FINANSBANK AML/KYC PROCEDURES

FINANSBANK
ANTI-MONEY LAUNDERING / KNOW YOUR CUSTOMER

PROCEDURE
DEFINITIONS
Terrorist
Financing
The provision of funds or material mediums or in any way receiving,

collecting, disposing, or managing funds with the intention to facilitate or
assist the execution of terroristic actions either by a terrorist organization or
by any individual terrorist.
As money laundering, the following conduct shall be regarded:
the conversion or transfer of property, knowing that such property is derived
from criminal activity or from an act of participation in such activity, for the
purpose of concealing or disguising the illicit origin of the property or of
assisting any person who is involved in the commission of such activity to
evade the legal consequences of his action,
Money
Laundering
the concealment or disguise, through any medium, of the true nature,

source, location, disposition, movement, rights with respect to, or ownership
of property, knowing that such property is derived from criminal activity or
from an act of participation in such activity,
the acquisition, possession or use of property, knowing, at the time of
receipt, that such property was derived from criminal activity or from an act
of participation in such activity,
the utilization of the financial sector by placing therein or moving through it
proceeds from criminal activities for the purpose of lending false legitimacy
to such proceeds,
the setting up of organization or group comprising two persons at least, for
committing one or more of the acts defined above and the participation in
such organization or group.
Criminal Activities shall denote the commission of one or more of the
following offences:
participation in an organized criminal group,
Criminal
activities
terrorist activities and terrorist financing,

passive and active bribery,
bribery of judges,
trafficking in human beings,
computer fraud,
sexual exploitation and narcotic drugs,
bribery of employees
offences regarding weapons, ammunition, explosives, etc,
offences regarding antiquities and cultural heritage in general,
any other offence punishable by deprivation of liberty for a minimum of
more than six months and having generated any type of economic benefit
Suspicious
transaction
Unusual
transaction
Due
Diligence
Suspicious transaction is the case where there is an information, suspicion or

reasonable grounds to suspect that the asset, which is subject to the
transactions carried out or attempted to be carried out within or through the
obliged parties, has been acquired through illegal ways or used for illegal
purposes, used for terrorist activities or by terrorist organizations, terrorists or
those who finance terrorism or connected or linked with them.
Transaction or transactions or activities incompatible with the customers or
beneficial owners economic/transacting profile (transactional, professional or
business behaviour, financial condition) or have no apparent purpose or
motive of a financial, professional or personal nature.
Measures for the collection and maintenance of adequate information on a
customer, the use of such information for identification purposes and the
assessment of his overall economic/transacting profile on basis of procedures
that are comprised according to the relevant risk that they represent
regarding the use of the financial sector for ML/FT.
Due diligence measures form the basis for AML/CFT procedures and constitute
the most effective protection against negative effects on Banks solvency and
reputation.
Politically exposed persons are the natural persons who are or have been
entrusted with prominent public functions and immediate family members, or
persons known to be close associates, of such persons Natural persons
entrusted with a prominent public functions include:
heads of state, heads of government, ministers, alternate and deputy
ministers,
P.E.P.s
members of Parliament (MPs),

judges of supreme courts, constitutional courts or other high-level judicial
bodies,
judges of courts of auditors and members of the boards of central banks,
ambassadors, chargs d affaires and high-ranking officers in the armed
forces ,
members of the administrative, management or supervisory bodies of stateowned enterprises.
Immediate
family
members
of P.E.P.s
the spouse,
any partner considered by national law as equivalent to a spouse,
natural or adopted children and their spouses or partners, and
the parents.
Persons
known
to
be
close
associates
any natural person who is known to have joint beneficial ownership of legal
entities or legal arrangements, or any other close business relationships with
a P.E.P,
any natural person who has sole beneficial ownership of a legal entity or
of P.E.P.s
legal arrangement which is known to have been established for the benefit of
a P.E.P.
Electronic
funds
transfer
Any transaction that is carried out on behalf of a payer, through a credit or

financial institution, by electronic means, with a view to making funds
available to a payee in another credit or financial institution. The payer and
payee may be the same person.
Crossborder
funds
transfer
A funds transfer where the credit or financial institution receiving the order
from the payer is subject to a different legislation form that of the credit or
financial institution that constitutes the transferred funds at payee disposal.
Shell Bank
A credit institution or an institution engaged in equivalent activities,

incorporated in a jurisdiction in which it has no physical presence, involving
meaningful mind and management, and which is unaffiliated with a financial
group that meets the regulatory and supervisory requirements of Community
legislation or at least equivalent requirements.
Beneficial
Owner
Beneficial owner means natural persons who carry out a transaction

within an obliged party, and natural person(s) who control(s) the
natural persons, legal persons or unincorporated organizations on
behalf of whom a transaction is conducted within an obliged party or
who is the ultimate owner of the transaction or the account belonging
to them
Company that has no commercial or productive activity in the place of its
establishment, such as:
Offshore
Company
off-shore companies,
abroad commercial-industrial companies ,
Special purpose vehicle (SPV).
Nonprofit
organizatio
ns
Non-profit or public benefit bodies, agencies, organizations, associations,

societies and other unions as well as silent partnerships.
AML/CFT
Officer
AML/CFT Officer means the officer who is employed for the purpose of
ensuring the compliance with obligations established through the Law no 5549
on Prevention of Laundering Proceeds of Crime or the legislation issued on the
basis of the Law and who is entrusted with the required authority
Inspection
of
Obligations
Inspection of the obligations introduced by the Law no 5549 on Prevention of

Laundering Proceeds of Crime and relevant legislation is carried out through
Finance Inspectors, Tax Inspectors, Customs Inspectors, Revenue
Comptrollers, Sworn-in Bank Auditors, Treasury Comptrollers and Capital
Markets Board Experts
A- RISK MANAGEMENT ACTIVITIES

A-1 KNOW YOUR CUSTOMER AND ASSESSMENT OF CUSTOMERS
A-1-1
A-1-2
A-1-3
A-1-4
CONTROLS PRIOR TO OPENING BASE / ACCOUNTS

INDIVIDUALS AND ORGANIZATIONS NOT ACCEPTABLE AS CUSTOMERS
RISK-BASED ASSESSMENT OF CUSTOMERS AND TRANSACTIONS
TRANSACTIONS WHICH SHALL NOT BE CARRIED OUT FROM CUSTOMER ACCOUNTS
A-2 CUSTOMER IDENTIFICATION

A-2-1 GENERAL EXPLANATIONS ON THE LIABILITY OF IDENTIFICATION
A-2-2 IDENTIFICATION OF REAL PERSONS
A-2-3 IDENTIFICATION OF LEGAL PERSONS REGISTERED TO TRADE
(Incorporated, Limited, Unlimited, Commandite companies and cooperatives)
A-2-4 IDENTIFICATION OF ASSOCIATIONS AND FOUNDATIONS
A-2-5 IDENTIFICATION OF UNIONS AND CONFEDERATIONS
A-2-6 IDENTIFICATION OF POLITICAL PARTIES
A-2-7 IDENTIFICATION OF NON-RESIDENT LEGAL PERSONS
A-2-8 IDENTIFICATION OF ENTERPRISES WITH NO LEGAL ENTITY
A-2-9 IDENTIFICATION OF PUBLIC INSTITUTIONS
A-2-10 IDENTIFICATION OF THIRD PARTIES WHO ACT ON BEHALF OF OTHERS
A-2-11 AUTHENTICITY OF VERIFICATION DOCUMENTS
A-2-12 IDENTIFICATION FOR SUBSEQUENT TRANSACTIONS
REGISTRY
A-3 IDENTIFICATION OF REAL BENEFICIARY AND LEGAL PERSONS DUE DILIGENCE

A-4 TRANSACTIONS REQUIRING SPECIAL ATTENTION
A-5 MONITORING OF CUSTOMERS AND TRANSACTIONS
A-6 MEASURES TAKEN AGAINST TECHNOLOGICAL RISKS
A-7 PRINCIPLE OF RELIANCE ON THIRD PARTIES
A-8 REJECTION OF A TRANSACTION AND TERMINATION OF BUSINESS RELATIONSHIP
A-9 CORRESPONDENT BANKING RELATIONSHIPS
A-10 ELECTRONIC TRANSFERS
A-11 ADDITIONAL MEASURES AGAINST HIGH RISK GROUPS
A-12 RELATIONSHIPS WITH RISKY COUNTRIES
A-13 SIMPLIFIED MEASURES
A-13-1 TRANSACTIONS AMONG FINANCIAL INSTITUTIONS
A-13-2 IN THE EVENT THAT THE CUSTOMER IS A PUBLIC ADMINISTRATOR OR AN
OCCUPATIONAL INSTITUTE HAVING THE SPECIFICATIONS OF BEING A PUBLIC
INSTITUTION
A-13-3 IN THE EVENT THAT THE CUSTOMER IS INTERNATIONAL INSTITUTION OR EMBASSY
OR CONSULATE RESIDING IN TURKEY
A-13-4 COLLECTIVE CUSTOMER ACCEPTANCE WITHIN THE FRAME OF SALARY PAYMENT

AGREEMENTS
A-13-5 SALARY PAYMENT TRANSACTIONS OF MEMBERS OF UNITS OF INTERNATIONAL
INSTITUTIONS RESIDING IN TURKEY OR MEMBERS OF EMBASSY OR CONSULATES
A-13-6 IN THE EVENT THAT THE CUSTOMER IS A PUBLIC COMPANY WITH QUOTED SHARES
IN STOCK EXCHANGE
A-13-7 TRANSACTIONS RELATED TO PENSION AGREEMENTS, PENSION PLANS AND LIFE
INSURANCE
A-13-8 TRANSACTIONS OF PRE-PAID CARDS
A-13-9 VERIFICATION OF ACCURACY OF TELEPHONE AND FAX NUMBERS AND E-MAIL
ADDRESSES
A-14 REPORTING OF MONITORING AND EVALUATION RESULTS TO THE BOARD OF DIRECTORS
B- MONITORING AND CONTROLLING ACTIVITIES

B-1 MONITORING AND CONTROLLING OF THE TRANSACTIONS OF HIGH RISK CUSTOMERS
B-1-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO HIGH RISK GROUP CUSTOMERS
B-2 MONITORING AND CONTROL OF THE TRANSACTIONS PERFORMED IN RISKY COUNTRIES
B-2-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO THE RISKY COUNTRIES
B-3 MONITORING AND CONTROL OF COMPLEX AND UNUSUAL TRANSACTIONS
B-3-1 CONTROL OF SAFE DEPOSIT BOXES
B-3-2 INSPECTION OF CASH AND TRANSFER TRANSACTIONS
B-4 CROSS CHECK OF THE TRANSACTIONS ABOVE A CERTAIN AMOUNT WITH THE CUSTOMER
PROFILE BY SAMPLING METHOD
B-5 MONITORING AND CONTROL OF THE TRANSACTIONS WHICH EXCEED IDENTIFICATION LIMIT
AND WHICH ARE INTERRELATED
B-6 CONTROL OF THE INFORMATION AND DOCUMENTS RELATED TO CUSTOMERS THAT ARE KEPT
IN WRITING OR IN AN ELECTRONIC MEDIUM; CONTROL OF THE INFORMATION THAT HAS TO BE
STATED IN ELECTRONIC TRANSFER MESSAGES; COMPLETION AND UPDATING OF THESE
INFORMATION
B-7 ON-GOING MONITORING OF THE TRANSACTIONS IN ORDER TO CHECK THEIR CONSISTENCE
WITH THE CUSTOMERS OCCUPATION, RISK PROFILE AND SOURCES OF FUNDS
B-8 CONTROLS OF THE NON-FACE-TO-FACE TRANSACTIONS
B-9 RISK BASED CONTROL OF NEW PRODUCTS AND SERVICES THAT MAY BECOME VULNERABLE TO
MISUSE DUE TO TECHNOLOGICAL INNOVATIONS
B-10 SUSPICIOUS OR UNUSUAL TRANSACTION REPORTING
B-10-1 LAUNDERING THE PROCEEDS OF CRIME
B-10-2 SUSPICIOUS OR UNUSUAL TRANSACTION TYPES DESCRIBED IN GENERAL

COMMUNIQUE NO. 6 OF THE FINANCIAL CRIMES INVESTIGATION BOARD
B-10-3 TERRORIST FINANCING
B-10-4 HOW TO FILL-IN, SIGN AND SEND THE SUSPICIOUS TRANSACTION REPORTING
FORM TO THE COMPLIANCE DEPARTMENT
B-10-5 REPORTING SUSPICIOUS OR UNUSUAL TRANSACTIONS TO THE FINANCIAL CRIMES
INVESTIGATION BOARD
C- TRAINING ACTIVITIES
C-1 CONTENT AND SCOPE OF TRAINING ACTIVITIES
C-1-1 METHODS OF TRAINING ACTIVITIES
C-1-2 CONTENT OF TRAINING ACTIVITIES
C-1-3 TARGET GROUPS
C-1-4 TRAINING DOCUMENTS
C-1-5 TRAINERS
C-1-6 EVALUATION OF THE TRAINING RESULTS
C-1-7 REPORTING TRAINING RESULTS TO FINANCIAL CRIMES INVESTIGATION BOARD
D- INTERNAL AUDIT ACTIVITIES
E- RELATIONS WITH NBG GROUP COMPLIANCE DIVISIOM
APPENDICE
A-RISK MANAGEMENT ACTIVITIES

The below mentioned risk management activities are performed by our bank related to
prevention of laundering proceeds of crime and terrorist financing in order to identify, scale,
monitor, evaluate and minimize the risks that our bank is subject to.
Record Keeping
All records and documents obtained in line with the regulations on laundering proceeds of
crime and terrorist financing are kept for at least 8 years.
A-1 KNOW YOUR CUSTOMER AND ASSESSMENT OF CUSTOMERS
Where new customers are acquired without going through a careful review, the banks may be
subjected to the risk of losing reputation, operational and legal risks which may impose
significant financial costs. The principle of Know Your Customer is critically important not
only in terms of protection from launderers of criminal income prevention of money
laundering and terrorist financing, but also in terms of effective management of banking risks
In addition to knowing the customer well and knowing the customers type of business, it is
also important to know the relations of the customer with other customers for prevention of
the risk of concentration, which can be the case especially in credit transactions.
This section sets out the principles to be implemented for new customers at our Bank in
account openings and in monitoring the transactions of existing customers.
First of all, a Customer Assessment Form (Appendix 1) has to be prepared by the

Customer Representative for each customer who asks to open an account at our Bank.
This form shall cover, The reason for the customers preference and opening an
account at our Bank (in the event that the customer himself has applied to open an
account),
Principles of working with our bank, types of transactions to be carried out,
Customers occupation, commercial activities, occupational history, financial status,

country of residence, country where the customers business activities operate,
country or region of origin or destination of funds
Where possible, customers who work with our Bank, which may be used as reference,
Customer representatives evaluation.
If the customer is deemed as belonging to high risk group according to the assessment
criteria above, related box in the Customer Assessment Form (Appendix 1) is checked.
THE CUSTOMER REPRESENTATIVE SHALL DECIDE THAT THE ACCOUNT SHOULD BE OPENED
IF THE INFORMATION S/HE RECEIVES FROM THE CUSTOMER IS CONSISTENT AND THE
DOCUMENTS ARE CONSISTENT WITHIN THEMSELVES. ALL RESPONSIBILITY RELATING TO
THE CUSTOMER (FULL PROCUREMENT OF DOCUMENTS AND DETAILS, COMPLIANCE WITH
RECORDS IN COREFINANS SYSTEM AND UPTO-DATE THEREOF, ETC.) BELONGS TO THE
CUSTOMER REPRESENTATIVE.
Banking Transactions Agreement shall not be signed and customer base account shall not be
created upon power of attorney according to Know Your Customer principles even though
there is a clearly defined authorization in the power of attorney.
The Bank officers should visit the persons who do not have the physical capability to visit the
Bank in order to identification of these customers and signing Banking Transactions
Agreement. After opening to the customer a base number, accounts under this base number
can be opened by a power of attorney.
Age limit must be observed for accounts to be opened in the name of minors.
A-1-1 CONTROLS PRIOR TO OPENING BASE / ACCOUNTS
Customers who want to open base/accounts are checked against the banks in-house
and international warning lists (such as OFAC; UN Sanctions List, EU Black List, SABAS,
our banks warning list). The mentioned controls are automatically performed at base
openings. The workflow is as follows;
In the phase of customer identification by a branch, while the user is registering
customers information, the system cross checks potential customers information with
the persons/institutions in the following lists:
* OFAC SDN List (Office of Foreign Assets Control Specially Designated Nationals
List),
the
list
prepared
by
the
Treasury
http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt
of
the
USA.
* EU Sanctions List, The warning list prepared by the European Union

http://ec.europa.eu/external_relations/cfsp/sanctions/list/version4/global/e_ct
lview.htm
* Banned
and
sanctioned
countries,
the
link
http://www.treas.gov/offices/enforcement/ofac/programs/
for
the
details
is
* List of countries with which no transactions will be performed prepared by
Western Union; Western Union announces this list to its agencies. Information can be
obtained from FOMER- Western Union Unit and our unit.
* Finansbank Alert List which is prepared by AML unit including fraud, lost and
fictitious document notifications by customers, The Banks Association of Turkey,
prosecution offices etc. Information can be obtained from AML Unit.
* Capital Market Board Prohibited Investors including the persons/institutions that

are banned from operating on capital market instruments by the Capital Market Board;
it is included in the warning list. These persons/ institutions are banned from using only
capital market instruments. An alert will be put on the customer name and they will be
prevented from making such transactions on the internet.
http://www.spk.gov.tr/apps/islemyasaklilar/index.aspx
The user is notified on the basis of a certain ratio of matching before completing the
transaction and details on warning lists and matching records are provided in the related
menu. The user performs the following actions in order to decide whether s/he will continue,
make a research on the record or end the transaction:
* Finans_Base_OFAC - should be controlled in the OFAC list.

