Our Policy

As a financial institution operating in multiple jurisdictions, offering multiple products and services, BLC Bank is committed to fight against money laundering and our key principles are effectiveness and engagement. In order to fulfill this commitment, we at BLC Bank are adopting the following:

• We have enforced the compliance culture in the Bank where senior management is very committed to the implementation of appropriate controls and compliance procedures.
• We have established a Compliance Committee responsible for overseeing the Bank’s anti-money laundering policies and procedures and their implementation.
• We adhere to independent compliance, audit, risk management and legal functions to evaluate the Bank’s compliance with applicable anti-money laundering laws, rules and regulations.
• We rely on our local branch managers, relationship managers and customer service personnel to “know our customers”, to understand with whom we are dealing, and to ensure that our customers’ businesses are legitimate.
• We continuously strive to enhance our anti-money laundering policies and procedures to meet or exceed applicable laws and regulations; our staff are well trained in understanding and applying these laws and regulations.

Laws and Regulations

BLC Bank is conducting business internationally through its subsidiaries/branches in France and United Arab Emirates. Since legal and regulatory requirements differ from jurisdiction to jurisdiction, BLC Bank has set the compliance with Lebanese laws and regulations. 
Furthermove, the Bank's overseas affiliates in France ad in the UAE ensure that compliance responsibilities specific to each jurisdiction are carried out by individuals possessing the needed local knowledge and expertise. Oversight is provided by the Head of Compliance department in Lebanon in cooperation with the Bank's other risk management functions.

Lebanese Law No. 318
The main legislation applicable in Lebanon and related to anti-money laundering is outlined under the Law No. 318 dated April 20, 2001 (Fighting Money Laundering), and its amendments by Law No. 547 dated October 20, 2003.
Under the provisions of this law, any person who undertakes money laundering operations, or intervenes or participates in such operations, will be punished by imprisonment for a period of three to seven years, and be subject to a fine of no less than twenty million Lebanese Pounds.
Also, failure to reporting immediately to the Special Investigation Commission any suspicious transaction or disclosing to any person information that may prejudice money laundering investigations, will be punishable by imprisonment for a period of two months to one year and a fine not exceeding ten million Lebanese Pounds.

Banque du Liban (BDL) Regulations
BDL regulations are outlined in the Decision 8488 dated September 17, 2003 which replaces Decisions 7818 and 8142 (Regulations on the Control of Financial and Banking Operations for Fighting Money Laundering).

This Decision includes mainly the following:

• Control of financial operations for fighting money laundering;
• Checking the client’s identity, determining the economic right owner and the consequences of non-verification;
• The obligation to control certain operations;
• Committees and administrative units responsible for controlling money laundering;

Anti-Money Laundering Responsibilities

Compliance Committee
The Compliance Committee is responsible for overseeing the Bank’s anti-money laundering policies and procedures and their implementation, as well as the application of BDL Decision No. 8488 regarding Regulations on the Control of Financial and Banking Operations for Fighting Money Laundering.

Head of Compliance
The Head of Compliance acts as a staff to the Compliance Committee and to the Chairman of the Board by monitoring and reporting the results of compliance efforts of the Bank and in providing guidance to senior management on matters pertaining to compliance.

Compliance Officer
The Compliance Officer reports to the Head of Compliance by monitoring and reporting the results of compliance efforts in the Bank. The Compliance Officer reviews all KYC (Know Your Customer) forms received from branches as to the accuracy and completeness of information, ensures that all CTS (Cash Transaction Slip) forms are properly filled-in by the branches for non-exempted customers and for exempted customers who exceed the exemption limit, ensures that customers approaching the bank to open new accounts are not blacklisted, monitors the daily movements of customer’s accounts and informs the Head of Compliance of any suspicious transactions, monitors inward and outward transfers especially when received/transferred to countries know as Non-Cooperative Countries and Territories (NCCT), and asks the branches to provide any information useful to perform an investigation of suspicious transactions.

Branch Compliance Officer
Compliance Officers who reside in the branches have a reporting line to the branch manager but also have a reporting line through to the Central Compliance Department with regard to their compliance responsibilities. The Branch Compliance Officer ensures that KYC forms are properly filled-in by the Customer Service Officer and signed by the customer upon opening an account, re-verifies periodically customers’ files to ensure that all modifications to the customer profile (KYC information) are properly reflected, ensures that CTS Exemption Forms are adequately filled-in with all required details, signed by the Branch Manager, and submits it to the concerned department and to the Compliance Department, monitors transactions on accounts particularly cash transactions, and investigates and reports any suspicious case to the Central Compliance Department;

Internal Audit
The compliance and the audit functions are segregated to ensure that the activities of the compliance function are subject to independent review. The audit function should, of course, keep the compliance informed of any audit findings relating to compliance. In order to ensure that the Bank is properly implementing the provisions of the anti-money laundering policies and procedures, the Internal Audit includes in their audit program a systematic methodology for the review and assessment of internal control procedures, determines whether the internal control system is adequate and effective, ensures compliance with Central Bank regulations, particularly Decision No. 8488 regarding Regulations on the Control of Financial and Banking Operations for Fighting Money Laundering, determines through interviews, observation and inspection whether all staff are aware of and complying with the regulations, as well as internal policies and procedures, and identifies actual and potential control weaknesses and recommend feasible remedial measures for improving the system.

BLC Bank has developed detailed AML procedures to be adopted by all staff members in order to ensure that all our businesses are vigilant in detecting and preventing potential money laundering and suspicious activities. These procedures include, among others, the warning signs of money laundering, the new relationships and account opening procedures, the cash transactions procedures, the inward/outward transfers procedures, the maintenance of anti-money laundering watch list, the correspondent banking procedures, monitoring and reporting of suspicious transactions, as well as a training awareness procedures to keep staff abreast of latest methods of fighting money-laundering through seminars, workshops and other means.