Gulf Finance and Investment Company is determinedly committed to join the International efforts in combating Money Laundering and Terrorist Financing. As such, GFIC has established a policy to comply with Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) in line with the Financial Action Task Force on money laundering (FATF), local regulations and international standards.

GFIC COMPLIANCE PROCESS

As per the legal requirements, GFIC has implemented specific measures to ensure compliance with all regulations concerning Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) regulations. These measures entail:

  • ESTABLISHING A COMPLIANCE COMMITTE AND DETERMINING THE ROLES OF ADMINISTRATIVE UNITS IN CHARGE OF FIGHTING MONEY LAUNDERING AND COMBATING TERRORIST FINANCING
      • GFIC has a compliance unit working under the oversight of the compliance committee to ensure that GFIC is complying with all relevant laws and regulations relating to anti-money laundering and Counter Terrorist Financing (CTF).
      • The compliance program at GFIC includes a designated compliance officer responsible for coordinating and overseeing the AML and the CTF framework.
      • In addition to the inspections done by “Banque du Liban” GFIC has an internal audit department and external auditors overseeing the apposite application of the AML and CTF policies and procedures.
      • The Internal Audit Department reviews the effectiveness of the compliance procedures and controls at least annually.
  • RELATIONSHIP WITH CORRESPONDENT BANKS AND ULTIMATE BENEFICIARIES
      • GFIC will not establish, maintain, administer or manage a Correspondent Account for a Shell Bank.
      • GFIC will take reasonable steps to ensure that its Correspondent Bank will not use its Correspondent Account to provide banking services to a shell bank.
  • RELATIONSHIP WITH CUSTOMERS: DUE DILIGENCE MEASURES
    • GFIC believes that sound KYC policies and procedures are critical in protecting the safety and soundness of the company.
      • The “Know Your Customer” or KYC principle is applied, so as to make known the customer’s actual identity, his/her business profile and his/her intentions regarding the way of operation.
      • GFIC will obtain all information necessary to establish to its full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship.
  • ON-GOING MONITORING OF ACCOUNTS AND TRANSACTIONS
      • GFIC has set up procedures to monitor customers’ transactions and to fulfill the detailed requirements in compliance with BDL circular 83.
      • To ensure that records remain up-to-date and relevant, GFIC undertakes regular reviews of existing records and periodically checks the identity of the clients and monitors the accounts opened and operations carried
      • GFIC has a risk-based assessment of its customer base and their transactions.
  • REPORTING
      • GFIC has policies and procedures in place for the identification and reporting of transactions that are required to be reported to relevant authorities.
      • GFIC screens customers and transactions against lists of persons, entities or countries issued by the SIC and by other relevant authorities.
  • RECORD KEEPING
    • In compliance with BDL circular 83, GFIC keeps, at least for five years after implementing the operation or closing the account, the full name and residential address of the client, with information about the professional and financial status of the said client, together with copies of all documents used in the checking process.
  • COMPLIANCE TRAINING
    • GFIC ensures ongoing trainings for its staff to emphasize compliance issues, new circulars, means of controlling operations, AML risk awareness, fighting money laundering and Terrorist Financing and other relevant topics.


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