* Finans_Base_EU/BL - should be controlled in the EU Sanctions List.
8
* Finans_Base_Uyar - should be controlled in the Finansbank Alert List. If there is a
one-to-one match, AML Unit should be informed.

* Finans_Base_lke - should be controlled in the banned, sanctioned countries list.
* Finans_Base_WU List of the countries prepared by Western Union with which no
transactions will be performed. If there is a one-to-one match, FOMER-Western Union
Unit or Compliance Department should be informed.
Information checked in the phase of customer identification:
Legal person inquiries are based on title and Taxpayer Identification Number (TIN). When
the title and TIN match, necessary inquiries are made in order to decide on continuing or
ending the transaction.
Real person inquiries
For Turkish citizens; the inquiries are based on name/surname, identity number, name of the
father, place of birth and date of birth. When name/surname+name of the father+place of
birth+date of birth or identity number match exactly, necessary inquiries are made in order
to decide on continuing or ending the transaction.
For foreign citizens the inquiries are based on name/surname, name of the father, place of
birth and date of birth. When name/surname+name of the father+place of birth+date of birth
match exactly, necessary inquiries are made in order to decide on continuing or ending the
transaction.
* For the transactions approved by the Plastic Cards BDS (the name of the system
used by Plastic Cards Department), the system automatically creates a customer

number, and if there are similarities between the customer record and the
persons/institutions in the warning lists, the records are listed in the menu
Customer>Customer Identifications>Warning Lists Monitoring. The records in these
lists are controlled, and the Plastic Cards Allocation Unit decides to stop the issuing
of the card if there are any suspicions.
* In case there are matching records among the persons who will be paid their
salaries within the frame of FINBOR contracts, the system does not register them,
and the transaction is transferred to the related branch in order to give the final
decision after inquiry and continue the transaction if it is proper.
The accuracy of the presented documents is checked in line with the Prevention of
Fraud Attempts Directive (TAL.00460).
If there are any doubts about the authenticity of the documents presented by the
customer, authenticity of these documents is verified by consulting to the
person/institution who has prepared the document.
Whether the customer has high risk and his/her risk group is determined in terms of
laundering the proceeds of crime and terrorist financing by considering his/her
occupation, commercial activities, sources of funds, his/her country of residence and
other relevant indicators.
Individuals and organizations may not collect donations without having permission
from public authorities. To the extent it is desired to open an account for collecting
donations, if the activity of collecting donations covers more than one district of a
province, then permission must be obtained from the governor of that province; if it
is limited to the boundaries of a district, then permission must be obtained from the
governor of that district. To the extent the donation collection operation covers more
than one province, it is sufficient for the natural or legal persons to endeavor
collecting donations to obtain permission from the governor of the province of that
settlement. Which charitable association, agency or foundation may collect
donations without obtaining permission shall be determined and announced by the

Council of Ministers upon recommendation of the Ministry of Internal Affairs. The
opinion of the Compliance Department shall be obtained for accounts to be opened
for collecting donations. When such an entity has appointed more than one
authorised signatories to operate its account, the identities of all authorised
signatories shall be verified, according to the identity verification procedures for real
(natural) persons provided for.
A-1-2 INDIVIDUALS AND ORGANIZATIONS NOT ACCEPTABLE AS CUSTOMERS
Persons and organizations in the banks in-house and international sanctions lists
(such as OFAC; UN Sanctions List, EU Sanctions List, SABAS, our banks warning
list).
Persons and organizations who ask to open an account under a name which is
different from their real identities; who avoid to fill in the customer information forms
and those who are reluctant to do so; or who supply misleading or unverifiable
information.
Information exists from reliable sources, of their participation in illegal activities (eg.
Drugs dealing, terrorism, organized crime), or investigation is conducted for their
participation in illegal activities.
Information exists, that another Bank has refused the provision of services to the
customer.
The verification of their identity is difficult (e.g. very complicated business structure
of the company that makes impossible the understanding of the ownership and the
identification of the person who exercises control).
Individuals and organizations asking to open an account, stating that they have
international connections and they will bring a large amount of funds to our Bank to
make investments in our country.
Individuals and organizations wishing to open an account with the request that
foreign currency cheques drawn on international banks are collected or purchased.
Shell Banks and financial institutions which have no physical address in any country,
comprising solely a web address, which are not subject to supervision or license of
any government authority in respect of banking transactions and records, which are
generally established at overseas jurisdictions known as offshore tax heavens.
Persons and organizations for which there is doubt that their wealth and funds have
been earned through legal means.
Those who demand to open accounts in the name of third parties under an
anonymous name or nick name.
Real/legal persons working at Bill Payment Centers.
Where it is believed that it is risky to open an account for the customer after the evaluation
made by the Customer Representative but the customer insists on opening the account, the
matter shall be forwarded to the Compliance Department.
A-1-3 RISK-BASED ASSESMENT OF CUSTOMERS AND TRANSACTIONS
The Bank differentiates its customers according to risk assessment by subordinating them
into three (3) categories, namely:
High risk
Medium risk
Low risk
Analytic instructions on how this categorization will be practiced will follow in due course.
10
HIGH RISK GROUP CUSTOMERS
Customers who are in the high risk group are determined according to the following and other
related criteria:
Their occupations/commercial activities,

Their transaction types and reasons,
Volume of transactions,
Sources of funds,
The countries they make transfers, and beneficiaries of those transactions,
The countries they receive transfers from and their principals
Real beneficiaries of the transactions,
The company profile and its shareholders,
Their country of residence.
The below listed customer types are considered as belonging to high risk groups. The box
indicating high risk in the Customer Assessment Form is checked at the opening of these
kinds of bases/accounts.
Non-residents
Customers having their residence abroad shall be subject to the same information
requirements and identity verification procedures as those who live permanently in
Turkey. Special attention is paid to opening accounts for non-resident person or
institutions, and information on their reason for opening an account in Turkey, their
commercial or non-commercial activities, nature of transfers that will be made to and
received from abroad together with their principals and amounts are asked. Especially
before opening accounts for persons residing in high risk countries, the documents
explained in Customer Identification section should be taken and be carefully examined.
Furthermore, when there is any doubt concerning the identity of a person, the Bank shall
seek verification and authentication of these documents by the embassy or consulate of
the issuing country in Turkey, or by reliable Credit Institutions in the customers home
country.
Residents in Offshore Regions and special purpose vehicles (SPVs)
If the customer is a company that has no commercial or productive activity in the place
of its establishment, such as an offshore company or a company referred to in, as
currently in force, or a Special Purpose Vehicle (SPV), the Bank shall conduct enhanced
customer due diligence.
Countries/Regions named as Offshore or Tax Heaven are; Andorra, Anguilla, Antigua,
Aruba, Bahrain, Barbuda, Belize, Bermuda, British Virgin Islands, Cayman Islands,
Bahamas,Cook Islands, Gibraltar, Grenada, Guernsey/Sark/Alderney, Cyprus, Isle of Man,
Jersey, Liberia, Malta, Mauritius, Montserrat, Niue, Panama, Vanuatu, Samoa, San
Marino, St. Lucia, St. Vincent and Grenadines, Dominica, St. Kitts and Nevis, The
Netherlands Antilles, The Prinsipality of Liechtenstein, The Principality of Monaco,
Marshall Islands, Nauru, Seychelles, The US Virgin Islands, Turks and Caicos Islands.
The Bank applies the following to the above companies:
Verifies the ownership structure and control of the company and identifies the
beneficial owners. In order to identify the beneficial owners, the Bank shall require
either (i) a declaration form (Appendix 2) in writing by the legal representative of the
11
company regarding the verification of the beneficial owners identity or (ii)

certification and verification of their identity by a credit officer of the Bank, following
approval by a member of senior management, on the basis of documents, data or
information from a reliable and independent source.
Obtains from the legal representative of the company a declaration in writing to the
effect that, if the shares of the beneficial owners are transferred to a third party or
there is any material change in the company's status, he shall immediately inform
the Bank. If there is any change in the beneficial owners of the company, the Bank
shall consider whether or not to continue the business relationship
Compares regularly the actual transactions through the account with those expected
on the basis of the companys economic/transaction profile. Any significant
divergences shall be scrutinized and the findings shall be entered in the companys
file.
Persons Residing and Transactions Carried out in Countries Which

Act in Accordance with the Recommendations of FATF
Do Not
The Bank shall examine with particular attention transactions and conduct additional
measures for the continuous monitoring of the business relationships and transactions
with natural persons or legal entities, including Credit Institutions and Financial
Institutions, from countries that are considered as non-cooperative or non-compliant or
inadequately compliant with the requirements of FAFT. All transactions with natural
persons or legal entities from these countries shall be examined with particular attention.
To assess country risk for AML/CFT purposes, the Bank uses the following criteria:
announcements by FATF concerning countries or territories that do not comply or

comply inadequately with its recommendations,
country assessment reports issued by FATF, regional bodies that have been
established and operate according to its standards (e.g. Council of Europe Moneyval
Committee), the International Monetary Fund and the World Bank,
list of countries or jurisdictions which, according to the Common Understanding of the

Committee for the Prevention of Money Laundering and Terrorist Financing, which
assists the European Commission, have equivalent AML/CFT systems to the EU,
countries characterized by FATF as non cooperative or tax havens;
inclusion in the EU, UN and OFAC (Office of Financial Assets Control) lists;
FATF membership;
implementation of EU directives;
implementation of the Wolfsberg principles; and
countries that ratified the UN Convention Against Illicit Traffic in Narcotic Drugs and
Psychotropic Substances of 1988
PEP-Politically Exposed Persons
Politically exposed persons are natural persons that are or have been entrusted with a
prominent public function, including their immediate family members or the persons
known to be their close associates.
Specifically natural persons entrusted with a prominent public function include:
12
(a)
Heads of State, heads of government, ministers and deputy or assistant

ministers;
(b)
Members of Parliament (MPs);
(c)
Judges of supreme courts, constitutional courts or other high-level judicial

bodies whose decisions are not subject to further appeal, other than in
exceptional circumstances;
(d)
Judges of courts of auditors;
(e)
Members of the boards of central banks;
(f)
Ambassadors and chargs d affaires;
(g)
High-ranking officers in the armed forces; and
(h)
Members of the administrative, management or supervisory bodies of stateowned enterprises.
None of the categories (c) and (h) above shall be understood as covering middleranking or junior officials.
The categories (b) and (g) above include functions exercised at the EU and
international levels.
Immediate family members of the persons referred to in the above paragraph shall
include:
(a) The spouse;
(b) Any partner considered by national law as equivalent to a spouse;
(c) Natural or adopted children and their spouses or partners; and
(d) The parents.
Persons known to be close associates shall include:
(a) any natural person who is known to have joint beneficial ownership of legal
entities or legal arrangements, or any other close business relationships, with a
person referred to in the above paragraph and
(b) Any natural person who has sole beneficial ownership of a legal entity or legal
arrangement which is known to have been established for the benefit of a person
referred to in the above paragraph.
Without prejudice to the application, on a risk-sensitive basis, of enhanced customer
due diligence measures, where a person has ceased to be entrusted with a prominent
public function for a period of at least one year, the Bank shall not be obliged to
consider such a person as politically exposed.
The Bank must adopt the following additional customer due diligence measures when
establishing a business relationship with a PEP:
(a) Apply the appropriate procedures, on a risk-sensitive basis, to determine whether
the customer is a PEP;
(b) Obtain senior managements approval of the establishment of business
relationships with such customers;
(c) Take adequate measures to verify the origin of the wealth and funds that the
business relationship or transaction concerns; and
(d) Monitor the business relationship on a continuous and enhanced basis.
13
In the case of accounts of legal persons and other entities, the procedures applied shall
aim at verifying whether the beneficial owners, legal representatives and persons
authorized to operate the relevant account are PEPs. If any of the above persons is
identified as a PEP, these legal persons and other entities accounts shall automatically
be subject to the enhanced customer due diligence measures.
Standard customer due diligence measures must apply to PEPs established in Turkey
Companies with Bearer Shares
Accounts which will be opened for companies that have issued bearer shares are
considered as high risk group accounts. Especially companies founded in offshore regions
issue bearer shares. It is possible to detect such cases from the companies main
contracts. Therefore, careful examination of the main contracts of both resident and nonresident companies is of vital importance. Prior to opening accounts for such companies,
verification of the obtained information on company owners, real beneficiaries and
financial status should be sought from relevant sources or by paying visits to the office of
the company.
The legal representative of the company provides a declaration in writing to the Bank
stipulating that, if the shares of the beneficial owners are transferred to a third party or
there is any material change in the companys status, he shall immediately inform the
Bank, unless the same commitment is made in an agreement with the company. When
there is a change of the person who is the real beneficiary of the company or a different
transaction other than the regular transactions performed from that account, an
evaluation should be made in line with the explanations stated in the Monitoring and
Controlling section.
A declaration form (Appendix 2) shall be signed by the legal representative of the
company with bearer shares, by which further information about the company is
requested.
Non-profit organizations
Non-profit organizations such as associations and foundations can be used for terrorist
financing. Funds that are obtained as subscription fees, donations and benefactions from
good-intentioned people may be transferred to terrorist organizations or terrorists via
these non-profit organizations. Most of the time, people are unaware of such transfers;
believing that the money they donate will be used for the sake of the legal aim declared
by these organizations. Accounts that will be opened for foundations, associations and
charity foundations are high risk group accounts.
With respect to accounts of non-profit or public benefit agencies, organizations,
associations, societies and other unions, the Bank shall verify the legitimacy of their
incorporation and objects, requiring the submission of a certified copy of their establishing
deed (charter, private agreement etc.), their certificate of incorporation, certificate of
registration and the number of their registration by the competent public authority. When
such an entity has appointed more than one authorized signatories to operate its account,
the identities of all authorized signatories shall be verified, according to the identity
verification procedures for natural persons provided for hereunder.
Persons with high amount of funds (Ex. Private Banking Customers)
The Bank shall take the following additional due diligence measures when undertaking the
management of portfolios of important clients:
The Branch Manager approves the opening of portfolio management accounts of new
important customers.
The identity of all the beneficial owners of such accounts is verified.
14
It is verified whether the owner of the account is a PEP.
The source of the assets managed and the expected use of the account by the
owners are established.
It is examined whether the operation of the account is consistent with its purpose
and the owners economic/transaction profiles.
It should be stated in the Customer Assessment Form that the person is a private
banking customer.
Non-Face-to-Face Transactions
Non-face-to-face transactions are conducted through alternative networks (e.g. ATMs,

Internet / Phone / Mobile banking, etc.)
Our bank is obliged to devote special attention to and take necessary measures against
risks of using advantages of new and developing technology for laundering proceeds of
crime and terrorist financing. Therefore, transactions like cash transactions and money
transfers carried out via alternative distribution channels such as internet, telephone
banking and ATMs are inspected within the frame of monitoring and controlling activities.
At the beginning of the business relationship, before establishing a business relation with
the customer, a customer should be physically present in our branches for ID verification
and other related actions such as signing the banking transactions agreement or other legal
documents. Therefore, such transactions cannot be executed by walk-in customers via
internet banking, call center, etc.
When the customer applies for the connection of his account with an alternative network,
it shall be ensured that the identity verification and certification procedures have been
completed, before the account opening. Consequently, any information by declaration will
not be accepted.
Risky sectors and profession groups
The below listed sectors and occupational groups who make transactions on behalf of third
parties and where there is an intense cash flow are considered as high risk groups.
Authorized institutions (foreign currency dealers).

