Compliance with Anti-Money Laundering Requirements, Sanctions and Embargos

IKB Deutsche Industriebank Aktiengesellschaft (IKB) is a stock company incorporated under the laws of the Federal Republic of Germany with its registered office in Düsseldorf. IKB is supervised by the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, or BaFin), and by the European Central Bank (ECB).

IKB supports medium-sized enterprises in Germany and Europe with loans, risk management, capital market services, and advisory services. As part of its online services, IKB offers its private clients various daily and fixed-term deposits, payments plans, and selected securities.

The Federal Republic of Germany is a member country of the Financial Action Task Force (FATF) and the European Union (EU), and it 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 and its branches, subsidiaries and affiliates are firmly committed to participating in these international efforts. IKB has implemented an anti-money laundering program throughout the bank that is designed to comply with certain required German anti-money laundering rules as a minimum standard. In addition, IKB’s program complies with all applicable local laws, regulations, and guidance relating to the prevention of money laundering, terrorist financing, and financial crimes.

The Know-Your-Customer principle is applied by IKB Group in order to obtain the highest level of transparency in its business relationships and in individual transactions. The Know-Your-Customer principle comprises the identification and documentation of the client’s identity as well as the determination of beneficial ownership.

IKB Group 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 regularly runs computerized checks on all business partners against current EU sanction lists.

If doubts remain about whether a transaction violates the above mentioned rules (after taking into account the background of the customer, the source of the money and the type of the transaction), appropriate measures have to be taken into account. This could lead to the complete termination of the business relationship.

IKB’s internal audit division and external auditors both perform audits to establish whether the measures to combat money laundering are reasonable and appropriate.

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 Form for use by any financial institution.

For further details please see the following: The Wolfsberg Group Anti-Money Laundering Questionnaire.
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