Anti-Money Laundering Measures

As a member state of the Financial Action Task Force on Money Laundering, Russia adopted a federal law in 2001 ''On counteraction of the legalization (laundering) of the proceeds of crime and the financing of terrorism''. Subsequent to the passage of the Anti-Money Laundering Law, the Central Bank promulgated a number of regulations in this field specifically for the banking sector.

In order to prevent systematic violations the management of OJSC Orient express bank undertook the following measures:
• Department of Combating Legalization of Illegal Proceeds (Money Laundering) and Terrorist Financing was implemented;
• in each branch there were implemented in the staff positions of "Responsible employee's assistant on combating Legalisation of Illegal Proceeds (Money Laundering) and Terrorist Financing" which task is the Internal Control Rules supervision un the Bank's branches;
• some normative internal documents were developed and approved, including Internal Control Rules, employees' training programme and etc.;
• the report "Regulation 207-R" was realized in the software IBSO which enables the employees of AML/TF Department to carry out the current control over operation subject to obligatory control;
• the employees of AML/TF Department on a permanent basis carry out the check with the purpose of requirements violations facts detecting of 115-FZ of normative acts of the Bank of Russia in the AML/TF sphere (for the period of 2006-2007 15 checks were carried out);
• when recruiting new employees the induction training is carried out as the obligatory requirement on questions of combating Legalisation of Illegal Proceeds (Money Laundering) and Terrorist Financing with the following knowledge assessment;
• the employees of AML/TF Department on a permanent basis carry out target, unplanned training with the purpose of professional development of the bank's structural subdivisions employees connected with settlement operations and customers service.

Currently one may notice generally the Bank's and branch organizations' compliance with the regulation in the field of AML/TF. The Bank's orientation on the retail line of activity significantly minimizes the risk of the Bank's involvement in the process of legalization illegal proceeds and terrorism financing.