Money Laundering Control Management by jba60919

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									Global Money Laundering Control Policy

                 Executive summary




  Policy owner           :   Andre Wentzel

  Policy custodian       :   Group Risk ERM

  Policy repository      :   K-Net

  Previous review date   :   17 October 2006

  Next review date       :   October 2007
1. Introduction

    The Nedbank Group (the group) will not be associated with money laundering or terrorist
    financing and will introduce policies and procedures to ensure statutory duties and
    regulatory obligations or, in their absence, agreed standards are met.

2. Objective of the Policy

    The objective of this level 3 policy (level as defined in the group level risk policies
    framework) is to ensure that:

    A framework is established within which money laundering control and the financing of
    terrorist and related activities are managed through adequate procedures to discharge the
    group's statutory duties and regulatory obligations.

    This framework will utilise the agreed standards and will be determined by engagement
    with business units operating in various jurisdictions.

3. Scope

    This policy applies to the group, globally.

    The conditions of this policy apply to any known or suspected money laundering or the
    financing of terrorist and related activities or related breach of duty, involving employees,
    contractors, temporary employees, consultants, clients, shareholders, vendors, outside
    agencies and unknown parties.

    This policy addresses the responsibility of management and employees for:

       preventing, detecting, monitoring and reporting confirmed, suspected, detected or
        prevented money laundering or the financing of terrorist and related activities;
       record-keeping;
       MLC and CFT training; and
       monitoring of accounts, activities, policies, procedures and plans.

4. Key Principles

    A detailed description of each key principle may be obtained from the actual Global
    Money Laundering Control Policy which is available to all employees on the intranet.

       The group will under no circumstances be associated with money laundering or the
        financing of terrorist and related activities and will introduce necessary policies and
        procedures (in line with agreed standards) to ensure that all statutory and regulatory
        obligations are adhered to.

       The group will report knowledge or suspicion of money laundering and the financing
        of terrorist and related activities, cooperate with the relevant authorities and release
        to them such information as required in terms of its legal obligations.

       The group will report any property or transactions involving entities identified on
        international monitoring lists to the relevant internal reporting structures and, where
        required, to the relevant authorities.




Global Money Laundering Control Policy (Level 3) – executive summary
Group Regulatory Risk Services
                                                                                      Page 1 of 2
       These monitoring lists are issued by, among others, the United Nations Security
        Council (UNSC), and reporting will be performed on any entity identified in such a list,
        irrespective of the nature of the relationship in respect of the transaction or property.

       All client identification, verification and transaction records are to be retained by the
        group. The applicable local legislation or agreed standard will prescribe the specific
        records to be retained and the respective retention periods.

       The group will provide, to all designated employees, the appropriate money
        laundering control and combating of the financing of terrorist and related activities
        training.

       The group will proactively monitor adherence to this policy, ensuring compliance with
        its obligations in terms of legislation and agreed standards enforcing money
        laundering control and the combating of the financing of terrorist and related
        activities.

       Relevant group employees must be made aware of the contents of the Nedbank
        Group Global Money Laundering Control Policy, which includes communication
        regarding their responsibilities and actions expected of them.

       The responsibility vests with the Group Money Laundering Control Officer (GMLCO)
        for the oversight of all matters within the group relating to money laundering control
        and the combating of the financing of terrorist and related activities.

       Each group subsidiary or associate company is to appoint a suitable person to the
        role of Money Laundering Control Officer (MLCO). This appointee will be responsible
        for the policies and procedures within that subsidiary or associate company relating to
        money laundering control and the combating of the financing of terrorist and related
        activities.

       Management reports must be produced to allow the group actively and effectively to
        monitor initiatives relating to money laundering control and the combating of the
        financing of terrorist and related activities. These reports are intended to address the
        requirements of the various authorities and group structures.


End of document




Global Money Laundering Control Policy (Level 3) – executive summary
Group Regulatory Risk Services
                                                                                      Page 2 of 2

								
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