The Bank adheres to high standards of integrity in the conduct of its business and ensures that its behaviour and the manner in which it chooses its project sponsors, clients, co-financiers and counterparties meets these standards. These standards include identifying and countering money laundering (ML) and terrorism financing (TF) risks.
As a non-deposit taking institution established by international treaty, the EBRD is not formally subject to national or supranational regulatory supervision, or anti-money laundering and counter financing of terrorism (AML/CFT) legislation. Nevertheless, the EBRD has developed an anti-money laundering programme to facilitate compliance with AML/CFT good practices which includes internal procedures and integrity guidelines that Bank employees must follow on how to identify, assess and respond to money laundering and terrorist financing risks in Bank projects. The Bank’s AML/CFT programme includes, but is not limited to, the following activities:
- identification of potential ML/TF risks relevant to each Bank project
- screening clients and key counterparties against relevant sanction lists
- identification of beneficial owners relevant to each Bank project
- regular monitoring for integrity and reputational risks that may arise during the life of a project, including ML and TF financing risks
- enhanced due diligence for high risk clients and sectors
- enhanced procedures for assessing risks associated with politically exposed persons
The EBRD will not provide financing or award any contract for the supply of goods, works or services to any person or entity that, according to the UN Security Council and/or the counter-terrorism subsidiary bodies of the Security Council, is or may be supporting terrorism.
The Office of the Chief Compliance Officer (“OCCO”) serves as the Bank’s money laundering reporting function. EBRD employees receive training to raise awareness in relation to money laundering and terrorism financing risks, to embed a culture of compliance and to apply the Bank’s guidelines and procedures on integrity due diligence. Internal Audit plays a valuable role in reviewing the control environment, including in relation to AML/CFT, on a regular basis.
Correspondent banking relationships are subject to appropriate customer due diligence and review which includes, inter alia, confirmation that the entity has the appropriate licences to operate in its country of origin and due diligence to avoid working with or through shell banks.
The EBRD is committed to participating in international efforts to counter money laundering and terrorism financing. The Bank, having observer status, regularly attends the meetings of the Financial Action Task Force (“FATF”), an inter-governmental body whose purpose is to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorism financing and other related threats to the integrity of the international financial system. Under the policy on Domiciliation of EBRD Clients, a referral to OCCO is required for all projects with an entity, intermediate entity, or controlling entity located in a jurisdiction with regard to which the FATF has released a public statement requiring its members to consider risks arising from strategic deficiencies in that jurisdiction’s framework to combat money laundering and the financing of terrorism and proliferation. These projects undergo heightened due diligence in order to satisfy the Bank that the entities established in that jurisdiction are not being used as vehicles for money laundering or terrorism financing.
Updated: January 2017