AML - Anti-Money Laundering program

“NAŠA BANKA” A.D. BIJELJINA based in Karadjordjeva 1. Bijeljina operates under the supervision of the Banking Agency of Republika Srpska.

“NAŠA BANKA” A.D. BIJELJINA (hereinafter: the Bank) operates in accordance with the provisions of the Law on Prevention of Money Laundering and Financing of Terrorist Activities (Official Gazette of Bosnia and Herzegovina Nos. 47/14 and 46/16). The Bank's operations are also fully compliant with all by-laws adopted under this Law, as well as with the standards defined by the Program on minimum standards for the activities of the Bank in the prevention of money laundering and terrorist financing with policies and procedures and FATCA regulations.

The Bank's objective is to comply both with the provisions of applicable domestic laws, EU directives, and regulations, as well as with best international practice as foreseen in the regulations of the Working Party on Financial Measures against Money Laundering (FATF) and documents of other international bodies such as Basel Committee or Wolfsberg Group. In line with the above, the Bank defined the key areas as AML through a risk-based approach, customer analysis obligations, documentation (database), suspicious activity reporting and employee training.

The Bank has acted in accordance with its legal obligations and implemented its Program of Minimum Standards for the Bank's Activities to Prevent Money Laundering and Terrorism Financing (a set of internal acts to prevent money laundering and terrorist financing), which contains strict rules for preventing, detecting and reporting so-called suspicious business transactions that indicate possible money laundering and terrorist financing.

The Bank has implemented systems for identifying the Bank's customers. The more we know about our clients, their history and business activities, the more efficiently we will identify suspicious transactions and separate them from the usual client transactions, thus avoiding potential money laundering. Thanks to this, the Bank builds a business relationship with its clients based on full trust, security, and transparency. For the purpose of identifying possible suspicious transactions and persons, the Bank uses a systemic solution - application support that enables it to continuously monitor and identify possible money laundering and terrorist financing. Through application support, transaction data is integrated with customer information, which, together with information obtained after checking the client's status by accessing SWIFT - compliance applications, results in a complete overview of activities - within the system and enables accurate and accurate detection of suspicious activities.

In accordance with the "Meet Your Client" procedure and the implemented Law on Prevention of Money Laundering and Terrorism Financing, the Bank does not enter into a business relationship, or perform any transaction at the request of a client who has refused the identification procedure, and lacks the necessary information on the nature and purpose of these transactions, or if for any other reason it is not possible to complete the due diligence process.

The Bank also has an appropriate policy in place that covers relationships with politically exposed persons and is consistent with international best practices in the area of anti-money laundering.

“NAŠA BANKA” A.D. BIJELJINA does not establish correspondent relationships with shell banks or allow its clients to directly use a correspondent account or correspondent sub-account for business transactions on their behalf (eg transitional accounts). The Bank conducts regular training of employees in the field of anti-money laundering and terrorist financing. These training address topics related to the identification and reporting of transactions that we are required by law to report to the appropriate regulatory body, with various examples of money laundering that are closely related to specific banking products and services, as well as an adequate explanation of the provisions of internal anti-money laundering acts. Bijeljina, 07.02.2020.