Programme for anti-money laundering and countering the financing of terrorism

NLB has zero tolerance for all forms of financial crime. Our AML/CFT Programme for anti-money laundering and countering the financing of terrorism, therefore, pursues the international standards in the area of AML/CFT and enables the Bank to participate in various international efforts in fighting money laundering, terrorist financing, and other criminal offences.

Our money laundering and terrorist financing prevention standards are in compliance with the Slovenian and the EU legislation in the area of money laundering prevention, and the guidelines of the Bank of Slovenia. They are also in compliance with the recommendations of the intergovernmental organisation Financial Action Task Force on Money Laundering (hereinafter: FATF). Clients and their operations are reviewed using detailed procedures and an automated system for detecting potential abuse of the financial system for the purpose of money laundering.

Our requirements in the area of anti-money laundering and anti-terrorism financing prevention apply in all countries where NLB Group operates, regardless of their location. The members of NLB Group must namely operate in full compliance with the Slovenian AML/CFT legislation and NLB Group Standards. All our employees and senior managers must act in accordance with those standards in order to prevent abuse of our name or our products and services for the purposes of money laundering. To ensure that we always use the best possible harmonisation practices, we regularly inspect our goals, methodologies, procedures, and strategies for the prevention of money laundering and terrorist financing, and regularly train and raise the awareness of all employees in the front offices.

Strict measures for anti-money laundering and combating the financing of terrorism

Based on the AML/CFT Policy, NLB does not permit payments (transactions) to prohibited countries/jurisdictions. NLB does not cooperate with the clients from such countries. The harmonisation of the implementation of the AML/CFT system in the Group also includes the supervision and review of the AML/CFT system. With this approach and the upgrade of the AML/CFT system, NLB and NLB Group have been efficiently managing the AML/CFT risks in the recent years and thus meeting the obligations imposed by the international standards and other regulations.

Other measures used for preventing money laundering and combating terrorism financing:

-    NLB has in place a prohibition of starting business cooperation with entities having headquarters in high-risk countries with inadequate standards regarding the terrorist financing,

-    the restriction and in-depth reviews of non-residents without economic or logical bases for the entry into the business relationship,

-    prohibited operations with the countries and regimes defined as high-risk by the international banking standards (including Iran, North Korea, Sudan, and South Sudan, Myanmar, Afghanistan, Cuba, Crimea and Siria),

NLB has set up a special committee for the prevention of money laundering which regularly investigates suspicious cases and adopts decisions on the termination of business cooperation where risks exist for money laundering and terrorist financing.

In terms of acceptability of operations with entities and segments where the actual risks exceed the acceptability level, the Bank adopts a sovereign decision not to enter into a business relationship with such client or group or to terminate any existing business relationships.

How we ensure the know your customer (KYC) principle

NLB upholds the laws and international standards in the AML/CFT area. NLB Group carries out the client due diligence review process (a) prior to establishing a business cooperation, (b) prior to implementing individual transactions in the amount of EUR 15,000 or more, (c) in the event of doubt regarding the accuracy of data or (d) in the event of suspected money laundering or terrorist financing regardless of the amount of transactions and (e) in the case of periodic transactions performed by a non-client of the Bank.

To support the fight against terrorist financing and money laundering activities, NLB obtains, verifies and records data which identify every person or entity that opens an account with NLB.

NLB strives to obtain and update the data and documents in relation to the process of knowing the client at least every two years for high-risk clients and every 5 years for usual-risk clients.

NLB’s client due diligence review comprises the following:

•    establishing and verifying the customer's identity on the basis of independent and objective sources,

•    identifying the actual owner of the client,

•    obtaining data on the activities, reasons, purpose and intended nature of the business relationship, and other data as required by law,

•    regular monitoring of the clients’ business activities based on the risk assessment.

What does the implementation of the KYC procedure mean for your customers? When you open the account, we will ask you for your name, address, date of birth and other data enabling us to identify you. We can also ask you to present your identification documents (passport, personal ID card or other identification documents) for verification. Should we need additional data and information (e.g. on the origin of money, actual owners and similar) we will ask for them, since we are required to do so by the regulations and international standards that bind us.

More detailed information on the implementation of the KYC procedures - how do we assess and monitor our clients

We have developed efficient Know Your Customer or KYC procedures and the procedure of deciding about accepting new clients in order to ensure the appropriate level of compliance with international standards for the sake of anti-money laundering and combating the financing of terrorism. These also help us reduce the risks in relation to money laundering, terrorist financing, and other economic crime. Our KYC procedures begin with client due diligence reviews carried out in accordance with the international standards and guidelines of our regulators (client reviews are carried out prior to the establishment of the business relationship with individual clients and later in the form of regular reviews). Our procedures do not only apply to individuals and business entities that are or could become our direct business partners, but also for the people and entities behind them (actual owners) or indirectly associated with them (business partners).

Based on the KYC principle, we assess and determine the level of risk for each client and business relationship. Based on the risk assessment, we carry out a simplified or an in-depth client review. In the event of high risk, an in-depth review is carried out (e.g. for politically exposed persons) which comprises additional measures, such as: obtain data on the origin of assets and property, additional data on the activity, purpose and interests of the client, obtain approval of the business relationship from the senior management and carry out more frequent and in-depth monitoring of the client’s business activities and operations performed by the client using our services.

Financial sanctions and EMBARGO (UN, EU, OFAC, HMT)

The unacceptability of entering into business relationships and carrying out transactions applies to all operators, entities, ownership associations, goods, countries and geographical areas listed among the international restrictive measures. In accordance with the regulatory requirements, NLB carries out the restrictive measures of the UN (United Nations) and the EU. Even though NLB as an entity with the registered office in Slovenia is not obliged to implement the US regulatory requirements, we have adopted a business decision in the framework of the policy of implementing the international restrictive measures (financial sanctions and embargo) and committed to implementing the OFAC financial sanctions and embargo, the HMT and the US Patriot Act in the part relating to foreign banks.

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