Compliance is a top priority for MEAB, and the bank adheres to high international standards. The bank’s Anti-Money Laundering/Counter Terrorist Financing (AML/CFT) programs meet or exceed the requirements of both the Banque du Liban and the international standards of the Financial Action Task Force (FATF).
In addition to screening customers and transactions against the requirements of the Banque du Liban, MEAB also screens its banking activity against the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list, the UN sanctions lists and the EU sanctions lists, among others, using EastNet’s state-of-the-art SafeWatch® system.
The bank’s Compliance and Anti-Money Laundering Committee reviews and approves all compliance procedures. The committee is comprised of the most senior executives of the bank including the general manager, deputy general manager, head of compliance, head of internal audit, head of risk management and head of operations. Additionally, all AML/CFT policies and procedures are approved by the board of directors. The bank also has a dedicated compliance team at each MEAB branch that are overseen by MEAB’s corporate compliance officer..
All bank employees receive extensive training in AML/CTF when they are hired and participate in additional training annually. Personnel with compliance responsibilities receive more frequent training and attend conferences and external training on AML/CTF procedures, issues and emerging trends.
MEAB Compliance Manual
MEAB’s AML/CFT Compliance Manual assigns responsibilities for implementing the program, and is followed by all of the bank’s officers and employees. The manual sets forth the bank’s policies and standards with regard to transaction screening, customer due diligence, suspicious activity reporting, documentation and risk management, among other compliance procedures. Every MEAB employee including members of the AML/CTF Committee receives a copy of the manual and is expected to adhere to all policies and procedures.
Customer Due Diligence
MEAB conducts due diligence on its customers as part of its account opening procedures. When a prospective customer opens a new account, he or she is subject to identification due diligence. Customer identification is based on inspection of government-issued identification or corporate documents. If the bank’s staff is unable to obtain sufficient information to properly identify the customer or has any doubts about the veracity of any of the documentation or information provided by the customer, MEAB will not proceed with opening the account.
MEAB also checks all potential customers against U.S., UN, EU, Lebanese and other lists of designated or prohibited persons and entities using EastNet’s SafeWatch® system.
Know Your Customer
In addition to basic identification and advanced screening procedures, MEAB also conducts rigorous KYC procedures for potential individual, corporate, or charitable customers. These include verifying the source of funds and conducting field visits to corporate and charitable entities. MEAB also implements a separate set of screening procedures for wire transfers by or for customers, including verifying the initiator for incoming wire transfers and verifying the beneficiary for outgoing wire transfers. MEAB actively uses its knowledge of its customers to identify suspicious transfers and other transactions.
Existing customers are periodically rescreened against the designated persons and entities lists. If an existing customer is added to one of the lists, MEAB will immediately notify the Banque du Liban’s Special Investigative Commission and take appropriate action pursuant to the Commission’s instructions, including freezing and closing the account.