Jewelers, traders of precious stones and metals like gold and diamond.
Travel agencies, carriers of passengers and cargo.
Casinos, operators of halls of games of chance.
Gallery operators selling luxury vehicles.
Antique dealers and art galleries, carpet dealers.
Large real estate firms and any agents, representatives or commercial attorneys for
the same
Lessors of aircraft and sea vehicles.
Manufacturers and traders of leather goods.
Manufacturers and traders of car spare parts.
Those operating in lines of business with high use of cash (car park operators,
restaurants, fuel, lottery and newspaper dealers, distribution companies, traders of
toys and stationery).
Factoring firms.
15
Cash transactions
Branch and Business Units Officers shall examine with particular attention cash
transactions of a significant amount in order to verify the origin of cash and whether the
amount and nature of the transaction are compatible with the customers
economic/transaction profile. For that purpose, they shall obtain all the documents and
data required to verify the necessity of carrying out a cash transaction of significant
amount.
Therefore, information on the sources of the funds and the reasons for opening accounts
is obtained from the customer and check whether the transactions performed after
opening the account are in accordance with the reasons for opening the accounts.
If a customer requests to withdraw an amount of over TRY 500.000 (approx. the
equivalent of 250,000.00) in cash, it is recommended that the money be delivered to the
customer by cheque or an order for payment to a bank account, unless there are specific
and adequately proved reasons that warrant a cash withdrawal.
The results of the examination shall be documented and filed for at least eight years,
including all supporting documents.
Correspondent Banking Relationship
These relationships shall be established in line with rules and principles stated in Chapter A-9
of this Document.
Trusts
Trusts are not separate legal entities and, therefore, business relationships are established
through trustees acting on behalf of the trust. Our bank takes reasonable measures, on a
risk-sensitive basis, to comprehend the ownership and control structure of trusts.
Before establishment of such relationships and account opening the following shall be
verified:
the
the
the
the
name and date of establishment,

identities of trustors, trustees and beneficial owners,
nature, objects and activities of the trust,
source of its funds.
Copies of the establishing documents of the trust and any other necessary information on the
beneficial owners should be obtained and shall keep the relevant data and information in the
customers file.
A-1-4 TRANSACTIONS
ACCOUNTS
WHICH
SHALL
NOT
BE
CARRIED
OUT
IN
CUSTOMER
The following transactions may not be carried out in customer accounts:
No transaction of virtual nature (fictitious), seeking fulfillment of various legal

obligations (capital increase of companies indicating that there are funds in the
account at a specific time, etc.)
Accounting records shall be established in line with the nature of transactions.
Requests seeking to vary the nature of account-to-account transfers or cash payment
transactions to be made from accounts (entering into books of wire-to-wire transfer in
the form of cash payment, etc.) may not be accepted.
16
Transactions which will allow the customer to avoid tax obligations or which would lead
to loss of taxes.
A-2 CUSTOMER IDENTIFICATION

In this section, within the framework of the regulations issued by The Financial Crimes
Investigation Board, the principles of identification which is one of the measures taken for the
prevention of being an instrument of laundering proceeds of crime and terrorist financing on
the part of our bank are explained.
Besides our responsibilities brought about by legal regulations and the ones set out in this
directive, attention needs to be paid to our banks in-house regulations in order to protect our
banks reputation and avoid risky transactions. Apart from regulations set out in this directive
relating to identification during payment transactions, it is obligatory to consider our banks
in-house regulations with due care.
The most important measure to take for not being an instrument of laundering proceeds of
crime and terrorist financing transactions is customer assessment at the phase of gaining new
customers and proper identification. Therefore; identification of potential real and legal
customers prior to opening accounts, and obtaining information on their terms of working
with our bank and activities are of utmost importance. The liability of these issues lies on the
employee acquiring a new customer for the Bank. Finansbank also ensures that customers
data are continuously updated during the business relationship,
The principles of opening base/accounts have been explained in Section A-1.
A-2-1 GENERAL EXPLANATIONS ON LIABILITY OF IDENTIFICATION
Banks shall;
Regardless of the monetary amount in permanent business relationships as in opening

of accounts, hiring safe boxes, granting credit or issuing credit cards ;
When the amount of a single transaction or the total amount of multiple linked
transactions is equal to or more than TRY 20.000,-;
When the amount of a single transaction or the total amount of multiple linked
transactions is equal to or more than TRY 2.000,- in electronic transfers (such as
SWIFT, Western Union, EFT)
Regardless of the monetary amount in cases requiring Suspicious Transaction Report;
Regardless of the monetary amounts in cases where there is suspicion about the
sufficiency and the truth of previously acquired identification information,
Identify persons carrying out transactions and the persons acting on behalf of or for the
benefit of the customers by means of obtaining information on identity and verifying their
authenticity. Moreover, in the establishment of permanent business relationship, information
about the purpose and the nature of the business relationship shall be obtained.
In permanent business relationships such as opening of accounts, hiring safe boxes,
granting credit or issuing credit cards;
For real persons, besides verification of the below stated information from ID cards,
the authenticity of the declared address is verified by a settlement license or a bill of a
service which requires a subscription (like an electricity, water, gas, telephone bill)
and has been issued within 3 months, and/or a document issued by a government
office (or by other documents and methods approved by The Financial Crimes
Investigation Board). A legible photocopy is made or digital image of this verification is
taken or the distinctive information on these documents is recorded.
17
For legal persons, unincorporated enterprises and other institutions and

establishments, verification of address is performed as set out in the later chapters of
this directive.
In transactions which do not constitute a permanent business relationship but

necessitates identification,
It is obligatory to obtain the relevant persons ID Card and number, address, contact
information like telephone number, sample signature .
Determination of the TRY equivalent of F/X transactions are based on the buying rate of
exchange of the Central Bank on the day of the transaction.
The relevant branch or unit employee in Turkey is responsible for the proper performance of
identification. Our branches abroad carry out the transactions in line with the banks in-house
policies and the legislation of the country of residence and Regulation on Measures
Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism of MASAK
as far as authorities allow.
In transactions which do not constitute a permanent business relationship and do
not legally necessitate identification,
The identification number should be obtained by branches even if the transaction does not
exceed the above mentioned thresholds.
A-2-2 IDENTIFICATION OF REAL PERSONS
The following information should be obtained for the identification of a real person,
Name, Surname
Place and date of birth,
Name of father and mother for Turkish Citizens.
Nationality,
Identity number for Turkish citizens,
Type of identity card and number,
Address and if possible fax, telephone number, email,
Information on job and occupation,
Occupational address
Sample signature.
The authenticity of name, surname, place and date of birth, name of father and mother,
nationality, type and number of identity card is verified by,
ID Card
Drivers License,
Passport for Turkish citizens
and,
Passport,
Residence Certificate,
ID Cards approved by The Ministry of Finance for foreign citizens.
In order to present to the authorities when demanded, a legible photocopy is made or digital
image of this verification is taken or the identification information on these documents is
recorded after the related documents are presented by the customer.
18
The authenticity of the declared address during the transactions which constitute a
permanent business relationship is verified by;
Settlement license,
Bill of a service which requires a subscription (like electricity, water, gas, telephone
bill) and has been issued within 3 months including the electronic bills which can be
confirmed by the obliged that they have been issued by the relevant institution.
Any document given by a public institution,
On the condition that they cover information pertaining to the last three months, lists
prepared by institutions which have public institution specification like BEDA and
ASK or by telecommunication companies which provide subscription.
bill) and has been issued within 3 months in the name of the third party on the
condition that a recognized document showing the relatedness with the third party is
presented,
bill) and has been issued within 3 months in the name of the parents for majors who
live with their parents,
A declaration of address given by the education or institution or the dormitory for
majors who reside in dormitories.
A document showing that the customer has received a certified mail,
For banks, credit card delivery forms which shows that the customer was in sight of
the declared address,
Reports showing that the posts sent by the obliged have been received by their
customers at the declared address,
The originals or notarized copies of the above mentioned documents do not have to be
presented. Legible photocopies or digital images of the documents are valid.
ID Cards approved by The Ministry of Finance;
Citizens of Council of Europe Member States: Identification of the residents of the

countries listed in the appendix of European Agreement on Travel of Council of
Europe Member States (Austria, Belgium, France, Germany, Greece, Italy,
Liechtenstein, Luxembourg, Malta, Holland, Spain, Switzerland, and Portugal) who visit
Turkey for a maximum period of three months and do not seek profit is verified by the
following documents:
ID cards of the relevant countries,
Form of entry/exit from border crossings for persons travelling with ID cards.
Citizens of Turkish Republic of Northern Cyprus (T.R.N.C.);

Identification is made by T.R.N.C ID card.
Documents for identification of small business owners are;
ID card of the real person, Tax form,

Statement of signature (or a signature card signed in the presence of a bank
employee),
Notarized copy of Chamber of Tradesman/Trade Registry entry (to be taken only for
transactions involving granting credits such as issuing a credit card or granting
credit).
19
A-2-3 IDENTIFICATION OF LEGAL PERSONS REGISTERED TO TRADE REGISTRY

(Incorporated, Limited, Unlimited, Commandite companies and cooperatives)
For identification of legal persons registered to trade registry, the following are needed:
Title of the legal person,

Trade registry number,
Taxpayer identification number (TIN),
Companys field of activity,
Detailed address, telephone number, and if possible fax number and email address,
Name/surname, place and date of birth, nationality, type and number of ID card,
sample signature and additionally for Turkish citizens name of the father and mother
and ID Number of the authorized representative of the legal entity,
The authenticity of the legal persons title, trade registry number, field of activity and address
is verified by below mentioned entries in the trade registry. Authenticity of TIN is verified by
the documents issued by relevant departments of Revenue Administration.
Authenticity of the ID information of the authorized representatives of the legal person is
verified by the ID documents stated in the identification section for real persons and the
authenticity of their power of attorney is verified by entries in the trade registry.
In order to present to the authorities when demanded, a legible photocopy is made or digital
image of this verification is taken or the identification information on these documents is
recorded after the related documents are presented by the customer.
In permanent business relationships, in the event that a transaction is performed on behalf of
the legal person upon his/her written order by the person/s authorized to represent, the
authenticity of the ID information of the authorized representative/s is verified by notarized
signature circular including the information on ID cards, after being sure that the order is
given by a company executive.
In a permanent business relationship, the currency and authenticity of the information in the
presented registration documents is verified by checking the records of the relevant trade
registry office or by Trade Registry Gazette interrogation from The Union of Chambers and
Commodity Exchanges of Turkey. (http://www.tobb.org.tr)
With respect to the certification of the identity of legal persons or entities, if it is requested by
branch, the completeness of the required authorizations and certificates shall be certified by
the Banks legal department .Copies of the above documents shall be kept for a time period
of at least eight years from the end of the business relationship or transaction, in a manner
ensuring the confidentiality of the data received.
In order to determine the real beneficiary,
The identification of the real or legal person partners whose shares exceed 25% is made in
line with the explanations in this directive.
Documents that shall be obtained from incorporated companies are;
Photocopy of the Trade Registry Gazette that covers the complete main contract
(showing the establishment of the company),
Original notarized signature circular of the member/s of Board of Directors who will
represent the company in front of the bank, and photocopies of ID cards of such
persons,
Tax form of the company.
20
Documents that shall be obtained from limited companies are;
Original, recently signed and notarized signature circular of the manager/s who will
represent the company in front of the bank, and photocopies of ID cards of such
persons,
Tax form of the company.
Documents that shall be obtained from Cooperatives are;
Notarized copy of the main contract of cooperative, and photocopy of the Trade
Registry Gazette showing the establishment of the cooperative.
Photocopy of the Trade Registry Gazette showing resolution of the Cooperative
General Board on the appointment and power of Board of Directors.
Notarized copy of the resolution of the Board of Directors on the authorized
representative/s,
If attainable, resolution of Board of Directors on the opening of an account, Notarized
original of the signature circular of the authorized persons,
ID cards of the authorized persons,
Tax form of the cooperative.
Documents that shall be obtained from unlimited companies are;
Original notarized signature circular of the shareholder/s who will represent the
company in front of the bank as stated out in the main contract, and photocopies of ID
cards of such persons,
Tax form of the company and its shareholders (Base is opened under the TIN of the
company and tax forms of the shareholders are kept in the base folder.)
Documents that shall be obtained from commandite companies are;
Original notarized signature circular of the shareholder/s who will represent the
company in front of the bank as stated out in the main contract, and photocopies of ID
cards of such persons,
Tax form of the company and its shareholders (Base is opened under the TIN of the
company and tax forms of the shareholders are kept in the base folder.)
Documents that shall be obtained from the branch offices of companies are;
Documents of the main company,

Notarized copy of the resolution of the Shareholders Assembly/Board of Directors on
the opening of the branch office (including commercial title of the branch office,
detailed address, its representatives and powers),
Photocopy of the Trade Registry Gazette showing the establishment of the branch
office,
Recently signed, notarized original of signature circular of the branch office manager
and his/her ID card,
Tax form of the company/shareholders.
21
A-2-4 IDENTIFICATION OF ASSOCIATIONS AND FOUNDATIONS

For identification of associations, the documents that shall be obtained are;
Name of the association,

Cause of establishment,
Associations Record Registration number,
Detailed address, telephone and fax number (if attainable) and email address,
Name/surname, place and date of birth, nationality, type and number of the ID Card,
sample signature, and additionally for Turkish citizens name of the father and mother
and ID Number of the authorized representative of the association
The authenticity of the name, cause, record registration number and address is verified by
below mentioned documents related to association record and the registration; authenticity of
the ID information of the authorized representatives of the association is verified by the ID
documents stated in the identification section; and the authenticity of their power of attorney
is verified by the documents showing this power.
For identification of foundations, the documents that shall be obtained are;
Name of the foundation,

Cause of establishment,
Central commerce registration number kept at General Directorate of Foundations,
Detailed address, telephone and fax number (if attainable) and email address,
and ID Number of the authorized representative of the foundation.
The authenticity of the name, cause, central commerce registration number and address is
verified by below mentioned documents related to foundation record and the registration kept
at General Directorate of Foundations; authenticity of the ID information of the authorized
representatives of the foundation is verified by the ID documents stated in the Identification
of Real Persons section; and the authenticity of their power of attorney is verified by the
documents showing this power.
In order to present to the authorities when demanded, originals or notarized legible
photocopies/digital images of the verification documents are taken or the identification
information on these documents is recorded.
Identification of the branches and agencies of foreign associations and institutions is based on
the documents kept at the Ministry of Internal Affairs.
Documents that shall be obtained from associations are;
Notarized copy of the Association Record

Notarized copy of the document stating that the association is recorded in the
Association Record Book,
Notarized copy of the resolution of the Board of Directors on the members and powers
of the General Assembly,
Notarized copy of the resolution of the Board of Directors on the appointment of
representative/s among themselves,
Notarized copy of the resolution of the Board of Directors on the opening of an account
(if attainable),
Notarized original signature circular of the authorized persons, ID cards of authorized
persons,
TIN of the association.
22
Documents that shall be obtained from foundations are;
Notarized copy of foundation voucher,

Copy of the Official Gazette stating the establishment of the foundation,
Notarized copy of the resolution of the Board or Committee on the members and
powers of the Board of Directors (for the foundations appointed by Board of Directors,
Board of Trustees or General Assembly),
(if attainable),
persons,
TIN of the association.
A-2-5 IDENTIFICATION OF UNIONS AND CONFEDERATIONS

For identification of unions and confederations, the documents that shall be obtained are
Full name of the union or confederation,

Cause of the union or federation,
Registry number kept at Regional Directorate of Working of Ministry of Labor and
Social Security,
Detailed address, telephone number, fax number (if possible), and email address,
and ID Number of the authorized representative of the union or confederation.
The obtained information is verified by the statutes of these institutions and documents
recorded in the registry kept at Regional Directorate of Working of Ministry of Labor and
Social Security; the authenticity of the ID information of the authorized representative/s is
verified by the identity documents listed in the Identification of Real Persons section; and
their representative status is verified by documents recorded in the registry or a document
stating their authorization.
Documents that shall be obtained from unions are;
Notarized copy of the statute of the union,

Copy of the registry document kept at Ministry of Labor and Social Security,
Notarized copy of the resolution of the Union General Assembly on the members and
powers of the Board of Directors,
(if attainable),
persons,
TIN of the union.
23
Documents that shall be obtained from confederations at the opening of accounts

are;
Notarized copy of the statute of the confederation,

Copy of the registry document kept at Ministry of Labor and Social Security,
Notarized copy of the resolution of the Confederation General Assembly on the
members and powers of the Board of Directors,
(if attainable),
persons,
TIN of the confederation.
A-2-6 IDENTIFICATION OF POLITICAL PARTIES

For identification of political party organizations, the documents that shall be obtained are;
Name of the relevant unit of the political party,

and ID Number of the authorized representative of the political party.
The name and address of the relevant unit of the political party is verified by their statutes;
the authenticity of the ID information of the authorized representative/s is verified by the
identity documents listed in the Identification of Real Persons section; and their
representative status is verified by the documents of authorization.
Documents that shall be obtained from political parties are;
Notarized copy of the statute of the political party,

Resolutions of Center and Central Executive Committee on the powers of
Province/District Executive Committee (there is no need to obtain these documents if
they are clearly stated in the statute),
Notarized copy of the resolution of the Congress on the appointment of the chairman
and members of Central Executive Committee,
representative/s of the political party among themselves,
Notarized copy of the resolution of the Central Executive Committee on the opening of
an account (if attainable),
persons,
TIN of the political party.
24
A-2-7 IDENTIFICATION OF NON-RESIDENT LEGAL PERSONS

For the identification of the non-resident legal persons, equivalents of the documents that are
necessary for identification of resident legal persons are required. These documents need to
be approved by relevant Turkish Republic Consulates. Identification can also be made within
the frame of Agreement on Lifting the Obligation of Foreign Official Documents Ratification
by the notarized translations of the copies of these documents which have an annotation of
ratification by the relevant institution of a country who has signed that agreement.
Documents that shall be obtained from non-resident legal persons are;
Documents related to the establishment of the company (approved by the Turkish

Consulate/having an apostil) and notarized photocopies of their translations.
Documents related to the authorized representatives of the company (approved by the
Turkish Consulate/having an apostil) and notarized photocopies of their translations.
Document showing the scope of the person authorized to perform transactions on
behalf of the company (approved by the Turkish Consulate/having an apostil) and
notarized photocopies of their translations.
Newly signed signature circular (approved by the Turkish Consulate if it has been
issued abroad/having an apostil) and notarized original of its translation
ID cards of authorized persons,
Photocopy of the authorization document TIN of the company
A-2-8 IDENTIFICATION OF ENTERPRISES WITH NO LEGAL ENTITY

For identification of enterprises with no legal entity like building, site or office
building managements, the documents that shall be obtained are;
Name of the building, site or office building management,

and ID Number of the authorized representative of the building, site or office building
management.
The authenticity of the identity information of the person acting on behalf of the management
is verified by the identity documents listed in the Identification of Real Persons section;
information on management and representative status of the person acting on behalf of the
management are verified by notarized resolution book.
Documents that shall be obtained from management of apartment, site and office
buildings are;
A list showing the name, surname and separate block numbers of flat owners,
Notarized copy of resolution book related to building manager (or Assembly of
Managers) by assembly of flat owners,
Management plan (in order to check is there is a limitation on transactions) Notarized
original of the signature circular of the manager
ID card of manager (or of Assembly of Managers)
TIN of building management
For the identification of enterprises such as business partnerships with no legal

entity, the documents that shall be obtained are;
Name of the partnership,
25
Cause of the partnership,

Field of activity of the partnership,
TIN,
The authenticity of the information on the name, cause, field of activity and address of the
partnership is verified by notarized partnership contract; TIN is verified by the documents
issued by the relevant units of Revenue Administration; the identity of persons demanding a
transaction on behalf of the partnership is verified by the documents listed in the
Identification of Real Persons section; their representative status is verified by the
document stating this power.
Documents that shall be obtained from business corporations of
partnership nature that have been formed by two or more persons are;
ordinary
Notarized copy of the partnership contract,

Newly signed signature circular/statement of the authorized partner,
ID cards of the partners,
Tax forms of the partners.
Documents that shall be obtained from ordinary partnerships and consortiums are;

ID cards of the partners/documents related to entry in the trade registry of the
partner companies,
Tax forms of the partners.
Documents that shall be obtained from joint ventures are;

ID cards of the partners/documents related to entry in the trade registry of the
partner companies,
Tax forms of the partnership.
A-2-9 IDENTIFICATION OF PUBLIC INSTITUTIONS

