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AML Statement

Anti-Money Laundering Acknowledgement and Global Certification Regarding Foreign Correspondents Relationships (WLAHDE44XXX)

Administrative Details Details
Name Sparkasse Herford (BaFin Reg. No 100 856)
Founded in Herford, Germany
Registered Office Auf der Freiheit 20 in 32052 Herford
Business Area The district of Herford (Kreis Herford)
Is the bank publicly listed on a stock exchange? No
The Board of Management:

Chairman:
Peter Becker (Vorsitzender)

Members:
Horst Prüßmeier (Mitglied)

Our principal business activities and services are as follows Savings bank, universal and regional bank, corporate and private customers; mortgage lending, retail banking

Applicable laws

Is the bank subject to laws and regulations for the prevention of money laundering and the financing of terrorists? Yes
Relevant laws and regulations:
EU regulations and directives
  • Geldwäschegesetz (GWG)
    [Money Laundering Prevention Law]
  • Kreditwesengesetz (KWG)
    [Banking Law]
  • Außenwirtschaftsgesetz (AWG)
    [Foreign Trade & Payments Law]
  • Wertpapierhandelsgesetz (WPHG)
    [Securities Trading Law]
  • Amtliche Verlautbarungen des BaFin
    [Official statements of BaFin]
  • Sparkassengesetz NRW (SpkG NRW)
    [North Rhine-Westphalia Savings Banks Law]
 

Regulatory Authority

 
Is our bank subject to the supervision of any regulatory authority? Yes

Name of Auditors:

Sparkassenverband Westfalen-Lippe
Regina-Protmann-Str. 14
8159 Münster
Germany

Name of Regulator:

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Graurheindorfer Str. 108
53117 Bonn
Germany

 

AML policy and practice

 
Does our institution have a written policy against money laundering and terrorist financing?  
Does this policy meet FATF standards?  

Is the policy applicable to the headquarters, all branches and subsidiaries, including foreign branches and offices?

Yes

We verify the customer's true identity with the help of reliable, independent documentary, data and information sources and we retain all relevant documents and information relating to the customer's identity and transactions in accordance with the requirements of the regulatory  authority.

Furthermore Sparkasse Herford does not have any foreign branches and offices.

 
 Does our bank have an independent audit and/or compliance review function to test the adequacy of policy and procedures? Yes

Operational area

 
Does our bank maintain a correspondent banking relationship to a shell bank or do business with a shell bank ( A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group)? No
Does our institution have a policy prohibiting correspondent accounts/ relationships with shell banks? Yes
Does our institution have policies to reasonably ensure that we will not conduct transactions with or on behalf of shell banks through any of our accounts or products? Yes
Does our institution have policies to reasonably ensure that it only
operates with correspondent banks that possess licences to operate in
their countries of origin?
Yes
Does our institution obtain sufficient information to gain an
understanding of our correspondents' business, reputation and regulatory
history?
Yes
Are all new correspondent relationships approved by a Senior Manager? Yes

Does our bank offer "Payable Through Accounts" or any other accounts which can transact through nostro and vostro accounts?

(Payable Through Accounts are a type of correspondent banking account which is subdivided by the foreign bank into sub-accounts, each in the name of one of the foreign bank's customers, thus giving foreign bank's customers direct access to the products of the first financial institution.)

No
Does our bank maintain anonymous accounts, or numbered accounts for which we do not collect the full details of the beneficial owner? No
Does our bank monitor customer account databases for terrorist names? Yes
Does our institution require full details for outgoing wire transactions, i.e. sender and beneficiary names, address and account number in accordance with the requirements of the regulatory authority? Yes
Does our institution have any restrictions under our Banking Licence e.g. is our institution only limited to conducting business with non-residents or in non-local currencies? No
Do you ensure that every customer who has maintained an account at your institution can be identified for a period of at least five years after their accounts were closed? Yes
Does your institution identify the economic owners of corporate enterprises? Yes

Risk management details

 

Has a compliance office been set up and is a compliance officer in charge of supervising and coordinating efforts against money laundering  and terrorist financing as well as monitoring compliance?

