Compliance

Saradar bank (“The Bank”) is committed to maintaining the highest standards of Anti-Financial Crimes (AFC) including but not restricted to Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), Anti-Fraud, Anti-Bribery and Corruption, preventing tax evasion, and abiding by the Sanctions Program mainly:

• to prevent illegal activities• to preserve the reputation and integrity of the bank• to protect the interests of our stakeholders, including customers, shareholders and regulators

The Bank strives to comply with all applicable regulations and standards.

The Bank is mainly subject to the following regulatory bodies:

• Central Bank of Lebanon (www.bdl.gov.lb)• Special Investigation Commission (www.sic.gov.lb)• Banking Control Commission of Lebanon (www.bccl.gov.lb)• Capital Markets Authority (www.cma.gov.lb)

Moreover, Saradar Bank has adopted the recommendations of international industry groups including:

• The Financial Action Task Force (FATF)• The European Union (Directives)• The Basel Committee on Banking Supervision• The Egmont Group• The Wolfsberg Group• The international standards as set out by major global correspondent banks and their regulators

The following key principles are adopted by Saradar Bank to identify and properly manage its non-compliance risks, reflected in its AML Compliance program, and elaborated in its procedures:

• Top down approach• Risk based customer acceptance approach• Customer profiling and screening program• Sanctions management framework• Maintain robust correspondent banking relationships• Fight against tax evasion• Anti-Bribery and Corruption management system• On-going monitoring• Auditing and independent testing• Internal and external suspicious activities reporting• No tipping-off• Document retention• Raising awareness