According to the Public Financial Management and Control Law No.5018; for transactions
where the customers are public administrations within the scope of general government and
occupational institutes having the quality of public institutions, identification of the person
who acts on behalf of these is made by the identity information listed in the Identification of
Real Persons section; their representative status is verified by power of attorney prepared in
accordance with the relevant legislation.
A-2-10 IDENTIFICATION OF THIRD PARTIES WHO ACT ON BEHALF OF OTHERS
In the event that a transaction is demanded to be performed by authorized persons
on behalf of legal persons or enterprises with no legal entity;
Identification of legal persons or enterprises with no legal entity is made within the
frame of above mentioned explanations.
26
Identification of authorized representatives of legal persons and enterprises with no

legal entity and the persons they authorize is made within the frame of the
explanations in the Identification of Real Persons section.
Identification of authorized representatives of legal persons and enterprises with no
legal entity can be made by power of attorney or signature circular on the condition
that these documents are notarized and contain information found on ID card if their
identification can not be made in line with the explanations in the Identification of
Real Persons section.
Representative status of those authorized by representatives is cross checked with the
notarized power of attorney or the written order given by representatives. The
signatures of the authorized persons on those orders are cross checked with the
signatures on the notarized signature circular belonging to these persons.
In the event that a person acts on behalf of a real person;
Identification of a person acting on behalf of a real person within the frame of the
documents listed in the Identification of Real Persons section.
Representative status of those acting on behalf of a real person is cross checked with
a notarized power of attorney.
Identification of the customer on whose behalf a transaction is performed can be made
by a notarized power of attorney in cases where identification can not be made by the
documents listed in the Identification of Real Persons section.
In the event that identification of the person on whose behalf a transaction is
performed has been made before due to earlier transactions, the transaction can be
performed upon the written order of the person on whose behalf the transaction will
be performed on the condition that the signature of the customer on the written order
is cross checked with the signature kept at the bank.
In the transactions carried out by legal representatives, representative status of the parents,
guardians and trustees appointed by courts who act on behalf of minors or other persons
lacking full capacity is verified by the original or notarized copy of the relevant court decision.
In the event that parents acts on behalf of their minor children, identification of the minor
and the parents is made within the frame of the explanations in the Identification of Real
Persons section.
In order to present to the authorities when demanded, a legible photocopy or digital image of
these documents are taken or the identification information on these documents is recorded.
A-2-11 AUTHENTICITY OF THE VERIFICATION DOCUMENTS
If there are suspicions on the authenticity of the above mentioned documents used for
verification of identity and other information, the person or institution who has issued the
documents or other relevant authorities are consulted.
A-2-12 IDENTIFICATION FOR SUBSEQUENT TRANSACTIONS
In the subsequent transactions, which will constitute a permanent business relationship, of
those who have been duly identified, documents related to ID are taken and cross checked
with the documents kept at bank. If there are suspicions on the authenticity of the obtained
information, the documents of verification related to ID information or their notarized copies
are cross checked with the information kept at the bank.
A-3 RECOGNITION OF BENEFICIAL OWNERS AND PAYING SPECIAL ATTENTION TO
LEGAL PERSONS
Beneficial owner means natural persons who carry out a transaction with the bank, and
natural person(s) who control(s) the natural persons, legal persons or unincorporated
27
organizations on behalf of whom a transaction is conducted with the bank or who is the
ultimate owner of the transaction or the account belonging to them.
We take necessary measures in order to detect whether action is carried out for the benefit of
another person and to identify the beneficial owner of the transaction. Within this scope, an
announcement is presented at customers convenience in our branches and internet banking
stating that the liability lies on the persons who transact under their name but on behalf of
another person. It is also specified in the Banking Transaction Agreement signed with the
customer in the establishment of permanent business relationship.
In cases where the person requesting the transaction declares that S/he is acting for the
benefit of someone else, the identity and the authority of the person requesting the
transaction and the identity of the person for the benefit of whom the transaction is
conducted shall be identified in accordance with above mentioned identification rules.
In the establishment of permanent business relationship with legal persons registered to
trade registry we also identify, the natural and legal person partners holding more than 25%
of the legal person shares.
We take necessary measures to obtain accurate information regarding the persons ultimately
managing, or having the control or ownership of the legal person which is their customer
within the scope of a permanent business relationship.
In cases where there is a suspicion that the person is acting in his/her own name but for the
benefit of someone else although S/he has declared that S/he is not acting for the benefit of
someone else, we carry out reasonable inquiry in order to reveal the beneficial owner.
A-4 TRANSACTIONS REQUIRING SPECIAL ATTENTION
As described in the part B-10-2 and B-10-3,
Transaction or transactions or activities incompatible with the customers or beneficial

owners economic/transacting profile or have no apparent purpose or motive of a
financial, professional or personal nature,
Transaction or transactions or activities giving rise to sufficient indications or
suspicions of actual or attempted commission of money laundering and terrorist
financing offences or of involvement of the customer or beneficial owner in criminal
activities, on the basis of the assessment of data of the transaction and the person,
Require special due diligence either they are to be performed from an account or without
opening an account.
Information and documents shall be obtained related to the cause of the demanded
transaction, and they have to be kept in order to present to authorities if requested.
A-5 MONITORING CUSTOMERS AND TRANSACTIONS
Detailed information on ongoing customer due diligence and transaction monitoring by
branches and the Head Office can be found in Monitoring and Control Activities section.
A-6 MEASURES TAKEN AGAINST TECHNOLOGICAL RISKS
Our bank is obliged to devote special attention to and take necessary measures against risks
of using advantages of new and developing technology for laundering proceeds of crime and
terrorist financing.
Therefore, transactions like cash transactions and money transfers carried out via alternative
distribution channels such as internet, telephone banking and ATMs are inspected within the
28
frame of monitoring and control activities.

Only current customers, who already have relationship with the bank and who are fully
identified according to KYC rules, can open accounts using internet and phone banking.
A- 7 PRINCIPLE OF RELIANCE ON THIRD PARTIES
A business relationship can be established or a transaction can be performed by relying on
the measures taken by another financial institutions against a customer related to the issues
of identification of a person acting on behalf of the customer and the beneficiary or
information on the reason of the transaction. The relevant terms and conditions are defined in
individual contracts established between the Bank and the third parties. In any case, the
Bank is ultimately responsible for the identification and verification of its customers and
ensures that any additional data and information for updating and formulating the customers
economic/transaction profile, on a risk-sensitive basis is directly received from the customer
or beneficial owner and/or third sources.
The third parties we rely upon for the identification and verification of our customers are as
the following:
Banks
Institutions other than banks who have the authority to issue bank cards or credit
cards.
Authorized exchange offices given in legislation on foreign exchange.
Money lenders, financing and factoring companies within the scope of legislation on
money lending.
Capital Markets Brokerage Houses, Futures Brokerages and portfolio management
companies
Investment Fund managers.
Investment partnerships.
Insurance, reinsurance and pension companies, and insurance and reinsurance
brokers
Financial leasing companies.
Institutions furnishing settlement and custody services within the framework of capital
markets legislation.
Principle of reliance applies when it is certain that;
The third party maintains a business relationship with the potential client and applies
customer due diligence and record-keeping measures that commensurate with the
applicable laws and regulations.
Third parties duly meet the requirements of identification, record keeping and Know
Your Customer policy,
Non-resident third parties are subject to effective regulations and audits regarding
combat against laundering proceeds of crime and terrorist financing (this is
confirmed via sending related questionnaires),
Third parties will present approved copies of documents on identification upon
request.
In the event that a business relationship is established or a transaction is performed
upon reliance on a third party, identity information of the customer is obtained from
the third party.
Principle of Reliance on Third Parties does not apply;
When third parties are residing in risky countries,

When transactions on behalf of customers are
performed
among
financial
29
institutions,
For relationships of financial institutions with their agencies and alike units, and
people who provide complimentary or extension services for their main activity units.
AML/CFT Compliance Officer assesses the customer identification and Customer Due Diligence
procedures applied by the professional intermediary or third party/associate recommending
the customer, and he/she verifies that they are in line with acceptable international
standards. The relevant assessment report is prepared and entered in a separate file kept for
every professional intermediary or third party/associate.
A-8 REJECTION
RELATIONSHIP
OF
TRANSACTION
AND
TERMINATION
OF
BUSINESS
Business relationship is terminated when necessary identification and verification processes

cannot be conducted due to suspicions regarding the authenticity and adequacy of the ID
information.
We consider the termination of the business relationship with a customer in the following
cases:
Whenever the customer is detected on lists of suspect persons and entities (Watch
Lists) through real-time systemic review;
whenever customers transactions entail unacceptable level of risk;
in case of difficulties regarding the update of customers identification and verification

data, during the regular review or whenever there are doubts about data validity or
whenever the customers are classified as high risk;
in case the customer has not provided the required identification documents and the
relevant investigation returns no results, irrespective of the customers consent for
inspection of other data required;
in case there are valid suspicions or knowledge that the Banks customers are involved
in criminal activities, according to the current legislation for the prevention of ML & FT;
in case the customer has repeatedly been reported to the relevant local authority for
AML and CFT;
when during the high risk customers reassessment a recommendation is made for
terminating the business relationship;
For the termination of a business relationship with Banks customers, the relevant Business
Units prepare and submit a report to the Compliance Department.
The reports are assessed by the AML/CFT Officer and (if it is required) an overall consolidated
report is submitted to the AML/ CFT Committee of the Bank recommending the termination of
the business relationship.
The AML/ CFT Committee of the Bank decide on the termination or not of the business
relationship and determine the procedure and the means to inform the customer accordingly.
In any case it is required Financial Crimes Investigation Board (MASAK) should be informed
promptly about the Banks intention to terminate the business relationship with the
aforementioned customer.
The Bank, during the termination of the business relationship with a customer, applies all the
required confidentiality measures.
For all the aforementioned, relevant records are maintained according to Record Keeping
rules.
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A-9 CORRESPONDENT BANKING RELATIONSHIPS

Before establishing correspondent banking relationship with a non-resident bank;
Information should be obtained from public resources on whether the financial

institutions have gone through an inquiry related to laundering or terrorist financing
and have been imposed a penalty; their field of business; reputation; and adequacy of
audits performed in that bank.
Assessment should be made about the quality of supervision exercised by regulatory

authorities,
Taking into consideration the country assessment reports of FATF, the IMF and the
World Bank, as well as other independent and reliable sources, adequacy of the
AML/CFT system in place in the correspondent institutions country of establishment
should be evaluated,
Our banks responsibilities and those of the correspondent institution under the
banking correspondence agreement should be specified clearly,
It has to be ensured that financial institutions combat system against laundering and
terrorist financing is appropriate and efficient via sending relevant questionnaires.
Approval of Assistant General Manager of Foreign Relationships shall be taken.
In the event that correspondent banking relationship includes using transfer
correspondent accounts (a type of account opened in Turkey by a non-resident
company. Customers of the account owner company can directly use this account
which enables drawing cheques), it has to be ensured that the financial institution
takes necessary measures within the frame of Know Your Customer principles and
can provide customers identity information when requested
Correspondent banking relationships shall not be established with shell banks, and financial
institutions that are suspected to enable their accounts to be used by shell banks.
A- 10 ELECTRONIC TRANSFERS
It is required that the following information of the originator is included in the cross border
and domestic wire transfer messages which amount to 2.000.-TRY or more;
a) Name and surname, title of the legal person registered to trade registry, full name of the
other legal persons and unincorporated organizations;
b) Account number or reference number of the transaction where no account number exists;
c) Address or place and date of birth and at least one of the numbers such as customer
number, TR-ID number, passport number, tax ID number for identifying the originator;
The above mentioned obligation does not apply to the transfers of banks among themselves
on behalf of their own name and accounts; and on the condition that card numbers are
stated in the messages, transfers made from bank and credit cards.
In the event that an electronic transfer that does not include the above mentioned
information is received, the transfer is returned or the missing information is completed by
contacting the related financial institution making the transfer.
31
On the condition that electronic transfers always have missing information and they cannot
be completed, denying the transfers, limiting the transactions of the sender institution or
terminating the business relationship with that institution is considered.
A-11 ADDITIONAL MEASURES AGAINST HIGH RISK GROUPS

The definition of high risk groups, the issues that shall be taken into consideration during
their transactions, and the measures that shall be taken are explained in the Monitoring and
Control Activities section.
A-12 RELATIONSHIPS WITH RISKY COUNTRIES
The definition of risky countries, the scope of risky countries, and the measures that shall be
taken are explained in the Monitoring and Control Activities section.
A-13 SIMPLIFIED MEASURES

Simplified measure is performance of a transaction or identification of customers who are
thought to be unrelated to laundering and terrorist financing without taking any documents or
taking some of the necessary documents, or without fulfilling some obligations. In order to
decide whether simplified measures can be taken for a customer or the transaction has the
below mentioned characteristics, adequate knowledge has to be obtained on customers and
transactions. Therefore, information shall be obtained from the customer, public sources,
third parties who has worked with the customer before and other sources and these data
shall be recorded in writing or in an electronic medium. For every circumstance that simplified
measures will be taken; abuse of these measures in terms of laundering and terrorist
financing shall be considered, these measures shall not be taken if there are any suspicions
and suspicious transactions shall be reported. Moreover, risk assessment shall be made
before taking simplified measures on customer basis.
For the customers for whom simplified measures will be taken, the following liabilities may
not be fulfilled:
Paying close attention to legal persons and identifying the real beneficiary.
Monitoring the customers and their transactions.
A-13-1 TRANSACTIONS AMONG FINANCIAL INSTITUTIONS

For transactions of financial institutions (Appendix 3) among themselves on behalf of their
own name and accounts; their title, trade registry number, TIN, field of activity, detailed
address, telephone number, fax number and email address (if possible), and and
name/surname, place and date of birth, nationality, type and number of the ID Card, sample
signature, and additionally for Turkish citizens name of the father and mother and ID Number
of the authorized representative of the legal person are deemed as adequate. This
information does not have to be verified.
If it is a non-resident financial institution, the institution must be a resident of one of the
member states of Financial Action Task Force where the states are subject to sufficient
regulations and supervision required by international standards related to prevention of
laundering proceeds of crime and terrorist financing
For the transactions made through alternative distribution channels with non-resident
financial institutions; in order to verify that the person acting on behalf of the financial
institutions is authorized, the transactions have to be made via SWIFT or by using passwords
which will enable verification and confirmation of the identity and authority of that person.
32
A-13-2 IN THE EVENT THAT THE CUSTOMER IS PUBLIC ADMINISTRATION OR

OCCUPATIONAL INSTITUTES HAVING THE SPECIFICATION OF BEING A PUBLIC
INSTITUTION
In the event that the customer is public administration or occupational institute having the
quality of public institutions (Appendix-2) as per the Law No.5018, the information on title,
license date/number given by official authority, field of activity, detailed address, telephone
number, fax number and email address (if attainable) should be obtained. This information
does not have to be verified. However, the identification of the representative is made in line
with the explanations stated in the Identification of Real Persons section, his/her sample
signature is taken and representative status is verified by power of attorney prepared in line
with relevant regulations.
A-13-3 IN THE EVENT THAT THE CUSTOMER IS INTERNATIONAL INSTITUTION OR
EMBASSY OR CONSULATE RESIDING IN TURKEY
In the event that the customer is an institution such as The International Monetary Fund, The
World Bank, European Development Bank or an embassy or consulate residing in Turkey;
financial institutions record the information of the real persons acting on behalf of these
institutions stated in Section A-2-2. Authorization of these persons is verified through a
document showing that they are authorized. Verification of the information obtained
according to Section A-2-2 is not obligatory.
As for the transactions carried out within this scope, liabilities of recognition of beneficial
owners and paying special attention to legal persons and monitoring the customer profile and
the transactions are not obligatory.
A-13-4 COLLECTIVE CUSTOMER ACCEPTANCE WITHIN THE FRAME OF SALARY

PAYMENT AGREEMENTS
In the establishment of permanent business relationships by the opening of accounts for
public administration or occupational institute having the quality of public institutions
pursuant to Law No.5018, or institutions, companies or firms employing more than 100
people with the aim of paying their salaries through the bank, the following information of the
real persons shall be obtained:
Name and surname,

Date and place of birth,
Nationality,
Name of the mother and father and Identity number for Turkish citizens,
Work or residence address,
Telephone number, fax number, and email address if attainable.
The information pertaining to identity is verified in line with the Article 6 of the Regulation.
Verification can also be made by using identity sharing system database of Ministry of
Internal Affairs on the condition that digital image is taken.
The documents of identity as has been explained in the identification section and sample
signatures are obtained within three months maximum beginning from the date of
transaction. Verification of address and contact information is also conducted within this
period. Reporting the names of the persons who will receive their salaries through the bank
and detailed addresses of their institution is deemed adequate for address verification of the
institution
33
A-13-5 SALARY PAYMENT TRANSACTIONS OF MEMBERS OF UNITS OF

INTERNATIONAL INSTITUTIONS RESIDING IN TURKEY OR MEMBERS OF EMBASSY
OR CONSULATES
In the establishment of permanent business relationships by the opening of accounts for
members of units of international institutions residing in Turkey or members of embassy or
consulates with the aim of paying their salaries through the bank, the following information
of the real persons shall be obtained:
Name and surname,

