As criminals can use financial services to launder money and finance their criminal activities, it is important to have the right process to know our customers. Knowing the customer allows us to better understand the business relationship. We are obliged to detect unusual and suspicious activities and to check whether a specific customer or investment is on sanctions lists.

Money laundering, terrorism and financial sanctions violations not only harm society, but can also damage the stability and reputation of the financial sector. It is in the interest of the financial industry and society that financial institutions take measures to prevent money laundering and terrorist financing. To detect money laundering, we cooperate with a number of actors, including other banks, authorities and the police.

To ensure the effective establishment and implementation of an anti-money laundering and anti-terrorist financing culture, we:

• We have adopted anti-money laundering, counter-terrorist financing and financial sanctions compliance policies that require all parts of our business to take effective measures to comply with applicable laws.
• Customer Due Diligence (CDD) consists, among other things, of identifying and verifying the identity of the customer based on documents, data or information obtained from reliable and independent sources. We also need to understand the beneficial owner, ownership and structure of our customers.
• We perform daily reviews of the customer base against financial sanctions and PEP¹ lists. Furthermore, all holdings in our funds and portfolios are screened against sanctions lists on a daily basis.
• Initiating or continuing a business relationship with a PEP or other relevant high-risk customers requires an approved decision-maker.