STANDARD KYC & AML POLICY


1. Standard KYC procedures & compliance

As a responsible financial institution, RSB ensures it is in complete compliance with all applicable industry standards. We focus on enduring relationships with our clients and are proud of our ability to serve each client according to their specific needs and goals.

In addition to building excellent client relationships, we also comply with relevant anti-money laundering laws in a way that enables us to protect our clients’ assets and provide them first-rate financial services.

To balance this compliance and service issue, RSB requires original or certified/notarized ID and proof of residence for all corporate accounts.

Our standard KYC requirement for account opening includes providing the following:

If the account is opened for a company:

  • Certificate of incorporation;
  • Memorandum and Articles;
  • Certificate of good standing if the company is older than 1 year;
  • Appointment of director and shareholders;
  • Register of Directors and Members;
  • Power of Attorney and Deed of trust (when applicable).

All documents must be certified by a notary, lawyer or a bank.

For all beneficial owners (or private accounts):

  • Passport and ID copy;
  • Utility bill less than 3 months (as proof of address);
  • OR client’s last bank statement;
  • Client’s background;
  • Description about source of funds.

RSB can ask its clients to justify certain financial transactions. If you are asked such questions,you will be expected to provide us relevant contracts, invoices or purchase orders. We reserve the right to contact the parties associated with such transactions to verify their legitimacy.

RSB notifies all account debits to the account holders via email. Sometimes, we can also call on the given contact number to verify who is using the system/account. This necessitates that you notify us in case of a change of contact details.

RSB’s objective is to keep our institution above reproach, and we appreciate our clients’cooperation in helping us comply with all applicable legislation.


2. AML policy

2.1. Policy and definition

RSB enforces a strict anti-money laundering policy with zero tolerance for money laundering activities. We define money laundering as any activity that is carried out in an attempt tomisrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.

All RSB affiliates are obligated to comply with RSB’s anti-money laundering policy and with all applicable anti-money laundering laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.

RSB ensures complete compliance with laws pertaining to anti money laundering through its related policy. At RSB, fund transfers related to gambling without an duly obtained license from official government, or any kinds of illegal activity are strictly forbidden. RSB will immediately stop any such financial activity as soon as it is identified because such activities go against the spirit of RSB and the principles on which this institution was founded.

RSB implements a range of filtration operations for swift and accurate identification of any financial activities that may constitute or are related to money laundering. This helps ensure a money laundering-free financial operations throughout the RSB system.

All RSB clients acknowledge, undertake and agree to the following terms regarding their use of this website, opening and maintenance of accounts at RSB and for all financial transactions(including funds transfer, ATM cash withdrawal and debit card use) as a RSB client:

2.1.1. The client will comply (throughout the time as a RSBclient with all relevant statutes pertaining to money laundering and proceeds from criminal activities.

2.1.2. RSB operates under certain obligations known as “know-your-client” obligations which grant RSB the right to implement anti money laundering procedures to help detect and prevent money laundering activities where money laundering may mean to handle any funds associated with any illegal activity regardless of the location of such activity.

2.1.3. The client agrees to lend full cooperation to RSB with respect to anti money laundering efforts. This involves providing information that RSB requests regarding the client’s business details, account usage, financial transactions etc. to help RSB perform its duties as dictated by applicable laws regardless of jurisdiction.

2.1.4. RSB reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices.

2.1.5. RSB reserves the right to suspend or terminate any account or freeze the funds in an account if there is reason to believe that the account is being used for activities that are deemed unlawful or fraudulent.

2.1.6. RSB has the right to use client information for the investigation and/or prevention of fraudulent or otherwise illegal activities.

2.1.7. RSB has the right to share RSB information with:

  • Investigative agencies or any authorized officers who are helping RSB comply with applicable law, including anti-money laundering laws and know-your-client obligations;
  • Organizations that help RSB provide the services it offers its clients;
  • Government, law enforcement agencies and courts;
  • Regulatory bodies and financial institutions.

2.2. Risk assessment

RSB uses its standardized risk rating model to conduct risk assessment related to the exposure to money laundering across all clients relationships. RSB Board of Directors approves this model once every year.