Date and place of birth,
Name of the mother and father and ID Number for Turkish citizens,
Nationality,
Work or residence address,
Telephone number, fax number, and email address if attainable.
The information pertaining to identity is verified in line with Section A-2-2. Verification can
also be made by using identity sharing system database of Ministry of Internal Affairs on
the condition that digital image is taken.
As for verification of identification, the documents of identity as has been explained in
Section A-2-2 and sample signatures are obtained within three months maximum
beginning from the date of transaction. Verification of address is also conducted within this
period. Reporting the names of the persons who will receive their salaries through the bank
and detailed addresses of their institution is deemed adequate for address verification of
the institution.
Since, the ambassadors and the chargs d affaires are considered as PEPs; related due
diligence measures are applied prior to account opening. Simplified measures referred
under this chapter are related to the other members (Turkish or foreign citizens) of the
embassy or consulates such as mid-level staff members other than senior officials.
A-13-6 IN THE EVENT THAT CUSTOMER IS A PUBLIC COMPANY WITH QUOTED
SHARES IN STOCK EXCHANGE
For the transactions of such companies, information that has been stated in the identification
section shall be obtained for legal persons related to the company. This information does not
have to be verified.
A-13-7 TRANSACTIONS RELATED TO PENSION AGREEMENTS, PENSION PLANS AND
LIFE INSURANCE AGREEMENTS
In transactions carried out within the frame of pension agreements, pension plans which grant
pension rights by making deductions in the salary or life insurance agreements where the total
amount of premium paid in a year is TRY 2.000,- or below or in single premium accounts
where the premium amount to be paid is TRY 5.000,- or below; the information listed in the
Identification of Real Persons shall be obtained without regard to verification documents.
In case of disbursements, verification documents shall also be obtained and verified.
34
A-13-8 TRANSACTIONS OF PRE-PAID CARDS

Pre-paid cards are related to the Finansbank accounts of our customers.
Identification is not obligatory for the below mentioned pre-paid cards which are followed on
card number basis, do not have a name on them, effective when an amount is preloaded or
loaded, and allow spending up to the limit of loading.
Single use pre-paid cards in which the loaded amount does not exceed TRY 300,-,
Reloadable pre-paid cards for which the total loaded limit does not exceed TRY 5.000,(those cards that allow cash withdrawal or wire transfer to another account amounting
to a total of more than TRY 2.000 in the same calendar year are excluded) in a calendar
year.
A-13-9 VERIFICATION OF ACCURACY OF TELEPHONE AND FAX NUMBERS AND EMAIL ADDRESSES
Telephone and fax numbers and e-mail addresses of customers obtained for identification
purposes in the establishment of permanent business relationships are verified by contacting
the relevant persons through these contact information on a risk based approach when
necessary.
A-14 REPORTING OF MONITORING AND EVALUATION RESULTS TO THE BOARD OF
DIRECTORS VIA AUDIT COMMITTEE
The results of the monitoring and evaluation activities carried out by AML Unit are reported to
the Audit Committee every three months, which brings the report to the attention of the
Board of Directors.
B- MONITORING AND CONTROL ACTIVITIES

Monitoring and control activities aim at prevention the risks mentioned in this document and
continuous monitoring and control of the activities in order to ensure that they are being
carried out in line with the Law and relevant regulations, communiqus, banks in-house
policy and procedures.
The deficiencies detected at the end of the controls carried out or the sake of compliance with
the obligations brought about by the Law is reported to relevant units so that necessary
measures are taken and the results are followed. It has to be ensured that the officer who
conducts monitoring and control activities have access to in-house information sources.
B-1 MONITORING AND CONTROL OF THE TRANSACTIONS OF HIGH RISK GROUP
CUSTOMERS
The high risk group customers stated in risk management chapter in detail is;
Non-residents
Residents in Offshore Regions and special purpose vehicles (SPVs)
Persons Residing and Transactions Carried out in Countries Which Do Not Act in
Accordance with the Recommendations of FATF
PEP-Politically Exposed Persons
Companies with Bearer Share
35
Not-profit organizations
Persons with high amount of funds (Ex. Private Banking Customers)
Non-Face-to-Face Transactions
Risky sectors and profession groups
Cash transactions
Correspondent Banking Relationship
Trusts
Opening accounts for High Risk Group Customers is performed with the approval of the
branch managers. The branch manager signs the Customer Assessment Form. Base/account
openings cannot be carried out with a form that has not been signed by the branch manager.
Opening accounts for private banking customers is performed with the approval of Head
Office Private Banking or Head of Private Banking Center.
Prior to opening accounts for customers in high risk group, their reason for working with our
bank, reason for opening an account, working principles, information and documents about
their commercial or non-commercial business are obtained.
Apart from the regular inspections, on-going monitoring is conducted for accounts and
transactions of high risk customers, either through a relative information system, or by
employees of the Bank.
B-1-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO HIGH RISK GROUP
CUSTOMERS:
Exchange Offices (Authorized Institutions)
Accounts opened for exchange offices whose activities are limited to cash transactions, where
small bills are changed with larger ones, which do not require professionalism, can be
founded with a poor technical equipment, are relatively less costly to establish and manage
than other financial institutions are mostly used as instruments for money laundering in the
world and in our country without drawing attention in terms of bringing cash money into the
financial system. Therefore, control of the accounts of exchange offices are conducted
monthly.
Control of the Exchange Office Accounts
The aim is to detect sent and received transfers (money transfers, EFT, SWIFT) by the third
parties or the exchange office. Information is requested from branches regarding the
exchange office and transactions as a result of the evaluations made in accordance with these
criteria. In the light of the information obtained from the branch and the opinions of the AML
Unit, a suspicious transaction report is made to Financial Crimes Investigation Board if there
are any suspicions.
Control of the Real Persons Accounts Whose Address are Exchange Offices
Transactions of drawing accounts of such persons are inspected. After the inspections
conducted by paying attention to cash transactions, buying/sale of F/X, sent and received
transactions, principals/beneficiaries of transfers, information is requested from branches on
detected real person customers. Suspicious transaction report is made to Financial Crimes
Investigation Board if it is detected that these persons are partners/employees of exchange
offices and transactions of the offices are made through their accounts.
36
Controls conducted in the event that the customers are non-profit

organizations, private banking customers, or customers of risky sectors and
occupational groups
Within the frame of daily monitoring and control activities made through MANTAS AML
system, account activities of high risk customers are analyzed. In the event that there are
suspicious transactions, branches are consulted for further information and AML Officer
reports suspicious customers to MASAK.
B-2 MONITORING AND CONTROL OF THE TRANSACTIONS PERFORMED IN RISKY
COUNTRIES
The below listed criteria are taken into consideration in determining whether the countries are
risky or not:
Whether FATF recommendations are being implemented or not

Whether they are in the list of non-cooperative countries declared by FATF
Whether they are in OFAC, EU (European Union) and UN (United Nations) lists
Whether they comply with EU directives
The nature of the national regulations
Regime (Dictatorship, military government etc.)
Qualification of the banking sector
B-2-1 CONTROLS CONDUCTED BY AML UNIT RELATED TO RISKY COUNTRIES:
Control of the transfers made through Western Union

Western Union is a widely used system preferred by Turkish or Foreign walk-in
customers since it enables fast money transfer. WU transactions are highly risky
because originators/beneficiaries of the transfers are usually unknown and the senders
are mostly walk-in customers who are in Turkey for a short period of time. Controls
are conducted in every three months. Transactions are controlled according to certain
criteria (amount, risky countries, frequency of transaction, Structuring and Smurfing
method etc.) on the basis of beneficiary/originator. ID Documents, Senders and
receivers occupation, address, telephone number, relation with the risky country and
the parties of the WU Transaction, their reasons for working with our bank, purpose of
the WU transaction are asked to the branch. According to the answer of the branch
and the assessments of the AML Unit, AML Officer prepares a suspicious transaction
report to be submitted to MASAK.
Control of the Alerts Generated By ISS System.
In the electronic transfers the information in our Banking Core System on sender,
receiver, receiver bank, receiver country, a.k.a.s (also known as) and other related
information are cross checked by the KOMTA ISS System with the data obtained from
OFAC SDN list, EU Sanctions List, Banned/Sanctioned Countries List, Western Union list
and Finansbank Alert List The user is notified on the basis of a certain ratio of matching
before completing the transaction, and details are provided in the related menu on Alert
lists and matching records.
If there is a logical matching; the user consults the AML Unit immediately. Having
completed all necessary controls both on AML Units and the users side ; the transaction is
approved or , rejected by the user.
37
Furthermore, on a daily basis, AML Unit conducts certain controls and checks the previous
days customer base opening and electronic transfers to detect whether either of the
transactions has been approved without consulting AML Unit although the match rate is equal
or more than 85% for base opening, %75 for electronic transfers or there is a logical
similarity with the information provided in the KOMTA ISS system.
B-3 MONITORING AND CONTROL OF COMPLEX AND UNUSUAL TRANSACTIONS
Complex and unusual transactions are monitored within the frame of below stated controls:
B-3-1 CONTROL OF SAFE DEPOSIT BOXES
In order to detect risky transactions such as hiring a safe box for common use with those
other than family, relatives and business related persons, or giving power of attorney to such
persons; busy transaction traffic showing that the safe box is being used by many people as
safe deposit box; frequent use of safe boxes by those who do not have remarkable account
transactions and transaction volume; hiring the safe box under different names before and
after performing remarkable transactions; hiring a safe box on behalf of a commercial
company even though the transactions do not require one, the list of hired safe boxes are
taken at the end of every month. Suspicious transactions are reported to Financial Crimes
Investigation Board depending on the information obtained from the branches.
B-3-2 ANALYSIS OF CASH AND TRANSFER TRANSACTIONS:
system, cash and transfer transactions are analyzed. In the event that there are suspicious
transactions, branches are consulted for further information and AML Officer reports
suspicious transactions to MASAK.
B-4 CROSS CHECK OF THE TRANSACTIONS ABOVE A CERTAIN AMOUNT WITH THE
CUSTOMER PROFILE BY THE SAMPLING METHOD
Where in the evaluation phase made during account opening it is decided that the
transactions of the account shall be monitored for a specific period although there is no risk
involved in opening an account for that customer or where it is determined that the customer
carries out transactions that are inconsistent with his profile after the account has been
opened, the employee who has opened the account or made these designations shall inform
Compliance Department AML Unit in writing to allow customer-based monitoring and review
that will be conducted specifically.
system, customers whose accounts are inconsistent with their profiles are detected. Branches
are consulted for further information and after assessment of the information received from
the Branch, Compliance Officer submits suspicious transaction report to MASAK.
B-5 MONITORING AND CONTROL OF THE TRANSACTIONS
IDENTIFICATION LIMIT AND SUBSEQUENT TRANSACTIONS
WHICH
EXCEED
Report on cash transactions and transfers which exceed identification limit are obtained by
Internal Audit Department Central Monitoring Unit. This report is sent to auditors who inspect
the branches detected in the report. Auditors, then, inspect sample transactions among the
cash and transfer transactions listed in the report in order to check whether identification has
been conducted, signature has been taken, and power of attorney has been taken if there is a
transaction performed by third parties. The findings are sent to Internal Audit Department
Central Monitoring Unit. Every six months, this unit informs the AML Unit about suspicious
transactions who report them to the Financial Crimes Investigation Board.
38
B-6 CONTROL OF THE INFORMATION AND DOCUMENTS RELATED TO CUSTOMERS

THAT ARE KEPT IN WRITING OR AN ELECTRONIC MEDIUM; CONTROL OF THE
INFORMATION THAT HAS TO BE STATED IN ELECTRONIC TRANSFER MESSAGES;
COMPLETION AND UPDATING OF THESE INFORMATION
Taking and keeping of the ID card for transactions requiring permanent business relationship
and exceeding identification limit has been explained in the Risk Management section.
For the control, completion and updating of the obligatory information in the electronic
messages, in line with the European Union directives, special attention is paid to fully provide
the principals information that is making the overseas transfer (name/surname, address and
reference number or passport number or account number). In the event that there is missing
information, extra time is given to the bank making the overseas transfer. If the required
information is not provided, transfer fee is returned.
B-7 ON-GOING MONITORING OF THE TRANSACTIONS IN ORDER TO CHECK THEIR
CONSISTENCE WITH THE CUSTOMERS OCCUPATION, RISK PROFILE AND SOURCES
OF FUNDS
In the event that the same customer has different accounts at different branches, these
accounts shall be monitored on a consolidated basis.
Customers;
Attempting to carry out any transaction with no apparent legal or economic purpose;
Who ask transactions which are not proportionate to their income or job are made;
Who avoid or are reluctant in supplying documents and information required to be
supplied by law;
Who give the impression of avoiding reporting and record keeping procedures;
Who supply misleading and unverifiable information;
Who ask for non-economical credit or credit with no explained purpose;
Who say that they are expecting or want to send high amount wire transfers from or
to risky geographical regions and countries;
Shall be monitored carefully.

Where in the evaluation phase made during account opening it is decided that the
transactions of the account shall be monitored for a specific period although there is no risk
involved in opening an account for that customer, where it is determined that the customer
carries out transactions that are inconsistent with his profile after the account has been
opened, or if the customer demands some transactions like the ones listed above, the
employee who has opened the account or made these designations shall inform Compliance
Department AML Unit in writing to allow customer-based monitoring and review that will be
conducted specifically.
system, customers whose accounts are inconsistent with their profiles are detected. Branches
are consulted for further information and after assessment of the information received from
the Branch, AML Officer submits suspicious transaction report to MASAK.
39
B-8 CONTROLS OF THE NON FACE-TO-FACE TRANSACTIONS

Our bank is obliged to devote special attention to and take necessary measures against risks
of using advantages of new and developing technology for laundering proceeds of crime and
terrorist financing.
Therefore, transactions like cash transactions and money transfers carried out via alternative
distribution channels such as internet, telephone banking and ATMs are controlled within the
frame of monitoring and control activities made through MANTAS AML system.
In addition, at the beginning of the business relationship, before establishing a business
relation with the customer, a customer should be physically present in our branches for ID
verification and other related actions such as signing the banking transactions agreement or
other legal documents.
Therefore, such transactions cannot be executed by walk-in
customers via internet banking, call center, etc.
B-9 RISK BASED CONTROL OF NEW PRODUCTS AND SERVICES THAT MAY BECOME
VULNERABLE TO MISUSE DUE TO TECHNOLOGICAL DEVELOPMENTS
Before a new product of our bank is put on the market, it is submitted to Legal Compliance
Department, Internal Audit Department, Internal Control Center and Risk Management for
approval. After the subject is evaluated in a risk-based approach and in accordance with the
legislation, the new product is approved and presented to customers.
B-10
SUSPICIOUS OR UNUSUAL TRANSACTION REPORTING
A suspicious transaction is an event where there is information, suspicion or any matter that
may evoke the suspicion that a possession which is part of a transaction made within or over
our bank or which is part of an attempted-transaction, is gained by illegal means or used for
illegal aims, terrorist attacks or that the possession is used by terrorist organizations,
terrorists or people who finance terror.
An unusual transaction or transactions or activities incompatible with the customers or
beneficial owners economic/transacting profile (transactional, professional or business
behavior, financial condition) or have no apparent purpose or motive of a financial,
professional or personal nature.
Suspicious or unusual transactions are regardless of the amount of the transaction
reported to The Financial Crimes Investigation Board (MASAK) operating within the body of
Ministry of Finance. While evaluating the suspiciousness of the transaction, matters like the
profile and scale of the activities of the client, nature of the transaction and whether the
transaction is found within the normal activities of the client or is proportional with the
activity of the client and to whom the transaction provides benefits, characteristics of the
sector and previous experiences shall be taken into consideration. In case of an international
transaction, it must be checked that whether the transaction is part of the business of the
client.
The term transaction in the concept of suspicious transaction is not limited to only one
transaction. When necessary, more than one transactions may be handled together to find
out whether there is suspicion or a reasonable cause for suspicion. For example, a series of
transactions which do not evoke suspicion as single transactions may evoke suspicion when
evaluated together.
In case of a suspicious or unusual transaction, customer identification shall be made for
reporting. In case of an attempted-transaction, the obligation for customer identification is
carried out in the possible extent.
40
The reporting of a transaction within continuous reports does not render the transaction
exempt from suspicious transaction reporting.
Compliance Officers are responsible for reporting suspicious or unusual transactions to
MASAK. In our bank, Mr. Ahmet Erzengin and Ms. Baak Ylmaz from Compliance Department
are authorized for this duty.
Suspicious Transaction Forms shall be filled in and sent to the above mentioned Compliance
Officers. It is compulsory to report these transactions to MASAK in 10 working days time
after the suspicion occurred.
When new information or findings are acquired about a previously reported transaction, a
new Suspicious Transaction Reporting Form is filled in and sent to the Compliance
Department stating that the new report is an addition to the previously reported transaction.
Those who report suspicious or unusual transactions and other bank personnel, who are
informed of the transaction, shall not reveal the reporting to anyone other than auditors who
are in charge of audit of obligations and courts in course of a trial. Internal reports are also
confidential. Compliance Officers carrying out suspicious transactions in the electronic media
shall not share instruments cards, passwords, etc. - that enable accessing the system with
anyone.
Central offices of the bank found in foreign countries, branches, agencies, commercial agents
and/or other similar units shall not be informed about the reporting.
Bank employees - Compliance Officers, legal agents, managers and bank personnel - who
carry out their obligations to report suspicious transactions shall not be held responsible for
any legal and criminal results about fulfilling this duty.
B-10-1 LAUNDERING PROCEEDS OF CRIME
Wealth gained by predicate offenses such as human trafficking, drug and arms smuggling,
corruption and bribery, fraud, forgery and hijacking are tried to be laundered in the financial
system through various stages, such as segmentation. Proceeds of crime that are placed into
the financial system through various methods pass through numerous operations in order to
make it difficult to track its source (money transfers to many people in the country or abroad,
purchase and sale of foreign currencies, etc.).
After placement and layering stages, proceeds of crime again pass through many transactions
called the integration stage in order to bring it back to the source. The purpose is to make
it harder both for those who perform the transactions and for auditors to reach the launderer.
Throughout their work to prevent money laundering, our employees shall be careful for
transactions;
Which do not have legal and economic purposes in appearance,

Which are not related and proportional with the income and job of the client,
In which the client is unwilling to present the documents and information that are
stated as compulsory by the Law,
In which the client tries to avoid reporting and preserving of records,
In which the information given by the client is misleading and impossible to attest,
Of high-scale sent to risky countries or geographical areas and extraordinary transfers,
and for loan applications which do not have economic purposes and purposes of which are not
described by the client.
Possible suspicious transaction types are described below:
41
B-10-2 SUSPICIOUS OR UNSUAL TRANSACTION TYPES DESCRIBED IN GENERAL

