Attention please! Every one should abide with the new Rwanda AML/CFT law.
Why Should we care? We are not the police nor the criminals.
AB Bank and its employees are obliged by law, and it's in the bank policies that every employees must ensure that the bank is not involved at any extent to money laundering or terrorism financing activities
How can we or the bank be involved in money laundering or terrorism activities?
A new Law Nº69 - 2018 OF 31/08/2018 on Prevention and Punishment of Money Laundering was released on 6th September 2018 and the bank and its employees have to abide with it.
You are considered to be involved in ML/TF activities if you (directly or indirectly) conducts, controls or advise on transaction involving deposits, exchanges, investments, transfers, conversions or any other movement of capital or other property that derives from a misdemeanor or a felony, or dedicated to terrorism activities.
But how can we know that if a client is bringing cash for deposit is from a criminal activities or that a loan being disbursed will be used for financing terrorism activities?
AB Bank has also its dedicated AML/CFT policy and procedures which each employee have to comply with.
You should always check if the amount brought for deposit correspond to the client's profile (amount s/he normally used to transact or declared at account opening). For the loan you can verify the capital of his/her business, the investment plan and the amount requested if does have a logic. If you found discrepency in both ways, ask the client for eplanation.
And what if the amount doesn't correspond to his/her profile or for the loan doesn't have a logic? Or the client doesn't have or refuse to give explanations?
Being involved in money laundering or terrorism financing activities is a criminal offences
You should then notify instantly your Supervisor or the Compliance Officer for further actions.
Being convicted to ML/TF crime, you are liable up to *Immediate dissolution for legal entity and a fine of (20) times the amount of money laundered or given, without prejudice to the liability for complicity of its representatives. * 15 years term imprisonment and a fine of (10) times the value of the amount of money given or laundered.
Read more about a recent ML case in Kenya: https://goo.gl/VAZkqP
For more details please refer to the attached Law and policy or refer to your supervisor or the Compliance officer.
That's feasible! Thank you, we will ensure that it's done!