should be taken.
-Any staff member can easily access the above policies.
-Employees continuously attend workshops and training sessions on the policies and procedures of AML.
-all the staff members are well aware of the bank secrecy law and any investigation against suspicious client should be acted and treated with total confidentiality. see more