COMMUNIQUE NO. 6 OF THE FINANCIAL CRIMES INVESTIGATION BOARD
SUSPICIOUS OR UNUSUAL TRANSACTIONS IN THE GENERAL NATURE
1.
Types regarding the customer profile
1.1. Insufficient or contradictory information on the documents presented to bank personnel

or reluctance in presenting documents.
1.2. Existence of concrete suspicious behaviors such as offering remuneration or various
gifts in exchange for the transaction or situations such as existence of unfavorable news
about the customer in the press that the customer is involved in financing of terror.
1.3. Customer is engaged in deliberate urge to establish friendly relations with the bank
personnel or is in a threatening attitude to prevent the reporting of the suspicious
transaction.
1.4. Inconsistency among customers job/occupation, financial situation and type of
transactions.
1.5. Commercial or other type of relations of the customer with risky persons or institutions.
1.6. When compared with other companies in the sector; unusual capital, partnership,
management and employment structure of the company.
2. Types regarding the transactions
2.1. A single transaction of a person or an institution engaged in commercial activities that
should normally be a routine and continuous transaction within the commercial activities or
on the contrary, continuous repetition of transactions that are relatively rare in the
commercial life.
2.2. In order to evade detection and reporting, without a reasonable explanation, separation
of transactions that should normally be made as a whole.
2.3. Absence of a reasonable legal or economic reason of the requested transaction.
2.4. Unusual use of payment instruments such as high amount of payments of the customer
in small denominations or payment using a rare foreign currency.
SUSPICIOUS OR UNUSUAL TRANSACTIONS ACCORDING TO THE SECTOR
3. Types regarding the banking sector
Suspicious or Unusual Customer Behaviors and Indications Regarding
Presentation of Insufficient-Misleading-False Information and Documents
the
3.1. Before carrying out a transaction, customer tries to acquire information and asks
questions about the customer identification and obligation of suspicious transaction reporting,
transaction limits and banks control methods in the fight against money laundering
3.2. Hardships are experienced during the receipt of the customers personal information
such as his occupation, identity, address and telephone number.
3.3. The customer has difficulty to explain or refrains from giving information about
the
42
purpose of the transaction and the source of the funds subject to the transaction.
3.4. The customer tries to persuade the bank official for not filling a document which is
legally or administratively required to be filled or submitted to the official authorities.
3.5. The customer requests to open account by power of attorney in the name of many
persons located inside or outside the country without a valid reason or without substantiating
its justification or he constantly deposits or draws cash for transactions carried out through
the accounts opened in the name of third persons.
3.6. The account holders do not have sufficient knowledge of the funds deposited or existing
in their accounts.
3.7. Customers, which are apparently independent from each other, giving the same
address, telephone number and other contact information, transferring fund to the same
beneficiaries, receiving transfers from same applicants and entitling same person(s) with the
authority to sign.
3.8. The customer rents safe deposit boxes together with persons who are not members of
his family or with whom he has no business partnership or he gives power of attorney to such
persons in order to allow them use his safe deposit boxes, intensive use of the safe deposit
box by many persons showing that the deposit box is used as a cash box, customers whose
account relationship and transactions with the bank are not at considerable amounts use the
safe deposit boxes intensely, customer rents safe deposit boxes in the name of third persons
just before or just after a remarkable transaction, and though its commercial activities do not
require, commercial institution rents safe deposit boxes.
3.9. Persons understood to be having no family or business relations with each other open
joint deposit accounts; they perform collective transactions on such accounts and it is
observed that the domestic or international cash or electronic funds transfer traffic through
such accounts is considerably higher than reasonably deemed appropriate for the profile of
the saving deposit in question.
3.10. It is understood that the real or legal entities shown as the partners and managers of
the legal entity customers are indeed not genuine shareholders of such companies and there
is a suspicion that the capital and the management of the company are under control of third
persons who have bad reputation or against whom legal actions have been instigated by
official authorities.
3.11. The new controlling partner and/or partners of legal entities evade providing
information regarding his personal and business background and the new partner has no
previous interest, educational background and work experience regarding the field of activity
of the company.
Customer Identification, Record Keeping and Indications of Avoiding Reporting
Procedures
3.12. Customer tries to open accounts, carry out transactions or perform transactions in the
name or over the accounts of others without presenting their identity cards or by presenting
false or imaginary identities.
3.13. Customer tries to persuade bank officials not to report the suspicious transaction by
different offers, oppression or by threatening.
3.14. In order to evade the procedure of reporting, customer segments or attempts to
segment the money that is subject to transaction by depositing or transferring into different
accounts or as cash.
3.15. Customer holds many accounts by which he operates on his behalf or on behalf of
others in different branches of the same bank or persons understood to have opened similar
43
accounts in other banks.

3.16. Many people depositing money into the same account or drawing money from the
same account without any clear or practical reason.
Types regarding transactions with cash character
3.17. The cash brought by the customer is in small denominations and dirty; there are stains
on it or it smells indicating that it has been carried as covered inside various articles; it has
been packed precariously and in a hurried way; it often turns out to be less or more than the
value stated by the customer once it is counted; there are counterfeit money in it; the
customer gives this in pack or covered by an article in a way that can not be deemed
appropriate for the customer.
3.18. It is observed in the customers accounts that cash draw or deposit transactions in
many small amounts which total a high amount, or in a single transaction in a high amount
which can not be deemed congruent with the living standards, occupation and income level of
the customer.
3.19. The cash deposited to the accounts is constantly transferred abroad or to other
domestic accounts without providing sufficient explanation, or such accounts are left idle for a
long time after such transactions are carried out for a period.
3.20. The amounts transferred to the accounts which are understood to have been opened
for the sole purpose of collecting the transfers from abroad are constantly drawn in cash
without being subject to any transaction, or such accounts are left idle for a long time after
such transactions are carried out for a period.
3.21. The customer keeps idle accounts with small balances in several branches of the same
bank, and he draws the incoming transfers to such accounts through maximum limit cash
drawings from ATMs.
3.22. People, who do not have a clear relationship with the company, deposit cash into
accounts or draw cash from accounts opened in the name of the company and from the sum
of these transactions it is evident that the transaction is not carried out within commercial
purposes.
3.23. The customer often deposits or draws significant amounts of cash in a single
transaction without considering the risks of security, theft and abuse that may arise out of
transport of cash money, except for appropriate reasons.
3.24. Without any clear economic purposes, accounts opened with high amounts of cash by
legal persons or entities about whom no sufficient information is acquired.
3.25. By frequently putting in cash equivalents, the customer requests the issuance of quasi
money instruments such as certified check, letter of guarantee, and payment order over
sums that are not related or which can not be associated with his business.
3.26. Depositing small pieces of denominations into the same account by different persons
through the same or different branches.
3.27. Depositing a high amount of cash into an account of a small balance and drawing this
sum or transferring into one or more than accounts just after the transaction.
Indications Regarding Electronic Transfers
3.28. Transfers in high amounts and at a single transaction without any reasonable
explanation to or from risky countries or offshore centers, or such transfers in small amounts
but many in number during a certain period of time.
44
3.29. There are no explanations regarding the purpose of the electronic fund transfers at
considerably high amounts and frequencies from high-risk regions; the spaces for the full
names and addresses of the payees and payers in transfer messages are not filled or
pseudonyms, codes or abbreviations are written instead of specifying the full names of the
genuine payers.
3.30. A considerably high traffic of domestic and international electronic fund transfers at
considerably high frequencies is observed at the customers accounts and which are
incongruent with the declared occupation, activities, income sources and income level of the
customer.
3.31. The incoming funds transferred from abroad to the accounts or the names of the
customers with registered addresses inside or outside the country are transferred back to
abroad after a brief period, or the customer requests from the bank clerk realizing the
transaction that the transfer amounts he expects from abroad and not registered to his
accounts yet to be transferred to abroad; similar amounts of funds enter and exit the country
at similar dates through such accounts used as transitory accounts.
3.32. The customer opens more than one account in the same currency without any specific
cause, and transfers the cash deposited to these accounts or the cash funds transferred to
these accounts to persons or entities located in free trade zones or offshore geographical
areas with which the customer has no apparent business relation.
3.33. Accounts opened only for transfers outside the country and there is no sufficient
information regarding the relationship between payees and payers of these transfers.
3.34. Customer carrying out indirect electronic fund transfers that are not related to the
personal or economic situation of the customer.
3.35. High amounts are transferred into an account right after it is opened and the account
is left idle for a long period of time.
3.36. Transfers carried out by a person acting in the name of the customer, over foreign
currencies between people or countries which have no commercial relationship with the
customer.
Indications Regarding Loan and Credit Transactions
3.37. Real persons and entities, about whom there is not much, request cash credits or letter
of guarantee for commodity purchases, in a way not caring for the commissions, charges or
interest rates of the bank.
3.38. The customer presents a check of high amount which is drawn on a foreign bank, as
his guarantee for credit, to the bank granting the credit, but the information about the
commercial activity that the check stems from is contradictor, the customer can not present
supporting document, apparently a commercial relationship can not be observed among the
drawer and the endorsers and the endorsers have an association with risky territories in
terms of swindling and smuggling.
3.39. Credit utilization from banks found in risky countries or applying for credit in regard of
letter of guarantees provided from these banks.
3.40. The customer applies for a loan by showing the assets of third persons or of the
companies registered in risky countries as guarantee without a reasonable and practical
cause.
3.41. Although the customer has a remarkable amount of wealth, he applies for a credit that
is not rational for him by showing his assets as guarantee.
45
3.42. The customer applies for a credit by showing as guarantee bearer instruments or other
instruments the sources of which are unknown.
3.43. The potential credit customer is either reluctant to state the reasons of applying for
credit, refuses to state such reasons and states a doubtful reason.
3.44. Without a clear reason, third persons who are unknown to the bank and who does not
have close relationship with the customer provide guarantees.
3.45. Credit card customer perpetually draws a remarkable amount of cash, or uses the
credit card continuously and/or extraordinarily for the purchase of valuables that are easy to
change such as gold.
3.46. Without a logical reason and surprisingly, the customer all of a sudden pays back a
non-performing or an undue credit.
4. Types Regarding the Insurance Sector
4.1. The customer applies to insure a risk that that is not associated with his personality, his
business or capital.
4.2. The customer requests a single premium draft of high amount that is not associated with
his general and financial situation.
4.3. The customer declares or the bank finds out that he has bills from other companies as
well, and this shows incongruity with the financial situation of the customer.
4.4. The customer offers to buy insurance policy in the name of a third party which has
clearly no connection with him, or requests the insurance indemnity to be transferred into the
account of the party in question or again in the name of a third party, requests the changing
of the beneficiary.
4.5. The customer overpays in cash the premiums of insurance or pension plans.
4.6. A customer who owns a regular payment draft of small amount all of a sudden pays the
remaining premiums of the draft in cash, offers a remarkable increase or buys a new draft of
high amount.
4.7. Without a logical reason and aware of the remarkable loss the transaction would bring,
the customer requests the draft to be paid back before its expiry or to be paid in favor of a
third party.
4.8. The customer pays the premiums of an insurance contract via electronic transfer over a
financial institution found in a risky country.
4.9. The customer applies for a pension plan or life insurance, which can not be deemed
congruent with his age or health.
5. Types Regarding the Capital Markets
5.1. It can be understood that the customer do not seek profit in his transactions, does not
care the cost and risk of his investments and gives unreasonable orders that usually end up
with loss.
5.2. The customer borrows a loan of remarkable amount that is incongruent with his
business or the guarantee for the credit is given by a third person that is seemed to have no
relationship with the customer.
5.3. Without a situation regarding the market conditions or any other logical reason, the
46
customer, all of a sudden, pays back the security loan before its expiry.
5.4. Without a logical reason, the customer continuously transfers securities and/or cash into
to the accounts of others found in different intermediary institutions.
5.5. Inconsistent with his common activities, the customer buys securities or other capital
market instruments in remarkable amounts by cash.
5.6. The financial investments and/or the proceeds of these investments are immediately
transferred to third parties who are seemed to have no connection with the customer.
5.7. There is a transaction ban imposed by the Capital Markets Board for the shareholders or
founders of the legal entity customer.
5.8. There is a suspicion that the customer is carrying out transactions on behalf of persons
who are banned by the Capital Markets Board.
6. Types Regarding the Competent Authorities
6.1. In a short period of time, requests regarding foreign currency purchase and sale through a competent authority in amounts below the limit that requires customer
identification are constantly repeated.
6.2. Constant repetition of foreign exchange purchase or sale transactions and the change of
a foreign currency with another.
6.3. The change of small denominations in uncountable amounts with large denominations.
6.4. The cash brought by the customer is in small denominations and dirty; there are stains
on it or it smells indicating that it has been carried as covered inside various articles; it has
been packed precariously and in a hurried way; it often turns out to be less or more than the
value stated by the customer once it is counted; there are counterfeit money in it; the
customer gives this in pack or covered by an article in a way that can not be deemed
appropriate for the customer.
6.5. The request to change non-convertible or a rarely used foreign currency with another
foreign currency or with Turkish Liras.
7. Types Regarding the Lenders
7.1. The debtor requests a loan in exchange for a property the source of which is suspicious
(or unknown).
7.2. Despite the remarkable wealth of the debtor, he requests to carry out uneconomic loan
transactions.
7.3. The debtor pays back by checks to the bearer, by checks that belong to third parties, by
checks that are frequently endorsed or by cash in high amounts.
7.4. Surprisingly and all of a sudden, an unexpired or a non-performing credit is paid back.
8. Types Regarding the Factoring Companies
8.1. The company which transfers its claims of a forward sale to a factoring company
(vendor), continuously carries out the sale of goods or services at costs higher than the
conditions of the market to its legal person or legal entity customers (purchaser).
8.2. The purchaser company pays or guarantees to pay on time its forward debts, which
over exceed its financial situation, or in a similar situation the vendor company gives the
47
guarantee that the purchaser will pay its debts on time.

8.3. There is a suspicion that the purchaser or vendor company may be a shell company or
that there may be a fictitious transaction established between them.
8.4. There is a suspicion about the genuinity of the invoices presented to the factoring
company.
9. Types Regarding Leasing Companies
9.1. An attempt to rent a machine or equipment by leasing method at inappropriate prices
when compared with current market or estimated value.
9.2. Leasing payments that are much higher than normally requested and that are not based
on a reason.
9.3. The payment of leasing debts from an unknown source before its expiry.
9.4. Without a logical reason, the performing of obligations or payments that incur from the
leasing contract by third persons or by persons who supply the goods in question.
10. Types Regarding Consumer Finance Companies
10.1. Without a clear reason and despite the financial loss it will cause, the customer all of a
sudden pays back the credit.
10.2. The customer carries out unprofitable credit transactions in exchange for the
remarkable wealth he possesses.
10.3. There are indications that the customers do not care the costs and term of the credit.
11. Types Regarding Mail and Transportation Services and Courier Companies
11.1. It is clear that the goods that are sent via mail or courier are different than the ones
declared by the sender.
11.2. Sending valuables such as gemstones, mines, etc. to certain addresses other than
those dealing with trade or production in the sector.
12. Types Regarding the Real Estate Sector
12.1. Without a logical reason such as business or family relation, the customer purchases
real estate in the name of third persons.
12.2. Inconsistently with his financial situation, the customer buys real estates at high
values or without making any research about the location and conditions of the real estate,
the customer buys properties that require a remarkable cost of repair.
12.3. Customers who sell their real estates, and demand the sale value to be recorded
higher than the actual value.
12.4. After carrying out the first payment in cash; for the rest of the leasing, the customer
uses an extraordinary payment method or a high amount of cash.
13. Types regarding people who are supposed to have connection with terrorist
organizations and transactions carried out in risky countries
13.1. Opening accounts, transferring funds or carrying out electronic fund transfer in the
48
name of legal persons of legal entities that are known to have relations with a terrorist
organization.
13.2. Electronic fund transfers that have no commercial explanation or economic reason,
into commercial accounts found in risky countries and/or drawing these amounts out of the
account.
13.3. Transferring funds into risky countries or receiving funds from these countries,
opening accounts in financial institutions found in these countries or using credit cards of
banks found in these countries.
13.4. Funds are transferred by third persons to countries associated with terrorism and
smuggling or named as tax heavens, or to regions, which have no open business connections
with the customer, in the name of the customer after exchanging the currency of such funds.
13.5. Transferring the deposits that are gained by transfers from risky countries or over
risky countries to third persons.
13.6. Collection of funds particularly from risky countries or transferring funds into these
countries, by use of many individual and commercial accounts, and transferring such funds to
a limited number of payees.
13.7. Without a commercial reason that would render the transaction reasonable, use of
commercial financial transactions in fund transfers to/from risky countries.
14. The Types Regarding Non-Profit Organizations
14.1. Inconsistency between the pattern and size of financial transactions or amount of
funds raised or moved, and the apparent sources, stated purpose and activities of the NonProfit Organizations. For example, a cultural association that, after organizing a music
festival, deposits disproportionate amounts on its bank account.
14.2. Appearing of a sudden increase in the frequency and amounts of financial transactions
in the account of a non-profit organization.
14.3. Keeping funds in the accounts of a non-profit organization for a very long period.
14.4. Where non-profit organizations receive contributions only from donors located abroad
or the origin of which is mostly from abroad.
14.5. The existence of foreign directors in non-profit organizations, and particularly
existence of large outgoing transactions to the country of origin of such directors and
especially if destination is a high-risk jurisdiction.
14.6. The existence of a large number of non-profit organizations with unexplained links: for
example, several non-profit organizations transfer money to each other or share the same
address, same managers or personnel.
14.7. The existence of account movements which makes an impression that non-profit
organizations holding little or no staff, no suitable offices or telephone numbers have
intensive activities.
14.8. Receiving funds by using many personal and commercial accounts or accounts of nonprofit organizations and later transferring these funds to foreign beneficiaries in a short period
of time.
49
B-10-3 TERRORIST FINANCING
Characteristics of Terrorist Financing
The primary objective of terrorism is to compel a government or an international organization

