Compliance

TÜRKİYE CUMHURİYETİ ZİRAAT BANKASI A.Ş.
ANTI – MONEY LAUNDERING & COUNTER TERRORIST FINANCING (AML/CTF)
POLICY

It is the policy of Türkiye Cumhuriyeti Ziraat Bankası A.Ş. to prohibit and actively pursue the money laundering and any activities that facilitates money laundering or the funding of terrorist or criminal activities.

The bank is committed to AML/CTF compliance in accordance with applicable law and requires its management and employees to adhere to these standards in preventing the use of its products and services for money laundering purposes. Therefore in line with Know Your Customer Principle, it is essential to identify the customers and those who carry out transactions on behalf of the customers, and it is forbidden to open anonymous accounts and to conduct transactions with shell banks.

The Bank’s branches and subsidiaries, regardless of their geographic location, must adhere to this policy provided that it does not conflict with the applicable AML/CTF legislation of their host country.

The Bank has established a Compliance Department and designated a Compliance Officer in order to ensure the compliance to applicable AML/CTF laws, rules and regulations.

The Compliance Officer is entitled to demand and access all kinds of information and documents from all units within the Bank, regarding its own area of duties, in order to make a decision at his discretion independently.

1. RISK MANAGEMENT
AML/CTF related risks are defined, rated and the necessary precautions are taken tomonitor, assess and reduce these risks.

2. MONITORING AND CONTROL
The purpose of monitoring and control is to protect the Bank against risks and to monitor and control on a permanent basis whether the Bank's operations are carried out in accordance with the Law and other arrangements issued as per the Law as well as the Bank's policies and procedures.

3. INTERNAL AUDIT
The purpose of internal audit is to give assurance to the Board of Directors regarding the effectiveness and adequacy of the whole Compliance Program. The Bank procures that corporate policies and procedures are reviewed and inspected annually by using a risk-based approach in order to determine whether risk management, monitoring and control activities as well as training activities are adequate and effective, whether the risk policy is adequate and effective, and whether transactions are conducted in accordance with the Law and other arrangements issued as per the Law and the corporate policies and procedures.

4. TRAINING
The purpose of the Bank’s training policy on AML/CTF is to ensure the compliance with the Law and other arrangements issued as per the Law, to develop a corporate culture by increasing the sense of responsibility of the personnel with respect to the Bank's policies, procedures and risk-based approaches and to update the personnel’s knowledge.