 

Yes

Contact address:

Sparkasse Herford
Geldwäschebeauftragter/ AML Officer
Auf der Freiheit 20
32052 Herford
Germany

 
Does our institution determine the appropriate level of enhanced and ongoing due diligence necessary for those categories of customers and transactions that we have reason to believe pose a heightened risk of money laundering and terrorist financing activities at or through our institution? Yes
Does our institution take steps to understand the normal and expected transactions of our customers based on our risk assessment of our customers? Yes
Has our institition implemented systems for the identification of all our customers at account opening, including verification of customer information from independent and reliable sources (e.g. name, street address, date of birth, number and type of valid official identification)? Yes
Does our institution have procedures to establish a record for each customer noting their respective identification documents and Know Your Customer Information collected at account opening? Yes
AML TrainingDoes our institution provide AML training to relevant employees that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms of money laundering involving our products and services and internal policies to prevent money laundering? Yes
Does our institution retain records of our training sessions including attendance records and relevant training materials used? Yes
Does our institution have policies to communicate new AML related laws or changes to existing AML related policies or practices to relevant employees? Yes
Does our institution employ agents to carry out some of the functions of our institutions and if so does our institution provide AML training to relevant agents that includes identification and reporting of transactions that must be reported to government authorities, examples of different forms money laundering involving our institution's products and services and internal policies to prevent money laundering? Yes

Transaction monitoring

 
Does our institution have a monitoring program for suspicious or unusual activity that covers funds transfers and monetary instruments (such as travellers cheques, money orders, etc)? Yes
Does our institution filter payments against relevant sanctions lists? Yes
Reportable transactions and prevention and detection of transactions with illegally obtained fundsDoes our institution have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities? Yes
Does our institution have procedures to identify transactions structured to avoid large cash reporting requirements? Yes
Does our institution screen transactions for customers or transactions we deem to be of significantly heightened risk (which may include persons, entities or countries that are contained on lists issued by government/ international bodies) that special attention to such customers or transactions is necessary prior to completing any such transactions? Yes
Compliance statusDoes our bank respect the currently valid laws and internal guidelines for the prevention of money laundering and the financing of terrorists? Yes
Has our institution been involved in any regulatory or criminal enforcement actions resulting from violations of laws or regulations against money laundering and terrorist financing in the past 5 years? No
Herford, 01. Januar 2013  
US Patriot Act

Die amerikanische Gesetzgebung schreibt US-Banken, US-Wertapierbrokern und -händlern vor, Pflichtinformationen über Banken, mit denen diese im Geschäftsverkehr stehen, vorzuhalten.

Die Sparkasse Herford hält folgende Informationen für Sie bereit:

Legend:

U.S. legislation obliges U.S. Banks, U.S. brokers and dealers in securities to provide information about banks with which they regularly do business.

Sparkasse Herford is pleased to provide the following information:

  1. US Patriot Act certification
  2. Anti-Money-laundering (AML) statements and global certification regarding foreign correspondent relationships

Certification

US-Patriot Act certification

The undersigned financial institution, Sparkasse Herford, hereby certifies as follows:

A. This Certification applies to all accounts established for Sparkasse Herford covered by Financial Institutions.

B. Physical Presence/Regulated Affiliate Status:
Sparkasse Herford maintains a physical presence. That means:
Sparkasse Herford has a place of business at the following street address: Auf der Freiheit 20, 32052 Herford, where Sparkasse Herford employs one or more individuals on a full-time basis and maintains operating records related to its banking activities.

The above addresses are in Germany, where Sparkasse Herford is authorized to conduct banking activities.

Sparkasse Herford is subject to inspection by Bundesanstalt für Finanzdienstleistungsaufsicht, Graurheindorfer Str. 108, 53117 Bonn, the banking authority that licensed Sparkasse Herford to conduct banking activities.

C. Indirect Use of Correspondent Accounts:
No Correspondent Account maintained by a Covered Financial Institution may be used to indirectly provide banking services to certain foreign banks. Sparkasse Herford hereby certifies that it does not use any Correspondent Account with a Covered Financial Institution to indirectly provide banking services to any foreign bank that does not maintain a physical presence in any country and that is not a regulated affiliate.

D. Ownership Information: Sparkasse Herford has no owner(s) except as set forth below. For purposes of this Certification, owner means any person who, directly or indirectly, owns, controls, or has power to vote 25 percent or more of any class of voting securities or other voting interests of Sparkasse Herford; or (b) controls in any manner the election of a majority of the directors (or individuals exercising similar functions) of Sparkasse Herford. For purposes of this Certification, (i) person means any individual, bank, corporation, partnership, limited liability company or any other legal entity; (ii) voting securities or other voting interests means securities or other interests that entitle the holder to vote for or select directors (or individuals exercising similar functions); and (iii) members of the same family* shall be considered one person. *The same family means parent, spouses, children, siblings, uncles, aunts, grandparents, grandchildren, first cousins, stepchildren, stepsiblings, parents-in-law and spouses of any of the foregoing. In determining the ownership interest of the same family, any voting interest of any family member shall be taken into account.

Name:
Sparkasse Herford
Adresse: Auf der Freiheit 20
32052 Herford
Germany

The Sparkasse Herford as the responsible body (Träger) for the Sparkasse Herford is owned by the cities of Herford (100%).