to do or to abstain from doing any act by intimidating a people or arousing indignation in a
people. All terrorist organizations need financial resources in order to carry out their financial
activities regardless of what the aimed target is. Therefore, terrorist organizations seek to
have adequate financial resources and to use these resources without attracting the attention
of concerned public authorities. For this reason, it is of great importance in the fight against
terrorism to deprive terrorist organizations of financial resources.
A good-knowledge regarding the characteristics of terrorist financing is the primary
requirement for an effective fight against terrorist financing. One of the most important
characteristic of terrorist financing is to necessitate carrying out it without attracting the
attention of law enforcement authorities. Therefore, by concealing terrorist acts, the reveal of
the connection between terrorist financiers and the original offence is avoided and the seizure
or confiscation of the funds allocated to terrorist financing is precluded. In this regard,
terrorist financiers usually apply methods similar to those used by launderers when they are
operating these funds for terrorist organizations or conveying them to terrorists or terrorist
organizations.
Obliged parties should be more careful about the detection of suspicious situations related
with terrorist financing as terrorism can be financed from funds acquired through not only
illegal means but also legal means. For example a terrorist organization can be financially
supported through legally acquired incomes of an enterprise running business in
manufacturing of service sector. In this respect, it is necessary to closely monitor and know
not only the origin of the fund but also where it is used.
The fact that even small amount of funds are enough for performing some terrorist acts
makes it necessary for obliged parties to be more careful in detection of acts related with
terrorist financing, which is different from that of laundering acts.
Financial Resources of Terrorism
Terrorist organizations meet the financial needs necessary for their activities from various
sources.
Resources acquired through illegal activities
Terrorist organizations obtain significant amounts of resource through illegal activities

committed by criminal organizations as well. The major activities include drug trafficking and
arms smuggling, human trafficking, migrant smuggling, threat, blackmail, racketing,
extortion, robbery and kidnapping.
Narcotics smuggling is one of the leading illegal financial resources of terrorism, and narcoterrorism concept is recently being used in defining the close connection between terrorist
organizations and drug smugglers.
Likewise, there is a direct relation between arms smuggling and terrorism. Terrorist
organizations both meet their need of arm and obtain income through arms smuggling.
Collecting money through racketing by applying pressure, threat and blackmail is another
illegal financial method.
Terrorist organizations also engage in human trafficking and migrant smuggling in
cooperation with networks conducting activities abroad and share the profits of the crime
networks involved in these fields.
50
Extortion and robbery are methods applied by small terrorist organizations or used for the
purpose of raising necessary funds to embark on activities.
Kidnapping for ransom is a financing method which is commonly used by terrorist
organizations. Once the organization proves to be successful in these activities, it keeps on
procuring funds without kidnapping, only by way of intimidation and threat.
Gathering funds by coercion from firms and persons participating in tenders is another
method that the organizations prefer for financing.
Sources Acquired through Ostensibly Legal Activities
Terrorist organizations acquire considerable amount of their funds through ostensibly legal
activities. The followings are the major ostensibly legal activities:
Use of Non-profit Organizations
Non-profit organizations such as associations and foundations are very often used in acquiring
ostensibly legal sources for terrorist organizations. Funds raised under titles of dues,
donations or aids for these organizations are funneled to terrorist organizations or terrorists
through various methods. Some people usually do not know that the money they give will be
transferred to terrorist organizations, but they donate believing that it will be used for the
legal purpose stated by the non-profit organization. On the other hand, some people finance
terrorist organizations intentionally and willingly in ostensibly legal ways, for example by
seemingly donating for a charity association, and therefore they do not attract the attention
of public authorities.
Use of Business Entities
Income derived from legal activities of entities established by persons who apparently do not
have any relations with the organization may be used for financing of terrorism. In most
cases, fields of activity of these entities are also fields through which logistic support may be
supplied to the terrorist organization. Establishment of a transport company for the purpose
of transporting necessary goods for the terrorist organization or for using in drug trafficking
or establishment of a travel agency to make it easy for members of the terrorist organization
to go abroad may be given an example. In this respect, it is important that the obliged
parties know owners of their legal person customers and report it to MASAK after carrying out
necessary research where there is a suspicious case.
Use of Visual and Printed Media
Media firms are among the means of propaganda and financing used by terrorist
organizations. Particularly sympathizers of terrorist organization provide funds through paying
high amounts of money to visual and printed media firms under the name of advertisement
cost. Members of the organization, as well, are supported financially by demonstrating as
employees of those media firms.
Use of social activities
Terrorist organizations organize concerts, festivals, exhibitions,

demonstrations for raising funds through receiving participation fees.
charity
fairs
and
Sources Supplied by Other Countries
Beside sources of finance cited above, countries willing to use terrorism as an international
51
means of policy provide support to terrorist organizations by granting right of asylum to the
members, permitting the organizations use its territory as a base as well as financing them in
a covered or uncovered manner. These covered financial supports are particularly made
through donations in kind or in cash provided for associations and foundations that have close
relations with the terrorist organizations. These contributions are then funneled to the
terrorist organization or used by those associations and foundations to gain sympathizers for
the organization, to make the propaganda of the organization or in a way to help the
organization gain sympathy within the society.
Definition of the Suspicious or Unusual

Financing
Transaction Regarding Terrorist
The definition of suspicious or unusual transaction covers use of the asset subject to
transaction for illegal purposes in addition to acquirement of it through illegal ways, which
demonstrates that it aims essentially to prevent financing of terrorism. In this scope, cases
where there is any information, suspicion or reasonable grounds to suspect that the funds are
used for terrorist activities or by terrorist organizations, terrorists or those who finance
terrorism, or that the funds are related or linked to terrorist organizations, terrorists or those
who finance terrorism shall be subject to suspicious transaction reporting.
Suspicious or Unusual
Terrorist Financing
Transaction Types Regarding the Detection of
Suspicious or unusual transaction types regarding the detection of terrorist financing are set
out in the General Communiqu No. 6 of Financial Crimes Investigation Board (MASAK) and
th
th
detailed in the 13 and 14 suspicious transaction types above. Regardless of the sum of the
transaction, in cases where there is information, suspicion or situation causing suspicion that
the wealth subject to the transaction carried out or attempted transaction made by/over
our bank is used for terrorist actions or by terrorists, those financing terror or is associated
with these and even if the transaction in question do not match any of the mentioned types,
it is compulsory to report the situation as a suspicious transaction of terrorist financing.
B-10-4 HOW TO FILL-IN, SIGN AND SEND THE SUSPICIOUS TRANSACTION
REPORTING FORM TO COMPLIANCE DEPARTMENT
When there is a suspicious or unusual transaction, regardless of the sum of the transaction,
our branches and units that are related with remote transactions (Telephone Banking,
Internet Banking) make a research within their authorities and taking the information and
findings acquired into consideration, prepare a Suspicious Transaction Reporting Form.
While filling-in the Suspicious Transaction Reporting Form, following points are taken into
account:
Suspicious Transaction Reporting Form (Appendix 4) is issued in the electronic media.

In section A, the name of branch, The Bank (in the line saying Liable Group),
address, telephone and Taxpayer Identification Number are written.
In section B, the date of reporting, explanation whether it is a new report or not and if
it is an additional report, the date of the previous report and the urgency level of the
report are written.
In section C, information regarding the identity of the person requesting the
transaction and information whether the person is requesting this transaction on his
behalf or on behalf of others is specified. Identity information shall be specified in full.
In case where the person is requesting the transaction on behalf of someone else, the
name of the person on whose behalf the transaction is carried out is specified in
section D.
In case where the person is requesting the transaction on behalf of a legal entity, the
name of legal entity or the organization which does not have a legal personality are
52
specified in full in section E.

In section F, the date and type of the suspicious transaction, information whether the
transaction is carried out within an account, city/district and the name of the branch,
name of the unit, sum of the transaction and through which channel the transaction is
carried out are specified in full.
In cases where the transaction is carried out within an account, information regarding
the account are specified in full in section G.
In part (H) of the form, suspicious transaction types are classified. In case, suspicious
transactions to be reported are marked at that part.
Whichever classification is appropriate, suspicious transaction to be reported is marked
with an (X). Then, at the suspicious transaction typology part, the code number of
the type of suspicious transaction is written down as stated in the General
Communiqu No. 6 of MASAK.
For example, if the customer do not seek profit in his transactions, does not care the cost and
risk of his investments and gives unreasonable orders that usually end up with loss; the
empty box in the line Types Regarding the Capital Markets in section H is marked with an X
and the number of the type of the transaction which is 5.1 in this example, is written down.
It is possible that the transaction is included in more than one type (transactions with general
nature, transactions regarding the sector and terrorist financing). In this case, all of the
relevant transaction types are marked and necessary points are specified in EXPLANATIONS
part.
If a transaction matches clearly with the types found in Suspicious or Unusual Transaction
Types Regarding Terrorist Financing, this type is marked in the form. But, if the transaction
matches with the types specified in transactions with general nature or transactions regarding
the sector, and thus evokes the suspicion that it is related with terrorist financing, the
relevant transaction type is marked and the situation is specified in EXPLANATIONS part.
If the suspicious or unusual transaction does not match with any of the 3 general types, the
suspicion and information regarding the character of the transaction is specified in
EXPLANATIONS part.
Legible copy of the identity card of the customer, abstract of the account in which the
suspicious transactions are found, receipt and other related documents are attached to
the form.
B-10-5 REPORTING SUSPICIOUS OR UNUSUAL TRANSACTIONS TO MASAK

The information found in Suspicious Transaction Reporting Forms that are sent to AML Unit is
evaluated considering the relevant laws, regulations and communiqus by the AML Officer.
Then, AML Officer decides whether to send the report to MASAK or not.
In cases where it is not deemed necessary to send the report to Financial Crimes
Investigation Board, the form together with the written statement about the reason for not
sending the report are kept by the Compliance Officer for 8 years to present to authorities
when necessary.
Transactions which are deemed necessary to report, are submitted to electronic MASAK portal
with e-signature in 10 working days at the latest. However, in very urgent cases, the
suspicious transaction and the parties of the transaction are reported both to the Financial
Crimes Investigation Board and to the competent and authorized Chief Public Prosecutors
Office.
As the reports sent to the Compliance Officer are confidential documents, the form and other
correspondences are kept for 8 years away from the access of third parties.
53
If a suspicious transaction is not reported, the institution and the Officer neglecting his
obligation will be imposed an administrative penalty.
Those who report suspicious transactions and other bank personnel, who are informed of the
transaction, shall not reveal the reporting to anyone other than auditors who are in charge of
audit of obligations and courts in course of a trial. Those who do not obey this confidentiality
are charged with one to three years of imprisonment and administrative penalty up to five
thousand days.
C- TRAINING ACTIVITIES
C-1 CONTENT AND SCOPE OF TRAINING ACTIVITIES
It is a legal liability for our bank to arrange training activities regarding prevention of
laundering proceeds of crime and financing terror. These training activities are organized by
the coordination and cooperation of AML and Training units. The authority and responsibility
of effective implementation of training activities lie on Compliance Department.
C-1-1 METHODS OF TRAINING ACTIVITIES
In-class training: New employees and promoted personnel attend in-class trainings
which last a day. At the end of the day, attendants are evaluated and those who get
70 or a higher grade complete the training with success.
E-Learning: AML Unit specifies the personnel groups who should take this type of
training and informs the Training Unit of these groups. The training is held accessible
for 3 weeks for the attendants to complete this training. At the end of the training,
attendants take an evaluation test and those who get 70 or a higher grade, complete
the training with success.
Seminars: Seminars are organized in cities or regions where AML Unit finds out that
there are deficiencies or breakdowns. Personnel working in the branches of the city,
neighbor cities and Regional Offices attend these seminars. The duration of seminars
a half-day or a day is decided by taking the number of attendants into consideration.
C-1-2 CONTENT OF TRAINING ACTIVITIES

Trainings, at the minimum level, include the following:
The terms Laundering proceeds of crime and terrorist financing

Stages and methods of laundering proceeds of crime and examples (real examples
from Turkey and abroad)
Legal legislation about laundering proceeds of crime and terrorist financing
Risk areas
Institutional policy and procedures
Principles regarding the identification of the customer
Principles regarding suspicious transaction reporting
Liability to keep and present
Liability to present document and give information
Sanctions to be imposed for the breach of liabilities
International regulations on prevention of money laundering and terrorist financing
In order to help the attendants to follow the subjects, both training documents and overhead
projectors are used. The training is strengthened by Examples regarding laundering proceeds
of crime and terrorist financing and case studies.
54
C-1-3 TARGET GROUPS

The following are the target groups of the training activities:
For Branches: All staff (except for security staff members and personal assistants.)
For Headquarters: All staff (except for security staff members, IT staff members,
Construction and Real Estate staff members and personal assistants.)
C-1-4 TRAINING DOCUMENTS

All of the training documents are prepared by AML Unit.
Training notes are prepared and distributed to the attendants of in-class trainings and
overhead projector is used in order to make easier for the attendants to follow the
subjects. The documents used with overhead projectors shall include subject titles and
summarized notes. The training is strengthened by the help of examples and case
studies which are determined by the educator.
E-trainings are prepared in cooperation with Training Unit.
The duration of seminars, content and documents to be used are determined and
prepared by AML Unit by considering the lack of knowledge and problems
encountered. Training documents are distributed to the attendants.
In accordance with the amendments in national or international practice and with the
new legislation, AML Unit updates training documents.
C-1-5 TRAINERS
Trainers are determined by AML and Training Units. Trainers should be experienced and
should have completed the training of trainers arranged by Financial Crimes Investigation
Board. Before the training, trainers should attend national and international trainings,
seminars or conferences.
C-1-6 EVALUATION OF TRAINING RESULTS
The test results of e-training and in-class trainings are sent to AML Unit by Training Unit at
the end of each month.
Training Unit is informed about those who fail or who do not complete e-training. These
personnel retake this training. Those who fail for the second time, take in-class training.
Personnel who fail in-class training retake this training in the next semester.
Those who complete in-class training with success are included in e-training every year to see
the latest updates.
C-1-7 REPORTING TRAINING RESULTS TO FINANCIAL CRIMES INVESTIGATION
BOARD
Every year until the end of March, a notification about the training activities carried out in the
previous year is prepared and sent to Financial Crimes Investigation Board.
Training dates
Place of trainings (cities or regions)
Type of training
55
Duration of the training

The number of attendants and the ratio of this number to the total number of
employees
Ratio of the personnel attending the training according to units and titles
Content of the training
The title and area of expertise of trainers
The above mentioned information is prepared by Training Unit and sent to AML Unit, who
sends this information to Financial Crimes Investigation Board until the 15
latest.
th
of March at the
D- INTERNAL AUDIT ACTIVITIES

The effectiveness and efficiency of institutional policy and procedures, risk management,
follow and control activities, effectiveness of risk policy, accordance of the transactions with
law, regulations and communiqus are annually examined and monitored in a risk-based
approach.
Internal Audit Department carries out internal auditing activities regarding Prevention of
Laundering Proceeds of Crime and Terrorist Financing. Internal Audit Department determines
the scope of this type of internal auditing in accordance with the views and recommendations
of Compliance Department.
In this context;
Views and recommendations about the deficiencies, faults and misuses that are found
out within internal auditing activities are presented to Compliance Department in order
to prevent the repetition of these matters and Compliance Department prepares a
report in the light of these findings and sends the report to the Executive Board.
Customers, services and transactions bearing risks and deficiencies are included in the
audit.
Size and transaction volume of our bank are taken into account while determining the
units and transactions to be included in the audit. Within this scope, it is aimed to
audit the units and transactions having the quality and quantity that would represent
all of the transactions carried out.
Reporting internal audit results
Regarding the work carried out within the scope of internal auditing; annual transaction
volume of our bank, total number of personnel and total number of branches, agencies and
other similar units, the number of audited units, agencies and other similar units, audit dates,
total duration of audit, personnel working in internal audit and total number of transactions
audited are annually presented to Compliance Department until the end of February.
Compliance Officer presents this report to Financial Crimes Investigation Board until the end
of March.
E- RELATIONS WITH NBG GROUP COMPLIANCE DIVISION

Unless there is a contradiction with the laws prevailing in Turkey, Finansbank A. shall act in
accordance with the legislation that NBG is subject to.
Finansbank A.. Compliance Department;
56
Submits quarterly reports of regular activities to NBG Group Compliance Division.

Submits annual activity report and a detailed compliance plan for the following year to
the NBG Group Compliance Division.
Reports penalties imposed to our bank by public authorities to NBG Group Compliance
division in 48 hours.
Submits the drafts of the in-house regulations to NBG Group Compliance Division in
order to assure compliance of these regulations with the legal regulations that NBG
Group is subject to, and publishes these regulations upon taking consent from NBG
Group Compliance division and making revisions if necessary.
Informs NBG Group Compliance Division about the practices which are detected by the
regulatory and supervisory authorities to be in contradiction with the legal regulations.
Informs NBG Group Compliance Division about the scope of the investigations carried
out by the regulatory and supervisory authorities.
Submits relevant reports to the NBG Group Compliance Division, in order to

incorporate the relevant information in the report submitted by the Group to the BoG.
Submits the necessary information to the NBG Group Compliance Division at least two
(2) months prior the submission deadline to the BoG.
Notifies the NBG Group Compliance Division for all changes in the internal procedures
as well for possible upgrades of systems.
57
Appendix 1
FINANSBANK A.S.
..................BRANCH
CUSTOMER ASSESSMENT FORM
Address
Customers Name, Last
Name/Title
Country of
residence
Occupation/Commercial
activity/Main type of
business
The reason for preferring and opening account with our bank:
Recommendation
Necessity (Use of accounts with our banks

in payments to be made to customer)
Adverts or Promotion
Branch Solicitation
Use of Credit
Other
Terms of working with our bank, types of transactions to be carried out:

Deposit Accounts and Other Investment
Products
Domestic Wire Transfers and EFT
International Wire Transfers
Use of Cheque Books
TRY/Forex Cheque Collection
Use of Credit
Credit Card
POS Device
International Trade Transactions
Insurance Products
Other
Customers who work with us, from whom we can get reference information:
Information about the financial situation of the customer and other matters to
be stated:
Customer is in the High Risk Group.
Customer is not in the High Risk Group.
Necessary assessments were made regarding Know Your Customer Principles and
Procedures of Prevention of Laundering Proceeds of Crime of our Bank and customer is
appropriate for opening an account.
Customer Representatives NameSurname
Signature
Date
58
Appendix 2
SOLEMN DECLARATION BY THE LEGAL REPRESENTATIVE(s) TO OPEN A

CORPORATE ACCOUNT
(OFFSHORE COMPANIES AND COMPANIES WITH BEARER SHARES)
Messrs.
Finansbank A..
Dear Sirs,
A.
I (We) the undersigned ...

