North Africa Commercial Bank S.A.L (NACB) is regulated by Central Bank of Lebanon-Banque Du Liban (BDL) which is mandated to exercise AML/CFT regulatory oversight on financial institutions and reporting entities. This function is carried out by Special Investigation Commission (SIC) or stated differently, Lebanon’s Financial Intelligence Unit (FIU) which is an independent legal entity with judicial status.

Our AML/CFT Policy

The principal objective of adopting a clear AML/CFT policy is the establishment of a general framework for the fight against money laundering, terrorism financing, corruption, and other financial crimes. Successful participation in this fight by the financial sector requires an unprecedented degree of global cooperation between governments, standard setters, regulators, and financial institutions. Our institution is highly committed to fight money laundering and terrorism financing and is determined to combat all illicit financial flows generated from predicate crimes linked to money laundering.

To this effect, we have put in place high compliance standards coupled with sound corporate governance principles whereby we require management and employees to adhere to these standards in preventing the use of our products and services for money laundering purposes or terrorism financing. In order to keep our institution immune from money laundering risks, we have designed strict Know Your Customer (KYC) policy by thoroughly vetting and running background checks on all new customers as well as analyzing the ownership structures of legal entities to determine the Ultimate Beneficial Owner (UBO). These strict procedures are not only applied during the on-boarding stage, but continue also throughout the on-going relation to monitor against any substantive change in customer profile and circumstances.

Compliance Program

NACB has detailed policies and procedures along with an AML Manual approved by senior management and the Board, designed to prevent involvement in money laundering or terrorist financing and to ensure utmost regulatory and legal compliance. It should be noted here that NACB has never been fined or censured for breaches of money laundering prevention regulations.

General Policies

  • NACB complies with the letter and spirit of all laws, regulatory requirements, codes and standards of best market practice
  • NACB has appointed a Certified AML/CFT Compliance Officer (MLRO) in accordance with regulatory requirements
  • NACB operations staff are required by virtue of the law to report any suspicious transaction to the operation control officer at the branch who shall consequently inform the AML/CFT Unit or the Money Laundering Reporting Officer (MLRO)
  • NACB prohibits the opening of anonymous and prohibits dealing with banks which don’t have physical presence i.e. “shell banks”
  • NACB doesn’t operate PTA “payable through accounts”
  • NACB has independent internal audit and risk management functions that regularly monitor the effectiveness of and compliance with its money laundering preventions policies and procedures
  • NACB retains all transaction and identity verification records for at least 5 years after ending a relationship

Transaction Reporting and Monitoring

  • NACB utilizes automated reports generated from its Temenos (Globus) core system to identify unusual patterns of account activity against known customer business
  • NACB screens all customers and transactions against terrorist lists issued by government agencies, central banks and other international bodies, when initially on-boarding and regularly throughout a continuing relationship
  • Appropriate procedures are designed and put in place to report suspicious transactions via AML/CFT Compliance Officer to relevant authorities

AML Training

  • NACB has a well-developed and comprehensive training and communication program to ensure that all staff are aware of the dangers of money laundering and terrorism and understand their legal obligations including any changes to laws and procedures
  • All records of attendees and material used in AML training sessions are retained