Introduction

SICO BSC (c) (“SICO”, “Bank”) is a joint stock company which is licensed as a conventional wholesale bank by the Central Bank of Bahrain (“CBB”) and listed on Bahrain Bourse (“BHB’).

Laws and Supervision

The Bank is under the supervision of the CBB and complies with Decree Law No. (4) of 2001 and its amendments (collectively, “the AML Law”) with respect to the Prevention and Prohibition of the Money Laundering.

The CBB has adopted and is compliant with the recommendations issued by the Financial Action Task Force (“FATF”), which are the international standards, for effective anti-money laundering regimesand the requirements of the Basel committee (Customer Due Diligence for Bank’s paper, that are relevant to conventional bank licensees.

The Kingdom of Bahrain is a member of the Gulf Cooperation Council (GCC), which is a member of FATF. The Kingdom of Bahrain is also a member of MENAFATF, which is an associate member of FATF.

The Bank’s Policies

The Bank will conduct its business in conformity with high ethical standards and will adhere to all laws and regulations pertaining to financial institutions.

The Bank will conduct its business in compliance with the following general principles:

• Ensuring that the highest standards of due diligence are applied to the “Know Your Customer” principles.
  
• Protecting the Bank, beneficial owners, our clients and staff from money laundering & terrorist financing at all times.
  
• Maintaining written AML policy and procedures, addressing a system of internal controls to ensure on-going AML compliance by the MLRO and take appropriate action, in case any suspicious transaction is detected.
  
• Compliance with applicable anti-money laundering & terrorist financing laws and regulations as established by CBB in accordance with the recommendations of the Financial Action Task Force on Money Laundering & Terrorist Financing.
  
• Application of the Bank’s anti-money laundering policies to all business units.
  
• On-going monitoring of compliance with the Bank’s anti-money laundering policies through a combination of internal audit, external audit and regulatory reviews of compliance with relevant anti-money laundering legislation and/or regulations.
  
• Ensuring that the Bank does not conduct any business with a Shell Company. In addition to this, the Bank does not open anonymous accounts.
  
• Initial and on-going training of staff on KYC and anti-money laundering policies and new AML laws and regulations. Training and Career Development has an on-going training program for the appropriate staff with emphasis on anti–money laundering and terrorist financing.
  
• The Bank has a system in place to detect transactions involving clients who are on the UN, OFAC and other similar international sanction lists.
• Conducting Enhanced Due Diligence for all high risk customers.
• The Bank has effective procedures for verifying client identification, source of funds and for retention of all customers due diligence information.
• Not initiating, developing relationship or entertaining prohibited accounts, as instructed by CBB.
• Cooperating fully with law enforcement and regulatory agencies in executing their duties under all applicable laws.
• Requiring all correspondent banks with which SICO does business maintain appropriate procedures.