2.3. Activities that RSB deems suspicions

Activities that RSB considers possible indications of money laundering include:

  • The client showing unusual apprehension or reservations about RSB’s anti-money laundering policies.
  • The client’s interest in conducting financial transactions which are contrary to good business sense or are inconsistent with the RSB’s business policy.
  • The client failing to provide legitimate sources for their funds.
  • The client providing false information regarding the source of their funds.
  • The client having a history of being the subject of news that is indicative of civil or criminal violations.
  • The client seems to be acting as a ‘front man’ for an unrevealed personality or business, and does not satisfactorily respond to requests for identifying this personality or business.
  • The client not being able to easily describe the nature of his/her industry.
  • The client frequently makes large deposits and demands dealing in cash equivalents only.
  • The client maintains multiple accounts and conducts an unusually high number of inter-account or 3rd party transactions.
  • The client is a native of, or has accounts in, a country on Financial Action Task Force’s list of Non- Cooperative Countries or Territories.
  • The client’s previously usually inactive account starts receiving a surge of wire activity.

The above list is by no means an exhaustive list; RSB monitors its clients and account activity in light of several other red flags and takes appropriate measures to prevent money laundering.

2.4. RSB’s identification procedures

RSB utilizes customer identification procedures to validate the true identity of its clients. Documenting and maintaining these identification procedures enhances RSB’s ability to prevent money laundering activities. If RSB fails to verify a client’s identity within an acceptable time period, all services will be suspended for that client and any accounts opened will be terminated. In addition, the account and services attached to that client will be under stricter scrutiny until the suspension and/or closure is carried out.

IDENTIFICATION PROCEDURES FOR NATURAL PERSONS

RSB requires the following information for natural persons:

  • Legal and other names used such as maiden name;
  • Complete permanent address;
  • Telephone and fax number;
  • Email address;
  • Date and place of birth;
  • Nationality;
  • Occupation details, client’s background;
  • Any unique identification number from a valid official document bearing a photograph of the client such as ID card, passport or driving license;
  • Source of wealth.

IDENTIFICATION PROCEDURES FOR BUSINESS ENTITIES

RSB requires the following information for business entities:

  • Entity’s name;
  • Entity’s mailing address;
  • Telephone number;
  • Any kind of official identification number, if available, such as tax identification number;
  • Certificate of Incorporation (original or certified copy);
  • Memorandum and Articles of Association (original or certified copy);
  • Nature and purpose of business;
  • Proof of legitimacy of business operations.

RSB verifies the above information via at least one of the following methods:

  • Reviewing the latest audited accounts in case of a corporate entity;
  • Utilizing a business information service or attorney to enquire about the entity;
  • Conducting commercial enquiries to ensure the entity is a going concern;
  • Leveraging independent information verification services e.g. databases;
  • Acquiring previous bank references;
  • Visiting the corporate entity;
  • Contacting the corporate entity using the contact details provided.

Any supporting documents can be certified by RSB employees, Lawyer, Notary, or any approved agent or official introducer who has signed a certification right agreement with RSB.

2.5. Record keeping

RSB keeps all relevant documents and service records for the minimum time as determined by applicable law.

2.6. Training

RSB implements a comprehensive training policy under which it imparts anti-money laundering training to every new employee. In addition to initial training, RSB employees also have to complete an annual anti-money laundering training program.

Moreover, employees involved in anti-money laundering roles are also required to participate in special training programs.

As a result of this comprehensive training policy, all RSB employees who are tasked with providing RSB’s services and/or deal with RSBs (directly or indirectly) are fully aware of all applicable anti- money laundering laws and regulations. All RSB employees are therefore in the ideal position to perform their duties in complete compliance with RSB’s AML policy, and with all applicable laws, statutes and regulations.

2.7. Administration

An AML Compliance Officer administers the anti-money laundering policy at RSB. The board’s responsibilities include interpreting, revising and implementing RSB’s AML policy.

2.8. Procedures for STR

Any staff identifying an account or transaction as suspicious is required to report the case to the Compliance Officer (CO). The CO will review the facts and determine whether the suspicion is allayed or whether a report to the regulator is required. If necessary the CO will discuss the transaction with the General Manager but if suspicions remain, the filing of a Suspicious Transaction Report (STR) cannot be suppressed. Under no circumstances will staff “Tipp-off” the customer that an STR is being prepared.