Prohibition of Money Laundering and Financing of Terrorism
The Bank will only open an account after conducting a proper KYC conversation with the client, which reasonably satisfies the Bank that in the expected activity or source of funds there is no concern of money laundering, financing of terrorism, trade with enemy elements or breach of international sanctions.
The Bank operates an automatic system for screening the names of clients and service recipients against lists of terrorist operatives and organizations to prevent the risks of financing of terrorism, and against lists of elements who aid the nuclear program of Iran.
Bribery and corruption
For years, Israel has been committed to the struggle against bribery and corruption and is a member of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and of the UN Convention Against Corruption.
The Bank sees itself as a loyal partner in the international struggle against bribery and corruption, and will act to prevent its exploitation for such purposes.
The Bank will not allow the performance of actions in cases when there is a concern that the action being performed is related to bribery and corruption, and adopts appropriate mechanisms for such purpose, including by way of identifying customers who may be exposed to giving / receiving a bribe and becoming better acquainted with their expected activity and source of their funds, in order to rule out the concern that the funds involve money laundering or corruption. The Bank also maintains a table of states at risk regarding bribery and corruption, which is determined by the Transparency International (TI) organization.
International entities, including OFAC (of the U.S. Department of Finance) and the European Union, have imposed international sanctions on states, entities and individuals. There are many and diverse reasons for which sanctions are imposed: the existence of a connection to terrorism or financing of terrorism, connection to drug dealing, execution of war crimes or violation of human rights, connection to cyber-attack activity and more.
The Bank complies with these sanctions, even though is not directly subject thereto, and will not conduct activity which runs contrary to the international sanctions programs. In this context, in its procedures and computer systems, the Bank has defined the states and territories under sanctions and ensures that no activities are conducted which run contrary to the sanctions programs. The Bank also operates a system for screening the names of clients, service recipients and transaction counterparts against persons and entities listed under the various sanctions programs, to prevent the risk of breaching the international sanctions.
The policy of the Bank is determined on a group-wide basis and will be binding upon the relevant subsidiaries of Mizrahi Tefahot Ltd. and the branches of the Bank in Israel and abroad, mutatis mutandis.