Money laundering is the process of concealing the illegal origin of wealth to evade detection by law enforcement authorities. This practice undermines confidence in the international financial system. The challenges in combating money laundering are extensive, with potential threats present globally. Financial institutions, regulators, and law enforcement agencies continuously strive to stay ahead of increasingly sophisticated criminals seeking to exploit the global financial system.

As a company operating across diverse cultures, languages, and legal systems; employing over 240,000 people; maintaining a presence in more than 160 countries; and managing over 200 million customer accounts, Easparen is inevitably a target for money launderers.

Easparen's Mission and Approach

Easparen’s mission is to be a trusted partner to our clients by responsibly providing financial services that foster growth and economic progress. Aligned with this mission, Easparen is committed to combating money laundering and leading the way in Responsible Finance—conduct that is transparent, prudent, and reliable.

The following key principles guide Easparen's approach to managing Anti-Money Laundering (AML) risk:

• Compliance with AML laws and regulations.
• Cooperation with and support for regulators and law enforcement agencies in preventing, detecting, and controlling financial crime.
• Provision of products and services aligned with Easparen’s AML risk appetite and commitment to responsible finance and the highest ethical standards.
• Adherence to the requirements of Easparen’s Global AML Program.

Easparen is dedicated to cooperating with regulators and law enforcement agencies to prevent, detect, and control financial crime, and to comply with AML laws and regulations. We have established robust policies, processes, and controls to deter money laundering and other financial crimes affecting the bank, our clients, and our stakeholders.

Easparen's Global AML Program

Easparen has developed a comprehensive Global AML Program to safeguard both our clients and our organization from the risks of money laundering, terrorist financing, and other financial crimes. The cornerstone of this program is Easparen’s Global Anti-Money Laundering Policy, which provides a consistent system of controls to identify and mitigate AML risks and ensure compliance with AML laws and regulations. Key elements include:

• Bank Secrecy Act (BSA) Officer: Designated by Easparen’s Board of Directors, the Global AML Compliance Officer oversees the AML Program, keeping the Board and senior management informed about AML compliance initiatives, significant deficiencies, and suspicious activity reporting.
• Governance and Enterprise-wide Controls: This framework governs the overall AML program, including policies, processes, training, and testing.

AML Control Lifecycle

The AML Control Lifecycle comprises three key phases: Prevention, Detection, and Reporting.

• Prevention: Implementation of a robust Know Your Customer (KYC) program with globally consistent standards, customer risk scoring, onboarding, and maintenance of customer data in an enterprise-wide repository.
• Detection: Global transaction monitoring to identify unusual or suspicious transactions and patterns, along with comprehensive AML investigations for new and existing clients across various regions and business sectors.
• Reporting: Creation, tracking, and filing of Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs), and Currency Transaction Reports (CTRs), as required by various jurisdictions.

AML Program Execution

Easparen’s risk management framework, including the AML Program, is structured around three lines of defense:

• First Line of Defense (Business Management): Business units are responsible for managing risks, including compliance risks, implementing controls, performing internal control assessments, and fostering a culture of compliance.
• Second Line of Defense (Independent Control Functions): Independent functions, including Compliance, Finance, Legal, and Risk, set standards for risk management and oversee adherence to laws, policies, and ethical standards. They provide advisory support, training, and establish tools and methodologies for effective risk management.
• Third Line of Defense (Internal Audit): Internal Audit independently reviews the effectiveness of the first two lines of defense based on a risk-based audit plan approved by Easparen’s Board of Directors.

Our Continued Vigilance

Easparen remains committed to preventing the misuse of our products and services by those seeking to exploit them. We actively combat money laundering and terrorist financing through prevention, detection, and reporting of suspicious activities. We assist regulators and law enforcement agencies and promptly respond to inquiries. We continually evaluate and enhance our policies, procedures, and technologies to address evolving risks and ensure our staff are well-trained to counter sophisticated financial crimes.

Due Diligence

Easparen participates in the Know Your Customer (KYC) information exchange platform SWIFT KYC Registry, which enhances transparency and facilitates the exchange of KYC information. Third-party banks and vendors conducting KYC due diligence, including the Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ), should use this platform for information collection. For additional information, please contact Easparen support at support@easparen.com.