General Statement Concerning Compliance With Anti-Money-Laundering Requirements

IKB's main area of business is financing for small and medium enterprises in Germany.

IKB and its branches, affiliates and subsidiaries are firmly committed to participating in international efforts to combat money laundering and the funding of terrorist and criminal activities.

IKB has its headquarter in Düsseldorf, Germany, and is supervised by the German Federal Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht - BaFin):

Bundesanstalt für Finanzdienstleistungsaufsicht
Graurheindorfer Str. 108
53117 Bonn, Germany
and
Lurgiallee 12
60439 Frankfurt

The Federal Republic of Germany is a member country of the Financial Action Task Force (FATF) and the European Union (EU) and has enacted laws and rules designed to implement the anti-money-laundering policies of both the FATF and the EU. The goal of these laws is to detect and prevent money laundering and potential terrorist financing.

IKB implements an anti-money-laundering program that is designed to comply with certain required German anti-money-laundering rules as a minimum standard throughout the bank as well as with all local laws, regulations and guidance relating to the prevention of money laundering, terrorist financing and related financial crimes. These include written policies and procedures, a designated anti-money-laundering officer and training for employees.

As part of its anti-money-laundering and anti-terrorist compliance efforts, IKB takes steps to ensure that it complies with any and all embargo regulations applicable in the EU and in the jurisdiction in which any respective branch or office is domiciled. IKB does its utmost to ensure compliance with prohibitions and restrictions and to detect suspicious activities. In accordance with the relevant EU directives and to prevent business operations from being used for terrorist financing, IKB runs a regular computer checks on all business partners against the up-to-date EU sanction lists.

An essential part of IKB´s Anti-Money-Laundering Policy is the identification of customers by official documents and other relevant information. Whenever IKB is required to identify a customer, the ultimate beneficiary (of the account/the cash transaction) must be established. If doubts remain about whether the person to be identified is acting on his/her own account, or in cases where it is obvious that the person is not act on his/her own account, IKB will take reasonable and appropriate steps to obtain information about the real identity of the person for whom the customer is acting.

Any suspicious activities detected are reported to the responsible law enforcement authorities, including the Financial Intelligence Unit (FIU) in Germany, which has been created at the Federal Investigation Office (Bundeskriminalamt).
Under section 25g of the German Banking Act (§ 25g Kreditwesengesetz) IKB must ensure that the statutory duties resulting from the regulations set out in this Act are fulfilled by its domestic and international branches, subsidiaries and affiliates.

IKB hereby certifies that the bank cannot be deemed a shell bank within the meaning of the U.S. Patriot Act. Pursuant to the regulations of the U.S. Patriot Act IKB has prepared a Global Certification for use by any financial institution and offers its business partners the opportunity of downloading its Global Certification Form.

Both the internal audit division and the external auditors perform annual audits to establish whether the measures to combat money laundering are reasonable and appropriate and whether the IKB Anti-Money-Laundering Officer has acted in accordance with the responsibilities assigned to him.

If you have any questions or require additional information regarding IKB´s anti-money laundering efforts, please contact:

Rainer Pfläging, Deputy Anti-Money-Laundering Officer +49 (0)211 8221-4320
Luitgard Leibmann, Deputy Anti-Money-Laundering Officer +49 (0)211 8221-4340