E. General Sparkasse Herford hereby agrees to notify in writing each Covered Financial Institution at which it maintains any Correspondent Account of any change in facts or circumstances reported in this Certification. Notification shall be given within 30 calendar days of such change. Sparkasse Herford understands that the statements contained in this Certification may be transmitted to one or more departments or agencies of the United States of America for the purpose of fulfilling such departments' and agencies' governmental functions.

We, Sparkasse Herford, certify that we have read and understood this Certification, that the statements made in this Certification are complete and correct, and that we are authorized to execute this Certification on behalf of Sparkasse Herford.

Sparkasse Herford
Auf der Freiheit 20
32052 Herford
Germany

Herford, 11. October 2016

AML Questionaire

Anti-Money Laundering Questionnaire

If you answer “no” to any question, additional information can be supplied at the end of the questionnaire.

I. General AML Policies, Practices and Procedures: Yes / No

1. Is the AML compliance program approved by the FI’s board or a senior committee?

2. Does the FI have a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework?

3. Has the FI developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions?

4. In addition to inspections by the government supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis?

5. Does the FI have a policy prohibiting accounts/relationships with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group.)

6. Does the FI have policies to reasonably ensure that they will not conduct transactions with or on behalf of shell banks through any of its accounts or products?

7. Does the FI have policies covering relationships with Politically Exposed Persons (PEP’s), their family and close associates?

8. Does the FI have record retention procedures that comply with applicable law?

9. Are the FI’s AML policies and practices being applied to all branches and subsidiaries of the FI both in the home country and in locations outside of that jurisdiction?

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes
 

II. Risk Assessment

Yes / No

10. Does the FI have a risk-based assessment of its customer base and their transactions?

11. Does the FI determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the FI has reason to believe pose a heightened risk of illicit activities at or through the FI?

Yes

Yes
 

III. Know Your Customer, Due Diligence and Enhanced Due Diligence Yes / No

12. Has the FI implemented processes for the identification of those customers on whose behalf it maintains or operates accounts or conducts transactions?

13. Does the FI have a requirement to collect information regarding its customers’ business activities?

14. Does the FI assess its FI customers’ AML policies or practices?

15. Does the FI have a process to review and, where appropriate, update customer information relating to high risk client information?

16. Does the FI have procedures to establish a record for each new customer noting their respective identification documents and ‘Know Your Customer’ information?

17. Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customers?

Yes

Yes

Yes

Yes

Yes
 

Yes

IV. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds Yes / No

18. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?

19. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations?

20. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities?

21. Does the FI have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin?

22. Does the FI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202COV and MT 205/205COV message formats?¹

Yes

Yes

Yes

Yes
 

Yes
 

V. Transaction Monitoring

Yes / No
23. Does the FI have a monitoring program for unusual and potentially suspicious activity that covers funds transfers and monetary instruments such as travelers checks, money orders, etc? Yes
 
VI. AML Training Yes / No

24. Does the FI provide AML training to relevant employees that includes:

  • Identification and reporting of transactions that must be reported to government authorities.
  • Examples of different forms of money laundering involving the FI’s products and services.
  • Internal policies to prevent money laundering.

25. Does the FI retain records of its training sessions including attendance records and relevant training materials used?

26. Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees?

27.Does the FI employ third parties to carry out some of the functions of the FI?

28. If the answer to question 27 is yes, does the FI provide AML training to relevant third parties that includes:

  • Identification and reporting of transactions that must be reported to government authorities.
  • Examples of different forms of money laundering involving the FI’s products and services.
  • Internal policies to prevent money laundering.

Yes



Yes

Yes

Yes

Yes

Yes


 

¹ The four payment message standards to be observed are: i) FIs should not omit, delete, or alter information in payment messages or orders for the purpose of avoiding detection of that information by any other FI in the payment process; ii) FIs should not use any particular payment message for the purpose of avoiding detection of information by any other FI in the payment process; iii) Subject to applicable laws, FIs should cooperate as fully as practicable with other FIs in the payment process when requesting to provide information about the parties involved; and (iv) FIs should strongly encourage their correspondent banks to observe these principles. Source: http://www.wolfsberg-principles.com

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Société Générale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.  

 
Key figures

Key figures

Legal Notice
Bank code:   49450120
BIC-Code: WLAHDE44XXX
Commercial Register Number: HRA 4596 beim Amtsgericht Bad Oeynhausen
sales tax identification number::   DE125364897
Chairman of the Board:   Peter Becker
Member of the Board:   Horst Prüßmeier
Telefon: 05221 / 16 - 0
Fax:   05221 / 16 - 1617
E-Mail:    kontakt@sparkasse-herford.de
Controlling institution:

Bundesanstalt für Finanzdienstleistungsaufsicht
Graurheindorfer Straße 108
D - 53117 Bonn

und

Marie-Curie-Straße 24-28
D - 60439 Frankfurt am Main

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