Compliance and Financial Monitoring

Is an integral part of PrivatBank daily business practice

PrivatBank pursues the policy which seeks to comply with all legal requirements, general banking standards, code of ethics, regulatory requirements on counteraction to legalization of funds and prevention from use of the bank products and services for money laundering purposes.

Compliance is an integral part of the culture within the entire bank. To implement the compliance culture at all organizational levels, PrivatBank’s top management creates the tone at the top atmosphere.

The corporate conduct in PrivatBank is built on the principles of legality, transparency and competence, in compliance with the rights and interests of PrivatBank customers, creditors, the shareholder and employees; it is aimed at increasing the efficiency of the bank activities, maintenance of its financial stability and profit.

The Code of Conduct (Ethics) is the main resource which the bank employees, customers and business partners may use on a daily basis to make sure that their actions and decisions comply with PrivatBank values.

The Code is a set of rules for the PrivatBank top managers and employees which is aimed at the promotion of risk management culture, the Code as well defines the high ethical and professional standards and the means to comply thereof.

In the course of providing its activities, PrivatBank endeavors its best to take measures for conflict of interests prevention. PrivatBank corporate values determine the importance of timely and frank consideration of unacceptable conduct or any other breaches within the bank which may harm either its interests or customers.

And to manage the risks associated with conflict of interests, PrivatBank has implemented the Conflict of Interests Prevention Policy which is entailed to ensure control over conflict of interests timely detection, prevention and settlement.

The key principles of The Conflict of Interest Prevention Policy include:

• setting the relevant standards and requirements obligatory for all the bank employees and top managers;
• governing the process of the timely detection and efficient settlement of conflict of interests;
• implementing the measures for the prevention of either real or potential conflict of interests;
• determining the grounds governing the liability for breaching the requirements on the prevention and settlement of conflict of interests.

The main tasks of the PrivatBank AML/FT Policy are the following:

1. To define and approve PrivatBank general principles for the compliance with the requirements of the current legislation of Ukraine on AML/FT issues.

2. To prevent using the bank’s services for the purposes of legalization (money laundering) of proceeds from crime, financing of terrorism and proliferation of weapons of mass destruction (the AML/FT).

3. To counteract any other activities that precede or facilitate money laundering, financing of terrorism and proliferation of weapons of mass destruction (AML/FT).

PrivatBank believes that the aforesaid measures are the most efficient instrument to prevent the AML/FT and applies all possible means, methods and ways to make impossible use of the bank services in providing illegal activities.

The AML/FT Policy is applied to all the PrivatBank units (including those which are separated and located in other jurisdictions); to all the bank employees; business partners; members of banking groups / members of the payment systems to which it is included or the members of the entities/payment systems created by the bank; to customers who perform financial transactions through PrivatBank on the territory of Ukraine and abroad pursuant to international treaties of Ukraine, the binding consent of which has been granted by the Verkhovna Rada of Ukraine; and to the counterparties of the customers.

The objective of the PrivatBank Sanctions Policy is:

1) To determine the general sanction control approaches for the bank;

2) to arrange and ensure the functioning of the bank internal risk management system, in terms of the risks related to the activities provided by the persons who are:

• included into the sanctions lists;
• related to the states (jurisdictions/territories) falling under the Risk Acceptance Criteria (the set of criteria for the states (jurisdictions/territories) of unacceptably high level of risk and/or which are imposed with the sectoral sanctions,

and making these persons unable to use the bank products/services to perform transactions which are intended to facilitate or might facilitate the sanctions evasion.

The Sanctions Policy is applied to all the bank employees; business partners; members of banking groups / members of the payment systems to which the bank is included or the members of the entities/payment systems created by the bank; to customers (and in particular to their representatives, ultimate beneficial owners); counterparties of the bank customers; correspondent banks; other physical and legal entities which are specifically identified in the bank internal sanctions control documents.

The Wolfsberg Group is an association of the world’s largest banks and includes: Banco Santander, Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Générale, UBS, Standard Chartered Bank and the Bank of America.

The principles developed by the Wolfsberg Group, while not formally having legal force, are a public obligation for the banks-members to adhere to certain ethical rules. Considering a real impact of the Group members, the adoption of such principles serves as an effective incentive for other banks to comply therewith.

The Wolfsberg Group has developed the Questionnaire (a survey) the Correspondent Banking Due Diligence Questionnaire (CBDDQ). Whose purpose is to gain a deeper understanding of cross-border and other higher risks in correspondent banking relations, to find out how the anti-bribery and anti-corruption standards are implemented, and to counteract the financing of terrorism and monitor the sanctions compliance.

FATCA (The Foreign Account Tax Compliance Act) is a regulatory act of the U.S. Treasury Department and the U.S. Internal Revenue Service (the IRS), it is developed and intended to combat tax evasion in the USA.

To comply with the FATCA requirements, PrivatBank must detect among its customers/founders (members and shareholders) the customers/ultimate beneficial owners of customers – individuals who are the U.S. residents, and legal entities registered in the U.S, and must submit the information about their accounts through the Ministry of Finance of Ukraine to the particularly designated body i.e., the U.S. Internal Revenue Service (IRS). PrivatBank is also obliged to detect financial and credit institutions which have not received their GIIN (Global Intermediary Identification Number).

The JSC CB “PrivatBank” is registered on the website of the U.S. IRS with the status - Reporting Financial Institution under a Model 1 and received its Global Intermediary Identification Number (the GIIN) – JUG662.99999.SL.804..

The form of PrivatBank W-8BEN-E is available at this link. Pursuant to the requirements set out in § 1.1441-1 (e) (4) (IV) B) of the Head of Terms of the U.S. Treasury Department, the submission and transmission of the certificates may be provided in an electronic form in PDF format.

Report us (you may do it anonymously) on the breaches related to the legislation and/or the internal procedures of the bank in the field of prevention and counteraction to legalization (money laundering) of proceeds from crime, financing of terrorism and proliferation of weapons of mass destruction, and on breaches related to other laws or PrivatBank Code of Conduct (Ethics) by one of the following ways:

• fill out the online form;
• send a letter to the correspondence address: JSC CB “PrivatBank”, 49094, Naberezhna Peremohy street, 30, Dnipro, Ukraine;
• email to: help@pb.ua.

We comply with the Law of Ukraine No. 361-IX “On Preventing and Counteracting to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction” dated December 6, 2019.