...,
in
our
capacity
as
the
Legal
Representative(s)
of
(name of company) which
wishes to apply for the opening of an account with your Bank, hereby declare
the following:
1. We are fully aware of the provisions of Law 5549 for the Prevention of
Laundering the Proceeds of Crime and Terrorist Financing and of the relevant
regulations.
In respect of the above Company we have applied our client acceptance procedures,
which, inter alia, include identification of the ultimate beneficial owners of the
Company and have conducted full enquiries regarding the nature and extent of its
business.
On the basis of the above procedures and enquires and to the best of our knowledge
and belief we hereby confirm that:
(a) At present the ultimate beneficial owner(s) of the above Company is (are) the
individual(s) listed below:
Name (1)
...........................................................
Full residential address
59
...........................................................
Nationality
.............................................................
Id Card No./ Passport No.

.............................................................
Profession / occupation
..........................................................
Name (2)
...........................................................
...........................................................
Nationality
.............................................................
.............................................................
..........................................................
Name (3)
...........................................................
...........................................................
Nationality
.............................................................
.............................................................
..........................................................
(b) The above mentioned ultimate beneficial owner(s) is (are) not directly and/or
60
indirectly involved in any criminal conduct or money laundering activity.
(c) The main business activity of the company is:

.
.
(d) The anticipated annual level of the business activity is:
.
(e) The purpose/reason for applying for the opening of the account is:
..
.
.
(f) The anticipated credit turnover in connection with all of the above
mentioned companys accounts is:
..
(g) The expected origin of the funds to be credited is:

..
.
.
(h) The expected destination of outgoing payments is:
..
.
.
2. In the event that there is any change in the above-mentioned information
and/or in the ultimate beneficial owner(s) of the above Company, I (we)
undertake to advise you immediately of any such change in writing as I (we)
will be liable for any damage towards the Finansbank A.. resulting from my
(our) omission to submit the above-mentioned changes.
3. The following documentation (or equivalent for entities registered abroad) is
enclosed in relation to the company concerned:
(a)
(b)
(c)
(d)
Abstract of Companies Registrar/

Certificate of registration by the Relevant Authorities
Memorandum and articles of association
Certificate of directors and secretary
Certificate of shareholders
61
(e)
(f)
Board resolution for the opening of an account

Board resolution appointing authorised signatories
(
g
)True copies of identity cards/passports of all
(h)
(i)
(j)
(k)
authorised signatories of the company

True copies of identity cards/passports of at least
two directors (including the managing director)
of the company
True copies of identity cards/passports of
ultimate beneficial owner(s), if different from persons
covered by (g) or (h)
Copy of the Trust Deed of Appointment of
Nominees
Written confirmation by the Legal Representative(s)
regarding the ownership structure leading to the
ultimate beneficial owner (diagrammatical or otherwise)
Signed by the said Legal Representative(s)
..
..
Name(s) (in print) and position
Date
In witness of Officer / employee of Bank:

S
i
g
n
e
d ....
Name /position
Bank
Unit
....
Date
62
Appendix 3
Financial Institutions:
Other banks,
Institutions other than banks which are authorized to issue bank

cards and credit cards,
Authorized institutions stated in foreign exchange legislation,
Those who give loans within the frame of legislation on lending

money, Financing institutions,
Factoring companies,
Capital Market brokers and portfolio management

companies, Investment funds,
Investment partnerships,
Insurance,
reinsurance
and
pension
companies, Financial leasing companies,
Companies offering clearance and keeping services within the frame

of Capital Market legislation,
General Directorate of Turkish Posts and Telegraph Organization as

limited to banking transactions..
Public Administrations within the scope of Law No.5018 against which

simplified measures can be taken
PUBLIC
ADMINISTRATIONS
GOVERNMENT
WITHIN
THE
SCOPE
OF
GENERAL
1-Public Administrations Within the Scope of General Budget

1. Turkish Grand National Assembly
2. Presidency
3. Prime Ministry and Ministries
4. Constitutional Court
5. Supreme Court
6. Council of State
7. Court of Accounts
8. Secretariat General of the National Security Council
9. National Intelligence Organization
10. General Command of Gendarmerie
11. Turkish Coast Guard Command
12. General Directorate of Security
13. The Presidency of Religious Affairs
14. Prime Ministry State Planning Organization
15. Undersecretariat of Treasury
16. Undersecretariat of Foreign Trade
17. Undersecretariat of Customs
18. Undersecretariat of Maritime Affairs
19. Secretariat General for EU Affairs
20. Prime Ministry State Auditing Board
21. Prime Ministry State Personnel Ministry
22. Administration for Disabled People
23. Turkish Statistical Institute
24. Revenue Administration
63
25. General Directorate of State Hydraulic Works

26. General Directorate of Highways
27. General Directorate of Land Registry and Cadastre
28. Turkish State Meteorological Service
29. General Directorate of Agrarian Reform
30. General Directorate of Petroleum Affairs
31. General Directorate of Press and Information
32. General Directorate of Social Help and Solidarity
33. General Directorate of Social Services and Children Protection
34. General Directorate of Family and Social Researches
35. General Directorate on the Status of Women
2.Special Budgeted Administration
A)Board of Higher Education, Universities and Institutes of Technology
1. Board of Higher Education
2. Student Selection and Placement Center
3. Universities and Institutes of Technology
B)Other Special Budgeted Administrations
1. Undersecretariat for Defense Industries
2. Atatrk Culture, Language and History Agency
3. Public Administration Institute for Turkey & the Middle East
4. The Scientific and Technological Research Council of Turkey
5. The Turkish Academy of Sciences
6. The Turkish Academy of Justice
7. General Directorate of Higher Education Credit and Dormitories Institution
8. General Directorate of Youth and Sports
9. General Directorate of State Theatres
10. General Directorate of State Operate and Ballet
11. General Directorate of Forestry
12. General Directorate of Foundations
13. General Directorate of Health for Borders and Coasts
14. General Directorate of Electrical Power Resources Survey and Development
Administration
15. General Directorate of Mineral Research and Exploration
16. Directorate General of Civil Aviation
17. Turkish Accreditation Agency
18. Turkish Standards Institution
19. National Productivity Center
20. Turkish Patent Institute
21. National Boron Research Institute
22. Turkish Atomic Energy Agency
23. Presidency of Development and Support of Small and Medium-Sized Enterprises
Administration
24. Export Promotion Center
25. Turkish International Cooperation and Development Agency
26. Environmental Protection Agency for Special Areas
27. Southeastern Anatolia Project Regional Development Administration
28. Privatization Administration
29. Agency for Workshops in Punishment and Correction Institutions and Prisons
30. Government Auditors Agency
31. Agency for Professional Competence
64
C)Regulatory and Supervisory Administrations

1.
2.
3.
4.
5.
6.
7.
8.
Radio and Television Supreme Council

Telecommunication Institution
Capital Market Board
Banking Regulation and Supervision Agency
Energy Market Supervisory Authority
Public Procurement Agency
Turkish Competition Authority
Tobacco, Tobacco Products and Alcoholic Beverages Market Regulation Agency
Occupational Institutes Having Specification of Public Administrations
These institutions that are nominated by secret vote are public legal entities
established in accordance with the laws with the aim of meeting the common
needs of members of an occupation, facilitating their occupational activities,
helping the occupation develop in line with general advantages, and making
honesty and trust dominant in their relationships with each other and public. The
units of these institutes are under judicial supervision of their members in line
with the principles stated in laws.
Some of these institutes are:
1. Cooperatives and senior organizations,

2. Chambers of Commerce and Industry, Chambers of Commerce, Chambers of
Industry, Chambers of Maritime Trade, Chambers of Commodity Exchange
and senior organizations,
3. Craftsmens Associations and senior organizations,
4. Chambers of Architects and Engineers and senior organizations,
5. Chamber of Medical Doctors and senior organizations,
6. Bar Associations and senior organizations.
65
Appendix 4
SUSPICIOUS TRANSACTION
REPORTING FORM
Mali Sular
Aratrma Kurulu
Bakanl
Maliye Bakanl, N Blok
Dikmen Cad. 06100
Dikmen/ANKARA
Tel: +90 (312) 415 37 67
Fax: +90 (312) 415 25 35 - 36
A- INFORMATION ABOUT THE LIABLE ISSUING THE FORM

i
Name, Surname - Title :
ii
Liable Group :
Address :
iii
Identity Number :
Tel :
B- INFORMATION ABOUT THE REPORTING
Date of Reporting
Document
New or Addition
New
Date of the previous reporting: .../.../.
Urgency level
Normal
Urgent
Very urgent
C- INFORMATION ABOUT THE LEGAL PERSON CARRYING OUT THE

SUSPICIOUS TRANSACTION
The customer is carrying out
the transaction
Is the identity card fake?
Name
Surname
Date and place of birth
Mothers Name
Fathers Name
Gender
Nationality
Identity Number
Type and Number of the
Identity Card
Address
Telephone Number
On his behalf
Else
Yes
No
Male
On behalf of someone
Female
Birth Certificate No:

Driving License No:
Passport No:
Residence Permit No:
Other (Type and Number):
Home:
Work:
Home
:
GSM
:
Work
:
Fax Number
E-mail address
Occupation
Additional information (if
necessary)
66
D- INFORMATION ABOUT THE LEGAL PERSON ON WHOSE BEHALF

v
THE TRANSACTION IS CARRIED OUT
Is the identity card fake?
Name
Surname
Place and date of birth
Mothers Name
Fathers Name
Gender
Nationality
Identity Number
Type and Number of the
Identity Card
Address
Telephone Number
Yes
No
Male
Female
Birth Certificate No:

Driving License No:
Passport No:
Residence Permit No:
Other (Type and Number):
Home:
Work:
Home
:
GSM
:
Work
:
Fax
E-mail address
Occupation:
Additional Information (if
necessary)
E- INFORMATION ABOUT THE LEGAL ENTITY/ORGANISATION WHICH

DOES NOT HAVE A LEGAL PERSONALITY IN WHOSE NAME THE
vi
TRANSACTION IS CARRIED OUT
Are the documents used for
identification fake?
vii
Title
Name of Business
Taxpayer Identification Number
viii
Register Number
Country of Founding
Place of Founding
Year of Founding
Address
Telephone Number
Yes
GSM
Work
No
:
:
Fax
E-mail Address
Web Site
Additional Information(if
necessary)
67
F- INFORMATION ABOUT THE SUSPICIOUS TRANSACTION

Date of Transaction
Is there a monetary
value/Activity in the
transaction??
The transaction is
ix
Place of Transaction
Type of Transaction
x
Sum of Transaction
Place or Method of Transaction
Single transaction :/../.

Linked transactions :/../. - ../../.
Yes
No
linked to an account (If you mark this

box, please also fill in Section G)
nor linked to an account
Branch
aATM
banking
Telephone banking
nternet
Other
G- ACCOUNT INFORMATION RELEVANT WITH THE TRANSACTION

Type of account
xi
Cheque Safe deposit box

Forward
exchange
Check exchange Current account
Investment
Other
Financial institution in which the

account is found
Account No
IBAN
Account Holder
Date of opening of the account
../../.
Date of closure of the account
Latest account balance
Branch in which the account is
found
Type of currency of the account
Is there a legal limitation on the
Yes
account?
Explanation of legal limitation
No
68
H- TYPE OF SUSPICIOUS TRANSACTION

NUMBER OF SUSPICIOUS
SUSPICIOUS TRANSACTION TYPES
SUSPICIOUS TRANSACTIONS IN THE GENERAL NATURE
Types Regarding the Customer Profile
Types Regarding the Transactions
SUSPICIOUS TRANSACTIONS ACCORDING TO THE SECTOR
Types Regarding the Banking Sector
Types Regarding the Insurance Sector
Types Regarding the Capital Markets
Types Regarding the Competent Authorities
Types Regarding the Lenders
Types Regarding the Factoring Companies
Types Regarding the Leasing Companies
Types Regarding the Consumer Finance
Types Regarding Mail Services and Courrier
Types Regarding the Real Estate Sector
SUSPICIOUS TRANSACTION TYPES REGARDING TERRORIST FINANCING
Types Regarding People who are Supposed to

Have Connection with Terrorist Organizations
The Types Regarding Non-Profit Organizations
EXPLANATION
Name-Surname and
Signature of the
xiii
Compliance Officer
69
Name and surname for legal person liable, commercial name for legal entities, name of
organisation which liables which do not have a legal personality
ii
The relevant group in found in 4
th
article of Measures Regulation
Identity Number for legal person liable, Taxpayer Identification Number for other liables
iv
Information of each legal person in transactions which are carried out by more than one
person
v
Information of each legal person in whose name the transaction is carried out in
transactions that are carried out in the name of more than one legal person
vi
Information of each legal entity in whose name the transaction is carried out in
transactions that are carried out in the name of more than one legal entity
vii
Commercial name for legal entities who are registered in the Commercial Register;
name of organisation for associations, syndicates, confederations and others which do not have
a legal personality, name of the relevant branch for political parties.
viii
Trade register number for legal entities registered in the Commercial Register, generation
number for associations, central register number for foundations, register number for syndicates
and confederations
ix
Information about the city/district and branch, agency or units in the transaction is carried
out
x
Specify the currency
iii
xi
Fill in by taking into consideration sub-clauses (a) to (h) of the 1

Measures Regulation.
st
clause of the 4
th
article of
Number of one or more suspicious transaction types found in Annex 1

In liables where it is not necessary to appoint Compliance Officer, the form is signed by
the person detecting or carrying out the transaction and if there is, by someone who is
authorized with the finalization of the transaction
xii
xiii
70
71

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FINANSBANK AML/KYC PROCEDURES

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FINANSBANK

ANTI-MONEY LAUNDERING / KNOW YOUR CUSTOMER

The provision of funds or material mediums or in any way receiving,

the concealment or disguise, through any medium, of the true nature,

terrorist activities and terrorist financing,

Suspicious transaction is the case where there is an information, suspicion or

members of Parliament (MPs),

Any transaction that is carried out on behalf of a payer, through a credit or

A credit institution or an institution engaged in equivalent activities,

Beneficial owner means natural persons who carry out a transaction

Non-profit or public benefit bodies, agencies, organizations, associations,

Inspection of the obligations introduced by the Law no 5549 on Prevention of

A- RISK MANAGEMENT ACTIVITIES

CONTROLS PRIOR TO OPENING BASE / ACCOUNTS

A-2 CUSTOMER IDENTIFICATION

A-3 IDENTIFICATION OF REAL BENEFICIARY AND LEGAL PERSONS DUE DILIGENCE

A-13-4 COLLECTIVE CUSTOMER ACCEPTANCE WITHIN THE FRAME OF SALARY PAYMENT

A-14 REPORTING OF MONITORING AND EVALUATION RESULTS TO THE BOARD OF DIRECTORS

B- MONITORING AND CONTROLLING ACTIVITIES

B-10-2 SUSPICIOUS OR UNUSUAL TRANSACTION TYPES DESCRIBED IN GENERAL

A-RISK MANAGEMENT ACTIVITIES

First of all, a Customer Assessment Form (Appendix 1) has to be prepared by the

Principles of working with our bank, types of transactions to be carried out,

Customers occupation, commercial activities, occupational history, financial status,

Customer representatives evaluation.

A-1-1 CONTROLS PRIOR TO OPENING BASE / ACCOUNTS

* EU Sanctions List, The warning list prepared by the European Union

* List of countries with which no transactions will be performed prepared by

* Capital Market Board Prohibited Investors including the persons/institutions that

* Finans_Base_OFAC - should be controlled in the OFAC list.

* Finans_Base_Uyar - should be controlled in the Finansbank Alert List. If there is a

one-to-one match, AML Unit should be informed.

used by Plastic Cards Department), the system automatically creates a customer

donations without obtaining permission shall be determined and announced by the

A-1-2 INDIVIDUALS AND ORGANIZATIONS NOT ACCEPTABLE AS CUSTOMERS

HIGH RISK GROUP CUSTOMERS

Their occupations/commercial activities,

Residents in Offshore Regions and special purpose vehicles (SPVs)

company regarding the verification of the beneficial owners identity or (ii)

Persons Residing and Transactions Carried out in Countries Which

announcements by FATF concerning countries or territories that do not comply or

list of countries or jurisdictions which, according to the Common Understanding of the

countries characterized by FATF as non cooperative or tax havens;

implementation of the Wolfsberg principles; and

PEP-Politically Exposed Persons

Heads of State, heads of government, ministers and deputy or assistant

Members of Parliament (MPs);

Judges of supreme courts, constitutional courts or other high-level judicial

Judges of courts of auditors;

Members of the boards of central banks;

Ambassadors and chargs d affaires;

High-ranking officers in the armed forces; and

Members of the administrative, management or supervisory bodies of stateowned enterprises.

Companies with Bearer Shares

Persons with high amount of funds (Ex. Private Banking Customers)

The identity of all the beneficial owners of such accounts is verified.

It is verified whether the owner of the account is a PEP.

Non-face-to-face transactions are conducted through alternative networks (e.g. ATMs,

Risky sectors and profession groups

Authorized institutions (foreign currency dealers).

Correspondent Banking Relationship

name and date of establishment,